ML20023D761

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Forwards Revised Response to 820701 Requests for Exemption from 10CFR50.48 & App R Requirements,Per 830330 Request.Rev Reflects Compliance w/10CFR50.48 & App R Requirements & Responds to 830120 Draft SER Concerns
ML20023D761
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 05/27/1983
From: Gucwa L
GEORGIA POWER CO.
To: Stolz J
Office of Nuclear Reactor Regulation
References
NED-83-318, TAC-43754, TAC-43755, TAC-47143, TAC-48071, TAC-48072, TAC-48748, TAC-48749, TAC-54802, TAC-54803, NUDOCS 8306030233
Download: ML20023D761 (164)


Text

e Georgia Power Company 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 5246526 Maihng Address:

Post Off:ce Box 4545 Attanta. Georgia 30302 Georgia Power L T.Gucws the soutnern elecinc system Chief Nuclear Engineer NED-83-318

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May 27, 1983 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.

20555 NRC DOCKETS 50-321, 50-366 OPERATIt0 LICENSES DPR-57, tFF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 DETAILED CLARIFICATION OF REQUESTS FOR EXEt0TIONS FROM 10 CFR 50.48 AND APPENDIX R Gentlemen:

Georgia Power Company's letter dated April 28, 1983, documented our supplemental commitments related to certain requests for exemptions from 10 CFR 50.48 and Appendix R.

Those commitments reflected our understanding of an acceptable compliance method provided by the NRC staff in a March 30, 1983, meeting.

As noted in our April 28, 1983, letter, the NRC staff requested in the March 30, 1983, meeting that within twenty-eight days we submit a revision to our July 1,1982, document, " Response to 10 CFR 50.48 and Appendix R".

Since twenty-eight days did not allow sufficient time for development of the revision, an agreement was reached with the NRC Hatch Licensing Project Manager that a response supplemental to the April 28, 1983 letter of commitment would be provided by May 30, 1983. That response was to be in the format of a revision to the July 1,1982, document and developed to the same level of detail as the original requests for exemption.

That revision is enclosed herein.

The revision fully and accurately reflects those positions which, as a result of our March 30, 1983, meeting with the NRC staff, we understand to be acceptable compliance with 10 CFR 50.48 and Appendix R and responsive to the concerns raised in the NRC's draft Safety Evaluation Report transmitted by your letter dated January 20, 1983.

If for any reason, our July 1,-1982,

" Response to 10 CFR 50.48 and Appendix R",

as revised by the enclosure to this letter, along with our commitments contained in the April 28, 1983, letter, do not support the granting of the requested exemptions, we then hereby request a meeting with NRC management prior to the issuance of any denial of the requested exemptions.

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o Georgia Powerd Director of Nuclear Reactor Regulation Attention:.Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 May 27, 1983-Page Two Should you have any questions regarding this letter or its enclosure, please contact this office.

Yours very truly, l'

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L. T. Gucwa WEB /mb Enclosure xc:

J. T. Beckham, Jr.

H. C. Nix, Jr.

-J. P. O'Reilly (NRC - Region II)

Senior Resident Inspector L

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Georgia Powtr company 333 Piedmont Avsnue Atlanta. Georgia 30308 Telephone 404 526-6526

/9 Mailing Address:

V Post office Box 4545 Atlanta. Georgia 30302 Georgia Power L. T. Gucwa the soutnem electrc system Chief Nuclear Engineer NED-83-318 Power Generation Department May 27, 1983 Director of Nuclear Reactor Regulation Attention:

Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.

20555 NRC DOCKETS 50-321, 50-366 OPERATIPC LICENSES DPR-57, bPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 DETAILED CLARIFICATION OF REQUESTS FOR EXEMPTIONS FROM 10 CFR 50.48 AND APPENDIX R Gentlemen:

Georgia Power Company's letter dated April 28, 1983, documented our pd supplemental commitments related to certain requests for exemptions from 10 CFR 50.48 and Appendix R.

Those commitments reflected our understanding of an acceptable compliance method provided by the NRC staff in a March 30, 1983, meeting.

As noted in our April 28, 1983, letter, the NRC staff requested in the March 30, 1983, meeting that within twenty-eight days we submit a revision to our July 1,1982, document, " Response to 10 CFR 50.48 and Appendix R".

Since twenty-eight days did not allow sufficient time for development of the revision, an agreement was reached with the NRC Hatch Licensing Project Manager that a response supplemental to the April 28, 1983 letter of commitment would be provided by May 30, 1983. That response was to i

be in the format of a revision to the July 1,1982, document and developed to the same level of detail as the_ original requests for exemption.

That revision is enclosed herein.

i The revision fully and accurately reflects those positions which, as a l

result of our March 30, 1983, meeting with the NRC staff, we understand to be acceptable compliance with 10 CFR 50.48 and Appendix R and responsive to the concerns raised in the NRC's draft Safety Evaluation Report transmitted by your letter dated January 20, 1983.

If for any reason, our July 1, 1982,

" Response to 10 CFR 50.48 and Appendix R", as revised by the enclosure to l

this letter, along with our commitments contained in the April 28, 1983, letter, do not support the granting of the requested exemptions, we then hereby request a meeting with NRC management prior to the issrance of any denial of the requested exemptions.

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m-O ceorgiaanver A Director of. Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 May 27, 1983' Page Two Z

Should you have any questions regarding this letter or its enclosure, please contact this office.

Yours very truly,

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L. T. Gucwa WEB /mb Enclosure xc:

J. T. Beckham, Jr.

H. C. Nix, Jr.

J. P. O'Reilly (NRC - Region II)

O Senior Resident Inspector t

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RESPONSE TO 10 CFR 50.48 AND APPENDIX R 4

REVISION INSERTION INSTRUCTIONS

. June 1983 4

Title Page Replace n

Revision Status Add Table of Contents Replace List of Figures Replace Table 3-1 -(Sheet 1 of 5)

Replace (Sheet 2 of 5)

Replace (Sheet 3 of 5)

Replace Table 3-2 (Sheet 3 of 5)

Replace (Sheet 5 of 5)-

Replace Chapter 4 Replace Chapter 5 Tab Replace Chapter 5 Replace l

' Revision Insertion Instructions Discard o

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A lEDWIN'I. HATCH NUCLEAR PLANT f

UNIT 1 AND UNIT-2 L~ve

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1E ENCLOSURE 3~

t RESPONSE TO 10'CFR-50.48 AND1 APPENDIX R

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O RESPONSE TO 10 CFR 50.48 AND APPENDIX R REVISION STATUS June 1983 Date Issued j

Chapter 1 July.1982 Chapter 2 July 1982 t

Chapter 3 July 1982 Chapter-4 June 1983 Chapter,5 June 1983 i

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D RESPONSE TO'10-CFR 50.48 AND APPENDIX R TABLE 0F CONTENTS Page

1.0 INTRODUCTION

1-1 1.1 Purpose 1-1 1.2 Scope 1-1 2.0 GENERAL 2-l'

2.1 Background

2-1

.2 Exemption Requests 2-2 2

2.3 Equivalent Protection 2-3 2.4 Fire Recovery Procedures-2-4 2.5 Cold shutdown Repairs 2-4 2.6 Modification Schedule 2-5 3.0 SAFE SHUTDOWN PATHWAY EVALUATION 3-1 I

3.1 General Fire Event Description 3-1 3.2 Development of Safe Shutdown Pathways 3-3 3.2.1 Safe Shutdown Pathway 1 3-4 3.2.2 Safe Shutdown Pathway 2 3-4 3.2.3 Investigation of Pathways 3-4 3.2.4 ATTS Modifications 3-5 3.3 General Electric Company Confirmatory Analysis

,3-5 3.3.1 System Combinations 3-5 3.3.2 Performance of Shutdown Systems 3-6 4.0 SAFE SHUTDOWN ANALYSIS 4-1 1

4.1 Safe Shutdown Analyses for Unit 1 4-2 4.1.1 4160-V Transformer Room - Unit 1 4-2 l

4.1.2 West 600-V Switchgear Room - Unit 1 4-4 l

4.1.3 Annunciator Room - Unit 1 4-6 l

4.1.4 Control Building Working Floor el 112 ft -

Unit 1 4-8 4.1.5 Unit 1 Reactor Building North of Column Line R7 4-11 4.1.6 Unit 1 Reactor Building South of Column Line R7 4-22 4.1.7 West de Switchgear Room - Unit 1 4-27 4.1.8 East de Switchgear Room - Unit 1 4-29 4.1.9 East 600-V Switchgear Room - Unit 1 4-31 O

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Page 4.2 Safe Shutdown Analyses for Unit 2 4-33 4.2.1 Control Building Annunciator Room -

Unit 2 4-35 4.2.2 Control Building Health Physics Area -

Unit 2 4-37 4.2.3 Control Building Switchgear Hallway -

Unit 2 4-39 4.2.4 Control Building Oil Conditioner Room -

Unit 2 4-42 4.2.5 Control Building Station Battery Room 2B - Unit 2 4-44 4.2.6 Unit 2 Reactor Building North of Column Line R19 4-54 4.2.7 Turbine Building Condenser Bay -

Unit 2 4-62 4.2.8 Unit 2 Reactor Building South of Column Line R19 4-63 4.2.9 Turbine Building East Cableway - Unit 2 4-66 4.2.10 Diesel Building Switchgear Room 2G -

4-68 Unit 2 4.2.11 Turbine Building West Cableway el 112 ft -

Unit 1 and Unit 2 4-68 4.2.12 West de Switchgear Room - Unit 2 4-69 4.2.13 East de Switchgear Room - Unit 2 4-71 4.2.14 West 600-V Switchgear Room - Unit 2 4-73 4.2.15 East 600-V Switchgear Room - Unit 2 4-75 4.3 Safe Shutdown Analyses of Areas Common to Units 1 and 2 4-77 4.3.1 Control Building LPCI Inverter Room, Common 4-77 4.3.2 Control Building Corridor, Common 4-79 4.3.3 RPS and Vertical Cable Chase Rooms -

Common 4-86 4.3.4 East Cableway - Common 4-90 4.3.5 River Intake Structure 4-93 5.0 APPLICATION OF NFPA CODES 5-1 5.1 General 5-1 5.2 Specific Code Deviations 5-1 5.2.1 Departure from NFPA 13, 14, and 15 with Respect to Hanger Selection and Spacing 5-1 5.2.2 Departure from NFPA 13, 14, and 15 with Respect to Component Selection 5-2 5.2.3 Departures from NFPA 13 and 15 with Respect to Sprinkler Head / Nozzle Placement 5-3 ii

'.v Page 5.2.4 Departures from NFPA 72E with Respect to-Detector Placement.

5-3 5.2.5 Miscellaneous Departures from NFPA-13, 14, 15, 20, and 24 5-4 REFERENCES 1

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LIST OF TABLES Table Safe Shutdown Systems and Components List - Unit 1 (Pathway 1 to Shutdown) 3-1 Safe Shutdown Systems and Components List - Unit 1 (Pathway 2 to Shutdown) 3-2 Safe Shutdown Systems and Components List - Unit 2 (Pathway 1 to Shutdown) 3-3 Safe Shutdown Systems and Components List - Unit 2 (Pathway 2 to Shutdown) 3-4 Minimum Equipment for Safe Shutdown 3-5 Shutdown System Analysis Results 3-6 Area Description - 4160-V Transformer Room, Unit 1 4-1 Area Description - West 600-V Switchgear Room, Unit 1 4=2 Area Description - Annunciator Room, Unit 1 4-3 O

Area Description - Control Building Working Floor el 112 ft, Unit 1 4-4 Area Description - Reactor Building Working Floor el 158 ft, Unit 1 4-5 Area Description - Reactor Building CRD Accumulators and Working Floor el 130 ft, Unit 1 4-6 Area Description - Torus Room, Unit 1 4-7 Area Description - Control Building Annunciator Room, Unit 2 4-8 Area Description - Control Building Health Physics Area, Unit 2 4-9 Area Description - Control Building Switchgear Hallway, Unit 2 4-10 Area Description - Control Building Oil Conditioner Room, Unit 2 4-11 Area Description - Control Building Station Battery Room 2B, Unit 2 4-12 O

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Table Area Description - Reactor Building Working Floor el 158 ft, Unit 2 4-13 Area Description - Reactor Building HVAC Room, Unit 2 4-14 Area Description - Reactor Building Working Floor, Unit 2 4-15 Area Description - Reactor Building Torus Area, Unit 2 4-16 Area Description - Turbine Building East Cableway, Unit 2 4-17 Area Description - Diesel Building Switchgear Room 2G, Unit 2 4-18 Area Description - Control Building LP'CI Inverter Room 4-19 Area Description - Control Building Corridor 4-20 Area Description - RPS and Vertical Cable Chase Rooms 4-21 Area Description - East Cableway 4-22 Area Description - River Intake Structure 4-23

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V LIST OF FIGURES Figure HPCI Schematic Flow Diagram 3-1 Schematic Flow Diagram of Shutdown Cooling Systems II and III 3-2 Water Level Versus Time for Shutdown System I 3-3 Pressure Versus Time for Shutdown System I 3-4 Suppression Pool Temperature Versus Time for Shutdown System I 3-5 Suppression Pool Temperature Versus Time for Shutdown System II 3-6 Water Level Versus Time for Shutdown System III 3-7 Pressure Versus Time for Shutdown System III 3-8 Suppression Pool Temperature Versus Time for Shutdown System III 3-9 Pressure Versus Time for Shutdown System IV 3-10 Water Level Versus Time for Shutdown System IV-3-11 Suppression Pool Temperature Versus Time for Shutdown System IV 3-12 Pressure Versus Time for Shutdown System V with HPCI Test Line Available 3-13 Water Level Versus Time for Shutdown System V with HPCI Test Line Available 3-14 l

Pressure Versus Time for Shutdown System V with HPCI l

Test Line Not Available 3-15 l

Water Level Versus Time for Shutdown System V with l

HPCI Test Line Not Available 3-16 Location of Fire Protection Equipment, Unit 1 Turbine and Control Building Plan, el 130 ft 0 in.

4-1 Location of Fire Protection Equipment, Control Building Plan, el 112 ft 0 in.

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(v Figure Location of Fire Protection Equipment, Unit 1 Reactor Building Plan, el 158 ft 0 in.

4-3 Location of Fire Protection Equipment, Unit 1 Reactor Building at el 130 ft 0 in.

4-4 Location of Fire Protection Equipment, Unit 1 Reactor Building below 130 ft 0 in.

4-5 Location of Fire Protection Equipment, Unit 2 Reactor Building Plan, el 158 ft 0 in.

4-6' Location of Fire Protection Equipment, Unit 2 Reactor Building at el 130 ft 0 in.

4-7 Location of Fire Protection Equipment, Unit 2 Reactor Building below 130 ft 0 in.

4-8 Location of Fire Protection Equipment, Unit 2 Turbine Building Plan, el 130 ft 0 in.

4-9..

Location of Fire Protection Equipment, Diesel Generator Building Plan, el-130 ft 0 in.

4-10 Locativn of Fire Protection Equipment, Control Building Partial Plats 4-11 Location of Fire Protection Equipment, River Intake 4-12 Structure Location of Fire Protection Equipment, Turbine and Control Building, Unit 1 4-13 Location of Fire Protection Equipment, Turbine Building, Unit 2 4-14 Location of Fire Protection Equipment, Reactor and Radwaste Buildings, el 185 ft 0 in. - Unit 1 4-15 Location of Fire Protection Equipment, Reactor and Radwaste Buildings, el 185 ft 0 in. - Unit 2 4-16 O

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TABLE 3-1 (SHEET 1 OF 5) s SAFE SHUTDOWN SYSTEMS AND COMPONENTS LIST - UNIT 1 Pathway 1 to Shutdown Systems Required 1.

RHR 2.

RHR service water 3.

RCIC 4.

ADS 5.

Plant service water 6.

RHR and RCIC emergency room ventilation system 7.

RPV level 8.

Suppression chamber temperature 9.

Suppression chamber level 10.

Recirculation system 11.

Drywell air supply 12.

Diesel generator and associated equipment System Components

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and 2.

RHR and RHR Service Water Active Passive E11-F048A E11-F017A E11-F065A E11-F028A E11-F015A E11-F047A E11-F024A E11-F008 E11-F104A E11-FOO7A E11-F009 E11-F003A E11-F004A E11-F006A E11-F091A E11-S600A E11-C002A E11-F026A E11-NO21A E11-C001A E11-F027A E11-F068A E11-N002A E11-F006C E11-R600A E11-N007A E11-F073A E11-NO15A E11-R602A E11-F119A E11-R603A E11-C001C Ell-FOllA E11-FOl6A O

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TABLE 3-1 (SHEET 2 OF 5) 3.

RCIC Active Passive E51-F045 E51-N009Aus E51-FOO7 Trip and throttle valve E51-NOO9B'"

E51-F008 Governing valve E51-N006"'

E51-F104 E51-F046 E51-N017" E51-FOO3 E51-C001 E51-N018"'

E51-F022 E51-C002 E51-N012A'"

E51-F012 E51-COO 2-1 (cond. pump)

E51-N012B'"

E51-F015 E51-C002-2 (vacuum pump) E51-NO12C"'

I E51-F013 E51-N012D" E51-F019 E51-N019Ad E51-N002 E51-N019W

E51-N019C

E51-N020 E51-NO19D"'

E51-N003 E51-R613 E51-N602A E51-F031 E51-N602B B21-N017A!"

E51-F029 B21-N017C"'

E51-F010 4.

ADS Active B21-F013A B21-F013C 5.

Plant Service Water Active Passive P41-C001A P41-F310A P41-F040A P41-F310C P41-F037A P41-F380A l

P41-F039A P41-F317A P41-LOO 3A P41-F067 P41-LOO 3C P41-F313A P41-C001C P41-F352 i

P41-LOO 2A P41-F312 P41-F310D Service water discharge valve from P51-C001A

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Will be replaced by ATTS.

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k-TABLE 3-1 (SHEET 3 OF 5) 6.

RHR and RCIC Emergency Room Ventilation Active T41-BOO 2A

  • T41-BOO 4A 7.

RPV Level Active B21-NO37 B21-R610 B21-R604A B21-NO26A 8.

Suppression Chamb'r Temperature e

Active T48-NOO9C O's T47-R611 T48-NOO9A T48-R630 9.

Suppressicn Chamber Level Active T48-NO70 T48-N010A T48-RO70 T48-R622 10.

Recirculation System l

Active B31 - F023A 11.

Drywell Air Method and systems required:

The Unit 1 nitrogen system will supply compressed nitrogen to the ADS valves via P70-FOOL, P70-DOO8A, P70-DOO9A, and P70-FOO4.

One service air compressor will supply compressed air via the instrument air system to the valve actuator for P70-FOO4.

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TABLE 3-2 (SHEET 3 OF 5) m 9.

Drywell Air-Method and systems The Unit 2 nitrogen system will supply compressed nitrogen to the ADS. valves via T48-F013A, T48-F013B, P70-F001, P70-D009B, and P70-F005.

The Unit 2 nitrogen system will-also supply compressed' nitrogen to valve actuator for-P70-FOO5 via PS2-F875.

Nitrogen system - Unit 2 Drywell pneumatic system (downstream of receiver P70-A001 only)

Active Passive T48-F013A T48-F112B T48-F013B 2T48-F112A PS2-F875 2T48-F104 P70-FOO1 T48-F118A P70-F005 T48-F118B 2T48-F322 2T48-F327 N

T48-F112A 10.

Diesel Generator A.

R43-S001 A, B,

C (skid-mounted equipment) 1.

Diesel relay terminal box 2.

Engine overspeed switch (EOS) 3.

Lube oil low pressure switch (OPLS) 4.

Air vent solenoid 5.

Air start solenoids (AS1, AS2) 6.

Tachometer signal generator (TG) 7.

Tachometer 8.

Governor 9.

Speed switch (SSW) diesel 1A, 1B, 1C 10.

Lube oil pressure switch (OP1, OP2) 11.

Pushbutton switches (PB1, PB2, PB3) 12.

Selector switches 13.

Relays i

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HPCI

. Active Passive E41-F002 E41-F001 E41-N602A E41-F003 Turbine stop valve E41-N602B Turbine control valve E41-N610A E41-F111 E41-C002 E41-N610B E41-F104 E41-C002-1 E41-NO17A*8 E41-F007 (Condensate pump)

E41-N017B

E41-C002-2 E41-N001A*3 (Vacuum pump)

E41-NOOlB"'

E41-FOO4 E41-NOO1C

E41-F006 E41-NOO1D(*3 E41-F042 E41-N004(*'

E41-F041 E41-NOO5(*)

E41-COO 1 E41-NO12 A(

E41-F059 E41-N012B(*3 E41-F012 E41-N012C"8 B21-NO17B")

E41-N012D'*8 B21-NO17D(*)

E41-FOO8 E41-NO10"'

E41-F011

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E41-F051 12.

Core Spray Active Passive E21-C001B E21-F019B E21-F031B E21-F001B E21-FO:'5B E21-F015B E21-NOO6B E21-F004B E21-NOO3B E21-R601B 13.

ADS Active B21-F013K B21-F013L a.

Will be replaced by ATTS.

4.0 SAFE SHUTDOWN-ANALYSIS The design of a nuclear power plant provides certain barriers to

-the spread of fire.

These barriers are provided by separate buildings and rooms within the buildings.

The concept of

-divisional separation of redundant safety-related equipment is also used in nuclear power plant design.

This' separation serves to reduce the probability of a malfunction in both_ divisions of safety-related equipment as a result of any postulated event.

Divisional separation for electrical cables is also provided.

Separation by distance or barriers follows the approved criteria as set forth in,the Final Safety Analysis Report (FSAR).

In the investigation of the selected safe shutdown pathways, only buildings and areas containing safe shutdown components or circuits affecting those components were walked down and analyzed.

In this report, only those areas which do not presently meet the requirements of Appendix R,Section III.G, are described.

Other areas not included in this report fall into one of the following categories:

A.

No safe shutdown equipment is' contained in the area.

B.

Only one pathway of redundant equipment is contained in the area.

C.

No modifications are required for the area to meet Appendix R requirements.

Section 4.1 contains the analyses related to Unit 1 components only.

Section 4.2 contains the analyses related to Unit 2 components only.

Section 4.3 contains the analyses of areas common to Units 1 and 2 which contain safe shutdown components for both units.

O 4-1

i 4.1 SAFE SHUTDOWN ANALYSES FOR UNIT 1 4.1.1 4160-V TRANSFORMER ROOM - UNIT 1 4.1.1.1 Area Description This area contains approximately 250 ft of open area on el 2

130 ft. (See figure 4-1.)

The room contains one 4160/600-V switchgear transformer which is enclosed by walls constructed for a minimum 2-h fire resistance on all four sides to separate the area from adjacent safety-related switchgear rooms.

The east wall of the room contains a doorway opening protected by a 3-h rated sliding fire door to separate the area from the control building corridor.

Ventilation duct penetrations in the north wall are provided with 3-h rated fire dampers which are designed to close automatically upon sensing high temperatures within the duct.

Combustible loading in the area consists of cabling in conduit and fire retardant-type transformer oil for a negligible fire loading.

A summary of this area is contained in table 4-1.

4.1.1.2 Fire Protection Systems A smoke detector of the ionization type is installed to provide prompt notification of fire within the area.

Primary fire suppression is provided by two carbon dioxide (CO2) hose reels for fire brigade use.

In addition, hose stations are provided in the corridor near the area for secondary fire suppression.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Flooding is of no concern for this area since electrical equipment is pad mounted l

above floor level.

4.1.1.3 Safe Shutdown Analysis 4.1.1.3.1 For this area, it was assumed that all safe shutdown components in pathway 1 were lost in a fire and pathway 2 components would be used for cold shutdown.

The pathway 2 systems which may be affected by a fire in this area are as follows:

e Residual heat removal (RHR).

e Reactor recirculation system.

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4.1.1.3.2 The following raceway, circuits, and affected component must be protected or repaired to attain hot or cold shutdown as listed below:

Component Circuits Raceways Required for R24-SO18B R25-SO65-ES8-MO2 ESS-II-477 Hot shutdown R25-SO65-ES8-MO9 4.1.1.4 Modifications Protect conduit ESS-II-477 with a 1-h barrier.

4.1.1.5 Exemotions to' Appendix R_

An exemption from the requirement for an automatic suppression system is requested due to the low combustible loading in the The proposed 1-h fire barrier ensures the availability of area.

the pathway 2 components.

An exemption is also requested from the separation criteria of paragraph III.G.2 for the 2-h area boundaries.

These boundaries are commensurate with the combustible loading for the area.

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4.1.2 WES,' 600-V SWICTHGEAR ROOM - UNIT 1 h

4.1.2.1 Area Description This area contains approximately 600 ft of floor space on el 2

130 ft. (See figure 4-1.)

This area contains one safety division of 600-V switchgear (R23-S003).

The area is enclosed on the north side by a 3-h fire barrier separating this area from the Unit 1 condenser bay.

The east, west, and south walls are constructed for a minimum 2-h fire resistance and separate the area from the east 600-V switchgear room, the oil i

conditioner room, and the west de switchgear room, respectively.

The doorway opening in the south wall is provided with a 3-h rated sliding fire door to separate this area from the control building corridor.

Ventilation ducts penetrate the east, west, and south walls.

Each duct penetration is provided with a 3-h rated fire damper which is designed to close automatically upon sensing high temperature within the duct.

The combustible loading within the room consists of 25,533 Btu /ft for cable insulation.

A summary of this area is contained in table 4-2.

4.1.2.2 Fire Protection Systems smoke detectors of the ionization type are installed at ceiling h

level to provide prompt notification of fire conditions with'in the room.

Primary fire suppression capability for this area is hose reels fcr fire brigade use.

In addition, provided by CO2 hose stations are provided for secondary protection of the In the event of a single piping failure in the fire water area.

supply system, supplemental hose lines can be supplied from remote hose staticns located throughout the plant.

Floor drains are not provided for this area; however, flooding is of no concern for the area.

4.1.2.3 Safe Shutdown Analysis 4.1.2.3.1 For this area, it was assumed that all of the safe shutdown components in pathway 1 were lost in a fire and pathway 2 components would be used for cold thutdown.

The pathway 2 systems which may be affected by a fire in this area are as follows:

Suppression chamber temperad.ure elements.

e Reactor pressure vessel (RPV) level indication.

e Suppression chamber level indication.

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e Plant service water.

e Automatic depressurization system (ADS).

4.1.2.3.2 The following raceways, circuits, and affected components must be protected or repaired to attain hot or cold shutdown:

Raceway Circuit Component R25-5037-ES4-M14 R25-SO37-ES4-M14 T48-N009D R25-SO37-ES4-M32 R25-S037-ES4-M32 T47-R612 Suppressior. chamber temperature element and indicator.

4.1.2.4 Modifications s

The following raceways will be protected with a 1-h fire barrier:

R25-SO37-ES4-M14 R25-S037-ES4-M32

(~}

The 2-h west wall will be upgraded to 3 h to provide' adequate c (_/

separation from'the oil conditioner room.

4.1.2.5 Exemptions to Appendix R An exemption from the requirement for an automatic suppression system is requested due to the low combustible loading in the area.

The proposed 1-h fire barrier will ensure the availability of the pathway-2 components.

An exemption from the 3-h separation requirement is also requested for the 2-h concrete block walls.

The 2-h minimum wall rating is commensurate with the combustible loading in the area.

i O

4-5

4.1.3 ANNUNCIATOR ROOM - UNIT 1 4.1.3.1 Area Description This area contains approximately 250 ft: of area on el 130 ft. (See figure 4-1.)

Both safety divisions of cabling are routed through the room.

One safety division of cabling is protected with a fire retardant ceramic fiber blanket designed to provide a 1-h fire resistance rating.

All four walls of this room are 3-h fire resistive barriers separating the area from the control building corridor, health physics offices, and reactor protection system (RPS) room.

The combustible loading within the room' consists of cable insulation for a fire loading of 81,852 Btu /ft.

A summary of this area is contained in 2

table 4-3.

4.1.3.2 Fire Protection Systems Smoke detection of the ionization type is installed within the room to provide prompt notification of fire conditions within the area.

Fire suppression capability is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

In addition, CO hose reels are provided 2

in the corridor near the room.

Flooding is not of concern for equipment in this area since all electrical components are mounted above floor level.

4.1.3.3 Safe Shutdown Analysis 4.1.3.3.1 For this area, it was assumed that all of the safe shutdown components in pathway 1 were lost in a fire and pathway 2 components would be used for cold shutdown.

The pathway 2 systems which may be affected by a fire in this area are as follows:

o Plant service water.

e RPV water level.

e RHR.

1 High pressure coolant injection (HPCI).

e 1

O l

4-6

[h

(_/

4.1.3.3.2 The following raceways, circuits, and~affected components must be protected or repaired to attain hot or cold shutdown as listed below:

Raceway Circuit Component ESS-I-307 R25-SO64-ES7-M25 B21-N027 TEN 7-01 B21-R605 (RPV level element and indicator)

ESS-I-308 R25-SO64-M08 B21-N026B TEN 7-01 B21-R604B (RPV level element and indicator)

ESS-I-308 R25-SO64-ES7-M22 E41-N602A TEN 7-01 E41-N610A (HPCI room AT element) 4.1.3.4 Modifications

("h

(_)

The power circuits for the above instrumentation will be routed from an instrument bus isolated from the pathway 1 circuits in this room.

4.1.3.5 Exemptions to Appendix R None.

O 4-7

4.1.4 CONTROL BUILDING WORKING FLOOR el 112 ft - UNIT 1 4.1.4.1 Area Description 2

This area contains approximately 9000 ft of floor area on el 112 ft.

(See figure 4.2.)

The area contains three air compressors each for both Units 1 and 2 located on the north and south sides of the area, respectively.

Each air compressor contains 6 gal of oil.

Cable trays containing one safety division of cabling are installed near ceiling level in this area.

In addition, vertical cable trays extend downward frcm the floor of the 130-ft elevation and contain one safety division of cabling from the RPS vertical cable chase above.

The area is enclosed by reinforced concrete or masonry walls on all four sides.

All walls are constructed for 3-h fire resistance except for the elevator shaft and stairwell enclosure in the northwest corner of the area which is constructed for 2-h fire resistance.

Doorway openings, except watertight doors, separating this area from station and RPS battery rooms, vital ac inverter rooms, and oil storage rooms are provided with 3-h rated fire doors.

The doors on the entrances to the elevator and stairwell are 1 1/2-h rated fire doors.

All ventilation duct penetrations between this area and safety-related battery rooms and oil storage rooms are provided with 3-h rated fire dampers designed to close automatically upon sensing high temperature within the duct.

Access to the west cableway is provided through a 3-h rated fire door on the west wall and access to the east corridor is provided through 3-h rated double swinging doors on the east wall.

In addition, access to all elevations of the control building is provided through the freight elevator and enclosed stairway in'the northwest corner of the area.

Five cylinders of compressed gas are located on the south side l

l of this area immediately outside the Unit 2 station battery The cylinders are secured with chains and consist of two rooms.

cylinders of propane, one cylinder of oxygen, one cylinder of l

hydrogen, and one cylinder of nitrous oxide.

The gas from these cylinders is transported through welded tubing and is used for instrumentation in the health physics labora tory directly above the 130-ft elevation.

The combustible loading for this area consists of 34,799 2

2 Btu /ft for cable insulation, 1160 Btu /ft for flammable gas potential, and a negligible fuel loading for lube oil.

A summary of this area is contained in table 4-4.

4.1.4.2 Fire Protection Systems Localized closed head, water spray protection is provided for h

the safety-related cables from the RPS vertical cable chase near 4-8

4.

(g_)

the center of the area.

Smoke detectors of the ionization type are installed throughout the area to provide prompt notification of fire conditions within the area.

Fire suppression capability for general zone protection is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event

.of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located thoughout the plant.

Floor drains near oil-containing equipment are normally closed; however, flooding is of no concern for this area due to the large floor area and concrete pads provided for electrical equipment.

The relatively open nature of the area should aid in smoke dilution.

4.1.4.3 Safe Shutdown Analysis 4.1.4.3.1 For this area, it was assumed that all of the safe shutdown components in pathway 1 were lost in a fire and pathway 2 components would be used for cold shutdown.

The pathway 2 systems which may be affected by a fire in this area are as follows:

e Containment atmosphere cooling system.

f^)/

e Containment atmospheric control system, e

Service water system.

4.1.4.3.2 Raceway R25-SO37-ES4-M14 contains circuit R25-SO37-ES4-M14 and connects R25-5037, 120/208-V ac essential cabinet 1B, to R25-S065, 120/240-V ac 1B instrument bus.

Loss

)

of this circuit would affect operation of hot shutdown components T48-N009D, T47-R612, P41-F066.

4.1.4.4 Modifications Raceway R25-SO37-ES4-M14 will be protected with a 3-h fire rated barrier to assure availability of pathway 2 components.

4.1.4.5 Exemptions to Appendix R Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown paths.

The elevator shaft and stairwell walls are 2-h rated with 1 1/2-h rated doors.

An exemption is requested for these walls based upon the very low combustible loadings inside the stairwells and elevator shaft which minimize g-)g the possibility of a fire spreading beyond the area via the

(_

l, 4-9

stairs or elevator.

The control building station battery rooms 1A and 1B utilize watertight doors which are not fire rated.

An exemption from the requirements for 3-h rated fire doors is requested based upon the necessity to protect the battery rooms from a circulating water system flood accident.

Room 1A contains only shutdown pathway 1 equipment while room 1B contains only pathway 2 equipment.

The combustible loadings for 2

these rooms are approximately 26,000 Btu /ft for cable 2

2 insulation, 3.6 Btu /f t /h for hydrogen gas, and 2450 Btu /ft for battery casings.

The replacement of the watertight doors with fire rated doors would degrade overall plant safety as fire rated watertight doors are not available.

O I

l l

l I

4-10

(M

~

UNIT 1 REACTOR BUILDING NORTH OF COLUMN LINE R7

()

4.1.5 4.1.5.1 Area Description The Unit 1 reactor building is divided into two fire areas.

The dividing line is approximately along column line R7.

The areas are separated from each other by a combination of existing concrete walls, the drywell, and a proposed water curtain system.

The. north fire area was analyzed for fire hazards as seven fire zones, one for each level of the building, two diagonal rooms, and the HPCI room on the lower level and the upper levels above el 185 ft.

4.1.5.1.1 Working Floor el 158 ft and Heating, Ventilation, and Air-Conditioning (HVAC) Room el 164 ft This zone contains approximately 5200 ft of high bay floor 2

area.

(See figure 4-3.)

The RPS instrument rack (H21-P004) and a remote shutdown panel (C82-P002) are located in this zone.

Division II cabling is routed through the zone.

The east wall and east half of the north wall are noncombustible and separate the zone from the outside.

The remainder of the north boundary and the west boundary are 3-h constructed walls.

(')T The south boundary consists of the drywell, cleanup phase x_

separators walls, existing sprinkler system in the HVAC room, and a proposed sprinkler system along column line R7 between the reactor water cleanup (RWCU) pump room and the east wall of the area.

An open stairwell in the northeast corner of the area provides access to el 130 ft and 185 ft.

No safe-shutdown related equipment is located on elevation 185 ft; the portion of el 130 ft reached via the open stairway is a part of this same fire area.

The combustible loading in the working floor of the zone consists of 13,635 Btu /ft for cable insulation and a 2

concentration of clean health physics supplies along the east wall.

The combustible loading for the HVAC room consists of 2

35,000 Btu /ft for cable insulation and 107,000 Btu /ft for 2

charcoal filters.

A summary of this zone is contained in table 4-5.

4.1.5.1.2 Control Rod Drive (CRD) Accumulators and Working Floor el 130 ft This zone contains approximately 7500 ft of floor area.

(See 2

figure 4-4.)

This zone contains Division II cable, Division II

\\

CRD accumulators, Division II monitors and temperature recorders, and safe-shutdown related motor control center (MCC)

R24-SO12.

4-11

4 Safe-shutdown related~ instrument panel H21-P173 and de MCC panel 1B (R24-SO22) are also located in the zone.

All of these components are safe-shutdown pathway 2 items.

The only pathway 1 items in the zone are certain pathway 1 cables.

The west wall of the zone is constructed for 3-h fire resistance and separates the zone from the control building.

The west half of the north wall is constructed for 3-h fire resistance and separates the zone from the radwaste building.

The remainder of the north wall and the entire east wall of the zone consist of reinforced concrete walls which separate the zone from the outside.

The south boundary consists of the drywell, the main steam chase, and a proposed water curtain cystem along column line R7.

Access to other levels of the reactor building is provided through two open stairways to el 87 ft and 158 ft.

In addition, several ceiling level penetrations communicate with the HVAC room on el 164 ft.

The zone communicates with the torus room through the open shafts of the pipe penetration room on the east side of the zone.

The floor level of the eastern half of the zone is open and is used as a laydown and working area.

Five-deep tray stacks of Division II cabling are routed in trays along the north. wall.

Most cabling in the east portion of the zone is routed in conduit.

Division II cabling in the east portion is wrapped with a ceramic fiber blanket rated for 1-h fire resistance.

The combustible loading within the zone consists of 105,262 Btu /ft for cable insulation.

Clean health physics materials 2

are stored in the northeast corner of the zone.

A summary of this, zone is contained in table 4-6.

4.1.5.1.3 Torus Room Below el 130 ft l

2 l

This zone contains approximately 6700 ft of high bay area surrounding the drywell below el 130 ft.

(See figure 4-5.)

The ceiling height is approximately 40 ft.

The zone contains the safety-related pressure suppression chamber at el 87 ft which is a relatively open area with adequate access throughout the room.

The intermediate level within the zone contains a grated walkway around the drywell and is congested above the grated walkway with safety-related piping and valves.

Few cable trays are located within the zone.

Most safety-related cabling is routed in conduit.

i The zone is enclosed on three sides by reinforced concrete walls which separate the zone from the corner rooms.

Mechanical and electrical penetrations in these four walls are not all sealed.

The south boundary of the zone consists of the drywell and proposed water curtain systems on the east and west sides of the drywell.

The only personnel access to the zone consists of one small hatch on the north side of the drywell on the el 130-ft working floor and direct access from the south torus fire zone.

4-12

'4' 4

4 p

(

The combustible loading within the zone consists'of cable

. insulation for acfire. load;of 47,968 Btu /ft.

A summary of 2

this zone is contained in tableL4-7.

ip 4.'1.5.1.4 Northeast Corner' Room Below el 130 ft t

This zone contains approximately 700 ft of congestedLfloor-2 area on each ofDthree levels below el 130 ft.

(See fi'ure-g i

4-5.)

ante zone contains one safety division ~of core spray pumps and associated cabling and two-safety-related residual RER pumps.

4 Reinforced concrete. walls surround the zone and separate it from the HPCI room.and torus room.

Electrical and mechanical ~

3 penetrations in the north and southwest. walls are unsealed.

Access from the el 130-ft working floor;is provided through a single open stairway which serves as~the only personnel access to the zone.

The combustible loading within the zone consists 2

of 44,947 Btu /ft* for cable insulation and 9191 Btu /ft for i

lube oil (13.25 gal in each of the three pumps).

4.1.5.1.5 Northwest Corner Room Below*el 130 ft t

This zone contains approximately 700 ft* of congested floor area on each of three levels below el 130 ft.

(See figure 4-5.)

This zone contains the CRD pumps.

The north and west walls of the zone consist of 3-h rated fire barriers separating the zone from the radwaste building and turbine building,-

respectively.

The southeast wall is a reinforced concreta barrier with unsealed wall penetrations.b'etween this zone and the torus room.

Access to the el 130-ft working floor is l

provided through an open stairwell which provides the only j,

personnel access to the zone.

The combustible loading within the zone consists of 39,067 Btu /ft for cable insulation and 2

less than 2 gal of lube oil in each of the CRD pumps for an additional 468 Btu /ft*.

4.1.5.1.6 HPCI Room Below el 130 ft 2

This room contains approximately 1700 ft of high bay floor area on el 87 ft.

(See figure 4-5.)

The room contains the HPCI pump and turbine and associated cabling.

The only personnel i

access to this area is through the 3-h rated fire door and double door entrance in the southeast corner of the room on the 118-ft 0-in. elevation.

The north and west walls of this room are of 3-h fire resistance construction and separate the area from the outside and from the radwaste building, respectively.

The east and south walls consist of reinforced concrete barriers separating the room from the outside and northeast corner room, respectively.

Numerous penetrations in the south wall are unsealed.

The combustible loading within the room consists of v

4-13 4

.,,.,,-.2,.---

a a

155 gal of lube oil in the HPCI pump and turbine (14,800 Btu /ft ) and cable insulation (9322 Btu /ft ) for a total 2

8 2

fire loading of 24,122 Btu /ft.

4.1.5.1.7 Upper Levels Above el 185 2

Evelvation 185 ft contains approximately 11,000 ft of relatively open area.

(See figure 4-15.)

The zone contains gonessential equipment systems including the RWCU equipment and sample systems, the fan room for the reactor. building air supply system, the decontamination room, and a seqi-open working area.

'The 203 ft elevation contains the standby liquid control i,

equipment and reactor building closed cooling water (RECCW),

surge tank, heat exchangers, an open working floor, and a, fan r

room associated with the refueling floor air-handling pystem.

n.

No safe-shutdown related equipment is located on t'he upper, elevations.

,e This zone communicates with'the north and south zones on el 158 ft via open stairwells, an open hatchway, and unsealed floor penetrations, j'-

/

F J.

4.1.5.2 Fire Protection Systems t

il' 4.1'.5.2.1 Working Floor el 158 ft and HVAC Room el 1F4 ft ll 2

/'

Fire suppression capability within the z6ne consists of the standpipe system for use by the fire brigade.> Hose stations are provided for protection of the zoni.

In the event of a single piping failure in the fire water supply system, supplemental" hose lines can be supplied from remota hose stations located

/

throughout the plant.

Floor drains are provided for this zone; i

however, flooding is not of concern for equipment in this zone I

due to the large floor area and open stairways.

The relative open nature of the zone and the open stairwell and equipment hatch would assist in smoke dilution, if necessary.

Primary fire suppression capability for the HVAC roca protection consists of a closed head preaction sprinkler system with sprinklers installed at ceiling level throughout the room.

Where congestion due to cable trays, piping, and ventilation ducts obstructs the water distribution pattern from the ceiling l

level sprinklers, additional sprinklers have been installed below the obstructions (primarily in the northern half of.the zene).

Prompt detection of fires withir the zone is provided by located product-of-combustion detectors of the ionization type l

at ceiling level throughout the HVAC room.

These~ detectors also l

serve to automatically actuate the preaction sprinkler system.

l In addition to the general zone protection, lecalized water 1

l i

4-14 l

_s

/~N

-( )

deluge systems are provided for protection within. individual charcoal filter units.. Prompt detection of. fire within the-filter units is provided by thermal devices located within each cabinet'.

4.1.5.2.2 CRD Accumulators and' Working Floor el 130 ft Smoke detectors of the ionization type are installed at ceiling level to provide pronpt notification of fire conditions c

p

-throughout\\t,he zone.

Fire suppression capability is provided by:

,'the standpipr. system for fire brigade use.

Hose stations are provided for protection of the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be. supplied from remote hose stations located

. -throughout the plant.

The large floor area, open stairwell, and 1"f'provisid'n of, floor drains eliminate.any concern regarding flooding of the zone.

The large volume of the zone and the.open hatch and open stairwells would assist in general smoke y s; dilution, if necessary.

4' u-4.1.5.2.3

~

$'oris Room Below el 130 ft Fkresuppressioh}capabilityisprovidedbythestandipesystem f

^

Y

(~5 for. fire br466derkse.

Hose stations are provided for protection 4A of'the zone; In' the event of a single piping failure in the fire water supply 1sy' stem, supplemental hose lines can be supplied from remo'cra hose stations located throughout.the k'fj' plant.

Floor drainsJare provided; however, flooding is not of 3 -

-v concern fe'r this zone.

Excessive water in this zone would not-affect other areas sines the only access is from the el 130-ft sorking floor.

w.

s,

^c 4.1.5.2.4 Northeast Corher Room Below el 130 ft

}

L.

Y

~

j

~

E reZ. suppression' capability is provided by the-standpipe system

~

'c

/for use by the fire brigade.

Hose stations are provided for

/

In the event of a single piping failure

./ protection of the zone.

[/ in,thejfire water supply system, supplemental hose lines can be plant.4'i,from remote,ho6e stations located throughout the supplied loor drainage is provided; however, flooding is not of concera for: equipment in'this zone since the pumps are mounted l ~

onconcretc/ pads-abovnfloorlevel.

C'

/'

D

, ~ ' '.,4.1.5,2.5 NorthwesE Corner Room' Below el 130 ft

(_

+

Fire suppression capability is provided by the standpipe system for. lire' brigade use.

Hose stations are provided for protection

'of-the hone.

In the event of a single piping failure in the l'

fire vat'er supply system, supplemental hose lines can be Li p

supplied from remote hose stations located throughout the l

L

~

c.,, '

t-l r

4-15 i; -

f-

$}

~

u.- -

plant.

Floor drainage is provided; however, flooding is not of h

concern for equipment within the one.

z 4.1.5.2.6 HPCI Room Below el 130 ft Primary fire suppression capability consists of the wet pipe sprinkler system installed at ceiling level to provide general area protection.

A closed head, wet pipe water curtain system is also provided at several elevations along the south wall for protection of the unsealed penetrations.

Fire detection within the area is provided by operation of the thermal elements on each individual sprinkler head and water spray nozzle.

Secondary suppression capability consists of the standpipe system for use by the fire brigade.

Hose stations are provided for protection of the zone.

Floor drains are provided within the room; however, flooding is not of concern for equipment in the room.

The room configuration prevents flooding of adjacent areas since the only personnel access is at the 118-ft elevation.

4.1.5.2.7 Upper Levels Above el 185 ft Fire suppression capability for this zone is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection'of the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided for this zone; however, flooding is not of concern for thi's zone due to the large floor area and open stairwells.

The open nature of the zone and the' existence of the open stairwells and equipment hatch would assist in smoke dilution, if necessary.

4.1.5.3 Safe Shutdown Analysis The north half of the reactor building primarily contains components and cable of safe shutdown pathway 2.

In the event of a fire in the area (at any elevation) the loss of the pathway 2 components is assumed.

For a fire north of column line R7, pathway 1 will be used to bring the reactor to cold shutdown.

The following components require protection and are located north of R7.

O 4-16

I\\/

158-ft and 164-ft elevations:

Raceway Circuit Component

.ESS-I-3595 H11-P621-ES7-C013A B21-N017A ESS-II-3599 R24-S012-E58-C17H E51-FOO7 RDC8-04 RDC8 RDC8-02 RDC8-01 130 ft-elevation:

Raceway Circuit Component ESS-II-3801 H11-P614-ESO-C116 E51-N602B RAAO-01 H11-P614-ESO-C116 E51-N602B RDA8-02 R24-S012-E58-C17H E51-F007 RDA8-01 ESS-II-3651 Below 130-ft elevation:

Raceway Circuit Component ESS-II-3295 H11-P614-ESO-C116 E51-N602B O

ESS-I-3614 H11-P657-ES9-C233 T48-N009A ESS-I-3613 H11-P657-ES9-C233 T48-N009A ESS-I-3617 H11-P657-ES9-C234 T48-NOO9C Remote shutdown panel C82-P002 is-located north of column R7 and contains~ circuits which affect valve E51-F007.

The water curtain will be extended to protect this panel.

Temperature element T48-NOO9A & C in the torus will require.

protection; 4.1.5.4 Modifications Four principal types of modifications are proposed for the reactor building.

These are a water curtain system for definition of the fire area boundaries, the wrapping of circuits to provide 1-h protection, the-rerouting of circuits to resolve conflicts, and the addition of new fire detection systems.

Except for the el 185-ft sprinkler system, the water suppression systems ~to be utilized to separate the fire areas will cover the areas of-the building in which two trains of redundant safe shutdown equipment are located.

The coverage area wil! extend from the east-west centerline of the reactor building into each fire area to a distance of 20 ft beyond the last redundant

~ t.

opposite train component - for instance, from the east-west centerline northward (into the pathway 2 area) a minimum of 4-17

20 ft beyond the redundant pathway 1 component that extends farthest into the area.

The shutdown panels are not considered in the selection of the " opposite train equipment" as they are not utilized for shutdown following a reactor building fire.

In those areas where the system serves only as an area boundary and no opposite train equipment exists, the area of coverage shall be at least 20 ft wide.

The sprinkler systems will not cover the electrical switchgear and panels that could be damaged by inadvertent actuation of the sprinklers.

Draft curtains will be installed at the ceilings as required to limit the spread of smoke across the area boundary prior to system initiation.

Existing support members will be utilized if possible to constitute all or part of these draft curtains.

The present intent is to separate the entire building into a minimum number of fire areas, such that open hatchways between floors will not constitute penetrations of fire area boundaries.

Should it be determined by analysis to be necessary to utilize a floor as a fire area boundary, a water suppression system may be proposed to provide the fire area definition at the hatchway.

A closed head sprinkler system is proposed for el 185 ft south of column line R7.

The area south of R7 will be sprinklered on this elevation except for the decontamination room.

The possibility of an inadvertent actuation of the water curtain has been investigated by Georgia Power Company (GPC).

The potential problems associated with such an incident include local flooding, a backlog of water to be processed by radwaste, and possible unit shutdown to complete ra.dwaste processing of the water.

Since a closed head sprinkler system will reduce the potential for inadvertent actuation, GPC intends to utilize a closed head sprinkler design.

GPC has analyzed the impac't of a closed head system with respect to three concerns expressed by the Nuclear Regulatory Commission (NRC) staff:

A.

The ability of electrical cables to withstand elevated temperatures prior to sprinkler head opening.

B.

The effect of smoke on opposite train equipment.

C.

The effect of smoke from the fire area on the ability of plant operators to take required action in the adjacent area.

Regarding the effect of heat on the cables, the temperature at which the sprinkler head will open will be 50 or more degrees Fahrenheit lower than the temperature the cables can withstand for an extended time without loss of insulation integrity.

4-18 L

O)

The effect of smoke on opposite train equipment will not be

(.

significant because the potentially sensitive equipment is located in metal cabinets or is similar to equipment that is part of the environmental qualification program under I&E Bulletin 79-01B.

The smoke protection afforded by these cabinets is substantial and is judged to be superior to that which would be afforded by a radiant heat barrier which would be employed in the wrapping alternative as proposed by the NRC staff in the March 30, 1983, meeting.

The metal cabinets which house potentially sensitive equipment are not airtight; however, the cabinets do provide some barrier to the passage of smoke.

The cabinets are not fan ventilated, but rely on corrective flow with the air entering near the bottom of the cabinet and exiting near the top.

The placement of the cabinets on the floors will tend to limit smoke intrusion as most smoke will accumulate near the ceilings.

The equipment in the cabinets is not particularly sensitive to smoke.

No computer cards or similar equipment is present.

The potentially sensitive electrical components are heavy duty switches, circuit breakers, relays, motor controllers, and other equipment.

While smoke damage to such heavy duty components is possible, the likelihood of the occurrence of such damage within the time required to extinguish a fire and vent the smoke is extremely small.

[h

\\ >'

The operator actions for plant shutdown following a fire in the reactor building are primarily taken from the control room.

Those manual valve operations which may be required are either not needed for a period of several hours after unit trip or the manual action is taken outside the reactor building.

While GPC acknowledges that obscuration due to smoke is a potential problem, the portable smoke removal equipment already provided as part of our response to APCSB 9.5-1, Appendix A, will be adequate for smoke removal prior to entry into the area by an operator.

Both acceptable alternatives outlined by the NRC staff require the utilization of a smoke detection system.

Georgia Power Company proposes to install a partial smoke detection system on l

the 158-ft elevation.

The system will cover the entire area covered by the proposed sprinkler system and will include i

detectors on both sides of the proposed draft curtain.

A fire detection system is proposed for the two sprinklered areas of the torus room.

The proposed system will extend throughout the sprinklered areas.

The environment in the torus area is such that smoke detectors cannot be used.

The torus area is subjected to conditions of high humidity that would cause a very high incidence of false alarms for a smoke detection system.

Therefore, a fire detection system is proposed for the sprinklered areas of the torus.

O(~N t

l l

4-19 l

Those circuits listed in paragraphs 4.1.5.3 and 4.1.6.3 as requiring protection will be wrapped with a 1-h barrier material.

The wrapping will provide the required protection throughout the analyzed fire area.

The wrapping will extend beyond the water curtain boundary of the fire area for a distance of 20 ft past the area boundary (column line R7).

Additionally, in the coverage area of the water curtain, all safe-shutdown related circuits will be wrapped.

The following circuits will be rerouted in the reactor building:

Component Circuit Present Location E51-FOO7 R24-S012-ES4-M17 130 ft north of R7 E51-FOO7 R24-SO12-E58-C17K 130 ft and 158 ft north of R7 E51-F007 R24-S012-E58-C17J 130 ft and 158 ft north of R7 E41-F002 R24-SO11-ES3-M75 130 ft south of R7 E41-FOO2 R24-SO11-ES7-C75 130 ft south of R7 E41-FOO2 R24-S011-ES7-C75A 130 ft south of R7 B21-N026A H11-P603-ESO-C047 130 ft and 158 ft north of R7 Reroute ADS from the single penetration.

O 4.1.5.5 Exemptions to Appendix R An exemption from the separation criteria of paragraph III.G.2 of Appendix R is requested for the fire area boundary between the north and south halves of the reactor building.

The proposed water curtain system and the proposed wrapping of both

~

safe shutdown trains in the water curtain portion of the floors will assure that a fire in one area of the reactor building will

.not affect the safe shutdown equipment in the other fire area.

Further, the proposed and existing fire and smoke detection systems will provide reasonable assurance that any fire will be detected early and will be extinguished by prompt fire brigade action.

The separation exemption also extends to el 185 ft.

The sprinkler system on el 185 ft will assure that any fire propogating upward from the lower elevations or originating on el 185 ft will not be able to cross from one half of the reactor building to the other via the upper levels.

An exemption from the separation criteria of paragraph III.G.2 of Appendix R is requested for the substantial concrete shield walls on el 130 ft and 158 ft.

These walls are at least 3 ft thick but are not presently rated due to the presence of unsealed penetrations.

The heavy walls and relatively small penetrations ensure that a fire will not propogate past these 4-20

'.O k/

walls prior to its detection by the proposed detection systems.

Sealing these penetrations would not materially enhance fire protection safety.

An exemption from the requirement of paragraph III.G.2 of Appendix R for an area wide automatic fire suppression and detection system for the reactor building is requested.

The relatively low combustible loading in the area poses only a minimal fire hazard.

Further, the presence of electrical components and hydraulic control rod drive units that could be damaged or disabled by inadvertent actuation of a water system indicates that the installation of such a system throughout the area would degrade overall plant safety.

Remote shutdown panel C82-P002 is a safe shutdown pathway 2 component.

It is also a safety Division II component.

One function of safety Division II is the recovery from a reactor core isolation cooling (RCIC) steam line break accident.

The recovery from such a Division I accident involves the closure of valve E51-FOO7 (the RCIC steam supply valve inside containment).

The presence of a hand switch which controls E51-F007 on the C82-F007 constitutes the presence of a shutdown pathway 1 component on a pathway 2 panel.

An exemption from the 1-h barrier requirement of paragraph III.G.2 is requested for the hand switch.

This exemption is necessary as t,he presence of the switch in the panel is mandated

\\-

by.other plant safety considerations.

The wrapping of the switch is not physically possible due to the panel configuration.

Also, wrapping of the switch would not enhance fire protection safety because the switch is isolated from the valve except when the transfer switch (also on C82-P007) is switched to the local position.

The' likelihood of a fire causing the failure of the transfer switch in the location position,. causing the E51-F007 hand switch to fail in the valve closed position thus isolating the RCIC steam supply and destroying the pathway 2 HPCI cables overhead and disabling HPCI is extremely small.

Fins.lly, the sprinkler system in.the area will be extended to cover the panel.

Thus, the combination of the very low

-combustible loading, smoke detection to assure early warning and a-response, a very remote event sequence for loss of both shutdown i

i pathways, and the other safety considerations. constitute sufficient assurance that a fire in this area will not compromise plant safety.

l l

l(

[

4-21 i

4.1.6 UNIT 1 REACTOR BUILDING SOUTH OF COLUMN LINE R7 4.1.6.1 Area Description The south reactor building fire area was analyzed for fire hazards as five fire zones, one for each level of the building and two diagonal rooms on the lower level.

4.1.6.1.1 Working Floor el 158 ft and HVAC Room el 164 ft 2

This zone contains approximately 5200 ft of high bay floor area.

(See figure 4-3.)

Reactor protection system instrument rack (H21-P005) and a remote shutdown panel (C82-P001) are located in the zone.

Division I cabling is routed through the zone.

The east wall is noncombustible and separates the zone from the outside.

The south wall is a 3-h fire resistive wall separating the zone from the adjacent motor generator (MG) set rooms.

All penetrations in the south wall have been sealed with silicone foam to prevent the spread of smoke or flames.

The west wall is a 3-h fire resistive wall except for the blowout panels that are installed to allow steam venting during a steam line break accident.

The north boundary of the zone consists of the drywell, a

concrete shield wall south of the cleanup phase separators, an existing sprinkler system in the HVAC room, and a proposed sprinkler system along column line R7 between the RWCU pump room and the east wall.

This zone is separated from the southwest stairwell enclosure by a 3-h fire resistive barrier with a 3-h rated fire door on the opening.

A 20-ft square open equipment hatch location in the southeast corner of the zone provides access to both el 130 ft and 185 ft.

The combustible loading in the working floor of the zone consists of 13,635 Btu /ft for cable insulation and a 2

concentration of clean health physics supplies along the east wall.

The combustible loading for the HVAC room consists of 2

35,000 Btu /ft for cable insulation and 107,000 Btu /ft for 2

charcoal filters.

A summary of this zone is contained in table 4-5.-

4.1.6.1.2 CRD Accumulators and Working Floor el 130 ft This zone contains approximately 7500 ft of floor area.

(See figure 4-4.)

The zone contains Division 1 cables, Division I CRD accumulators, Division I monitors and temperature recorders, and safe-shutdown related MCCs (R24-S011, R24-S018A, and R24-5018B).

4-22

Q.

i U

The west and south walls of the zone are constructed for 3-h-fire resistance and separate the zone from the control building and Unit 2 reactor building, respectively.

The east wall of the 6

zone consists of reinforced concrete walls which separate-the zone from the outside.

Access to other levels of the reactor building is provided through open stairways to el 87 ft and i

i 158 ft.

In addition, a 20-ft square open equipment hatch to upper levels of the reactor building is located in the southeast corner of the zone and several ceiling level psnetrations communicate with the HVAC room on el 164 ft.

The zone communicates with the torus room through the open shafts of the pipe penetration room and the main steam pipe chase on the east and west sides of the zone, respectively.

The floor level of the eastern half of the zone is open and is used as a laydown and working area.

Seven-deep tray stacks of Division I cabling are routed in trays along the south wall of the zone.

Most cabling in the east portion of the zone is routed in conduit.

Division II cabling in the east portion is wrapped with a ceramic fiber blanket rated for 1-h fire resistance.

The combustible loading within the zone consists of 105,262 Btu /ft for cable insulation.

Clean health physics 2

materials are stored in the southwest corner of the zone.

A i

summary of this zone is contained in table 4-6.

4.1.6.1.3 Torus Room Below el 130 ft 2

This zone contains approximately 6700 ft of high bay area j

. surrounding the drywell below el 130 ft.

(See figure 4-5.)

The ceiling height is approximately 4,0 ft.

The zone contains the safety-related pressure suppression chamber at el 87 ft which is a relatively open area with adequate access throughout the The intermediate level within the zone contains a' grated room.

i walkway around the drywell and is congested above the grated I

walkway with safet'y-related piping and valves.

Few cable trays are located within the zone.

Most safety-related cabling is routed in conduit.

j The zone is enclosed on three sides by reinforced concrete walls which separate'the zone from the corner rooms.

Mechanical and electrical penetrations in these walls are not all sealed.

The north' boundary 1of the' zone consists of the drywell and proposed i-water curtain systems on the east and west side of the drywell.

l The only personnel access to the zone is one small hatch on the south side of the drywell on the el 130-ft working floor and direct access from the north torus fire zone.

The combustible loading within the zone consists of cable insulation for a fire i

load of 47,968 Btu /ft.

A summary of this zone is contained 8

in table 4-7.

O-l 4

4-23 i

..-.,-~,,,.,_..,--_,me.~______!__4.__.,-._-.,,,--

_,._.m

._m -,- - -.,,.

_m,._

,..__.._m.m._

_.4

4.1.6.1.4 Southeast Corner Room Below el 130 ft This zone contains approximately 700 ft of congested floor area on each of three levels below el 130 ft.

(See figure 4-5.)

The zone contains one safety division of core spray pumps and associated cabling and two essential RHR pumps.

Reinforced concrete walls enclose the zone and separate it from the Unit 2 reactor building and the torus room.

Electrical and mechanical penetrations in the worthwest wall separating the zone from the torus room are unsealed.

Access from the el 130-ft working floor is provided through a single open stairwell which serves as the only personnel access to the zone.

The 2

combustible loading within the room consists of 61,803 Btu /ft for cable insulation and 9191 Btu /ft for lube oil (13.25 gal 2

in each of the three pumps).

4.1.6.1.5 Southwest Corner Room Below el 130 ft This zone contains approximately 620 ft of congested floor 2

area on each of two levels below el 130 ft.

(See figure 4-5.)

This zone contains the RCIC pump and turbine associated cabling and emergency cooling units.

Also located on the west wall of the zone is the RCIC control panel.

The south and west walls of this zone consist of 3-h rated fire barriers separating the zone from the Unit 2 reactor building and control building, respectively.

The northeast wall consists of reinforced concrete with unsealed penetrations in the wall Access to the separating the zone from the adjacent torus room.

el 130-ft working floor is provided through a single open stairway which opens into a stairway and elevator enclosure on el 130 ft.

The combustible loading within the zone consists of 2 for the 53,937 Btu /ft for cable insulation and 1320 Btu /ft 2

5 gal of lube oil in the RCIC pump and turbine.

4.1.6.2 Fire Protection Systems 4.1.6.2.1 Working Floor el 158 ft See paragraph 4.1.5.2.1.

4.1.6.2.2 CRD Accumulators and Working Floor el 130.ft See paragraph 4.1.5.2.2.

O 4-24 i

+

,1 I, : -

4.1.6.2.3-Torus Room Below el 130 ft See-paragraph 4.1.5.2.3.

4.1.6.2.4 Southeast Corner Room Below el 130 ft See paragraph 4.1.5.2.4.

k 4.1.6.2.5 Southwest Corner Room Below el 130 ft Primary. fire suppression capability consists of a' wet-pipe

~

sprinkler system installed at ceiling level to provide general-zone protection.

Fire detection is provided by actuation.of-the thermal elements on each individual sprinkler nozzle.

Secondary suppression capability consists of the standpipe system for-use 4

by the fire brigade.

Hose stations are provided for protection l

of the zone.

Floor drainage is provided; however, flooding is not of concern for equipment within'this zone.

4.1.6.3 Safe Shutdown Analysis The south half of the reactor building primarily contains lO. '

components and cable of safe shutdown pathway 1.

In the event

~

of a. fire in the area (at any elevation) the loss of pathway 1 components is assumed.

For a fire south of column line R7, pathway 2 will be used to bring the reactor to cold shutdown.

The following components require protection and are located south of column R7.

130-ft elevation:

l-Raceway Circuit Component l

ESS-I-3109 H11-P614-ES9-C054 E41-N602A L

RBA9-05 H11-P614-ES9-C054

-E41-N602A RBA9-04 H11-P614-ES9-C054 E41-N602A RBA9-03 H11-P614-ES9-C054 E41-N602A' RBA9-02 H11-P614-ES9-C054 E41-N602'A RBA9-01 H11-P614-ES9-C054 E41-N602A ESS-II-3645 R44-SOO3-ES4-M01 R24-S018B ESS-II-3648 R24-S018-ES8-C44.

R24-S018B l

ESS-II-3648 R25-S065-ES8-MO9 R24-S018B L

ESS-II-3397 R24-S012-ES8-C31E E11-F007B ESS-II-3437 H11-P614-ES9-C210 E41-N610A I

RBB9 H11-P614-ES9-C210 E41-N610A LO i

4-25 L

l-

h Below 130-ft elevation:

Raceway Circuit.

Component ESS-I-3613 H11-P657-ES9-C233 T48-N009A ESS-I-3616 H11-P657-ES9-C234 T48-N009C MCC R24-S018B is located south of R7 and contains safe shutdown circuits.

4.1.6.4 Modification See paragraph 4.1.5.4.

4.1.6.5 Exemptions to Appendix R See paragraph 4.1.5.5.

In addition to the exempti6ns listed in paragraph 4.1.5.5, an exemption from the 3-h boundary requirement is requested for the steam blowout panels in the HVAC room.

These panels are necessary to mitigate the consequences of a steam line break accident.

The removal of the panels or installation of fire resistive coatings would degrade overall plant safety.

Further, the sprinkler system in the HVAC room would limit any fire spread into the area from a turbine building fire, so modifying the panels would not enhance overall fire protection safety.

It should be noted as clarification that MCC R24-SO18B is located approximately 10 ft south of R7 and is a component in the shutdown pathway generally located in the north end of the reactor building.

However, this MCC is contained within the sprinklered area.

O 4-26

(3 5

's /

4.1.7 WEST de SWITCHGEAR ROOM - UNIT 1 4.1.7.1 Area Description 2

This area contains approximately 300 ft of floor area on el 130 ft.

(See figure 4-1.)

The area contains one division of 125/250 V-dc switchgear which is enclosed by a minimum 2-h rated fire walls on the north, east, and south sides to separate the area from the 600-V switchgear room and the control building corridor.

The west wall will be upgraded to 3-h fire resistance and separates the area from the oil conditioner room.

The doorway opening on the south wall is provided with a 3-h rated sliding fire door to separate the area from the control building corridor.

The single ventilation duct penetration through the.

west wall is provided with a 3-h rated fire damper which is designed to close automatically upon sensing high temperature within the duct.

The redundant division of de switchgear is located in a separate enclosure on the same elevation.

The 8

combustible loading within the area consists of 47,520 Btu /ft for cable insulation.

4.1.7.2 Fire Protection Systems

/~')

A fire detector of the ionization type is installed at ceiling

\\_/

level to provide prompt notification of a fire within the area.

Primary fire suppression capability for this area is provided by CO hose reels for fire brigade use.

In addition, hose stations 2

are provided for secondary protection of the area.

In tho event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Flooding is of no concern for the area since electrical equipment is pad mounted above floor level.

4.1.7.3 Safe Shutdown Analysis For this zone it was assumed that all safe shutdown components in pathway 1 were lost in a fire and pathway 2 components would be used for cold shutdown.

There are no pathway 2 components located in this area that require protection.

4.1.7.4 Modifications Upgrade wall between this area and the oil conditioner room to a 3-h barrier.

(3 4-27

4.1.7.5 Exemptions to Appendix R Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown pathways.

The north, east, and south walls of this fire area have a minimum 2-h rated fire wall.

An exemption is requested for these walls based upon the very low combustible loading inside the area.

O l

l 9

4-28 s

l 2

4.1.8 EAST de SWITCHGEAR ROOM - UNIT 1 4.1.8.1 Area Description 2

This area contains approximately 300 ft of floor area on el 130 ft.

(See figure 4-1.)

The area contains one division of 125/250 V-dc switchgear and is enclosed by 3-h rated fire walls on the east and south sides separating the area from the east cableway and health physics area, respectively.

The north and west walls are rated for a minimum 2-h fire resistance and separate the area from the 600-V switchgear and the control building corridor, respectively.

The doorway opening on the west wall is provided with a 3-h rated sliding fire door.

The single ventilation duct penetration through the north wall is provided with a 3-h rated fire damper which is designed to close automatically upon sensing'high temperature within the duct.

The redundant division of de switchgear is located in a separate enclosure on the same elevation.

The combustible loading within the area consists of 41,870 Btu /ft for cable insulation.

2 4.1.8.2 Fire Protection Systems A fire detector of the ionization type is installed at ceiling

[')

level to provide prompt notification of a fire within the area.

Primary fire suppression capability for this area is provided by

\\'

the COz hose reels for fire brigade use.

In addition, hose stations are provided for secondary protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Flooding is of no concern for the area sin ~ce electrical equipment is pad mounted above floor level.

4.1.8.3 Safe Shutdown Analysis For this area it was assumed that all safe shutdown components in pathway 2 were lost in a fire and pathway 1 components would be used for cold shutdown.

There are no pathway 1 components i

located in this area that require protection.

4.1.8.4 Modifications None.

4-29

4.1.8.5 Exemptions to Appendix R Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown pathways.

The north and west walls of this fire area have a minimum 2-h rated fire wall.

An exemption is requested for these walls based upon the very low combustible loading inside the area.

O O

4-30

)

4.1.9 EAST 600-V SWITCHGEAR ROOM - UNIT 1 4.1.9.1 Area Description This area contains approximately 600.ft* of floor area on el 130 ft.

-(See figure 4-1.)

This area contains one division of-600-V switchgear.

The area is enclosed on the north and east by 3-h rated fire barriers separating the room from the Unit 1 condenser bay and east cableway, respectively.

The west and south walls are rated for a minimum 2-h fire resistance and separate the area from the west 600-V switchgear room,. east de switchgear room and the 4160-V transformer room.

The doorway opening in the south wall is provided with a 3-h rated sliding fire door to separate the area from the control building corridor.

Ventilation ducts penetrate the west and south walls.

Each duct penetration is provided with a 3-h rated fire damper which is designed to close automatically upon sensing high temperature within the duct.

The combustible loading 2 for cable within the room consists of 21,384 Btu /ft insulation.

4.1.9.2 Fire Protection Systems

(%

Fire detectors of the ionization type are installed at ceiling

(

)

level to provide prompt notification of fire conditions within the room.

The primary-fire suppression capability for this area hose reels for fire brigade use.

In-is provided by the CO2 addition,- hose stations are provided for -secondary protection of the area.

In the event of.a single piping failure in the fire water supply system, supplemental hose-lines can be supplied from. remote hose stations located throughout the plant.

Floor i

drains'are not provided for this area; however,. flooding-is of no concern for the area.

4.1.9.3 Safe Shutdown Analysis For-this area it was assumed that all safe shutdown components in pathway 2 were lost in a fire and pathway 1 components would be used for cold shutdown.

There are no pathway 1 components located'in this area that require protection.

4.1.9.4 Modifications None.

O 4-31

4.1.9.5 Exemptions to Appendix R Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown pathways.

The west and south walls of this fire area have a minimum 2-h rated fire wall.

An exemption is requested for these walls based upon the very low combustible loading inside the area.

O 0066n 4-32

i 4'

I p-

. 4.2 SAFE SHUTDOWN ANALYSES FOR UNIT 2 f

4.2.1 CONTROL BUILDING ANNUNCIATOR ROOM - UNIT 2 3

4.2.1.1 - Area Descriotion This area contains approximately 250 ft of area on el 130 2

ft.

(See figure 4-1.)

All four walls of this-room are in 3-h fire resistive barriers separating the area from the control building corridor, health physics offices, and reactor protection systems (RPS) rooms.

The south wall contains ventilation duct penetration which is provided with a 3-h rated-

. fire damper and a 3-h rated sliding fire door.

The damper is designed to close automatically upon sensing excessive heat.

The combustible loading within the room consists of cable insulation for a fire loading _of 81,852 Btu /ft.

A summary of 2

this area is contained in table 4-8.

4.2.1.2 Fire Protection Systems i

Smoke detectors of ionization.tnae are installed. to provide l

Fire prompt notification of fire conditions'within the area.

suppression capability for this area.is provided by the standpipe system for fire brigade use.

Hose stations are.

i w

provided for protection of the area.

.In the event of a single piping failure in the fire water supply _

system, supplemental hose lines can be supplied from_ remote hose stations located through the plant.

In addition, carbon dioxide.

l (CO2) hose reels are provided in the corridor.near the room.

Flooding is of no concern for electrical equipment in this area j

which is pad mounted above floor-level.

A fire within this area could' damage equipment and-cabling i

within the roomfbut would not be expected to spread beyond.the' area.

i i

4.2.3.1 Safe Shutdown Analysis l

l 4.2.1.3.1 For this area it was assumed that all of the safe' j

shutdown components of pathway 1 were lost in a fire and pathway i

2 components would be used for_ shutdown.

The pathway 2 system which may be affected by.a fire in this' area is the residual l-heat removal (RHR)' system.

o 4-33 l

r i

n sc,

-.Y, avr.wnwn-,-,

p es-s-euw y

-m-.ev.

r-w.e mrwe y-

,,,,g p,,,,w,

---g-

,-w,m,.e wy y m

-.--n~v----~---,,m-rya,--

-e we ww.---.e,-

4.2.1.3.2 The following raceway, circuit, and components of pathway 2 must be protected:

Raceway Circuit Component 2CVA801 EAX813M01 2E11-NO15B 2E11-R603B 4.2.1.4 Modifications Reroute circuit EAX813M01 to remove it from this area.

4.2.1.5 Exemptions to Appendix R None.

O I

l l

f I

O 4-34

i l

V 4.2.2 CONTROL BUILDING HEALTH PHYSICS AREA - UNIT 2 4.2.2.1 Area Description This area contains approximately 3400 ft of floor area on el 2

130 ft.

(See figure 4-1.)

This area is subdivided using noncombustible partitions into numerous offices and laboratories for use by the health physics department.

All walls of the area are constructed for 3-h fire resistance and separate the area from the control building corridors, RPS rooms, annunciator rooms, and the east cableway of both units.

The doorway opening in the east wall is protected by a 3-h rated fire door.

Ventilation ducts which penetrate 3-h rated fire barriers are provided with 3-h rated fire dampers designed to close automatically upon sensing high temperature within the ducts.

2 Fire loading in the area consists of 5160 Btu /ft.

A summary of this area is contained in table 4-9.

4.2.2.2 Fire Protection Systems Smoke detectors of the ionization type are installed throughout the area to provide prompt notification of fire conditions within the area.

Fire suppression capability is provided by the

.,')

standpipe system for fire brigade use.

Hose stations are

~

provided for protection of the area.

In the event of a single

+

piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located hose reels are throughout the plant.

In addition, two CO2 provided in the corridor near this area.

Floor drains are provided; however, flooding is of ne concern for equipment in this area.

4.2.2.3 Safe Shutdown Analysis 4.2.2.3.1 For this zone it was assumed that all of the safe shutdown components of pathway 1 were lost in a fire and pathway 2 would be used for shutdown.

The pathway 2 systems that may be affected by a fire are:

Diesel generator 2C and power distribution.

e e

RHR.

t r-/

4-35

I I

h High pressure coolant injection (HPCI).

e e

Plant service water.

4.2.2.3.2 The following raceways, circuits, and components of pathway 2 must be protected:

Raceway Circuit Component 2CQA801 R1E803C01 2R23-S004 2CQA801 R15803E02 2R23-5004 2CQA801 RlE809C01 2R23-S004 2CQA801 R1E810C01 2R23-5004 2CQA801 R1E812C01 2R23-S004 2CRA801 EAE807M01 2R25-S002 2CRA801 EDE802M01 2R25-S002 2CRA801 EDE807M01 2R25-S002 2CRA801 EDE807M02 2R25-S002 2CRA801 PUE836C13 2P41-C001B 2CRA801 PUE856M01 2R25-S037 2CRA801 PUX817C05 2P41-F310 2CRA801 R1E803M01 2R25-S002 2CRA801 R1E827M01 2R25-S002 h

4.2.2.4 Modifications The modifications proposed are the extension of the sprinkler system in -the corridor area to cover trays 2CQA801 and 2CRA801 and the extension of the cable chase sprinkler to cover tray 2CUA701.

4.2.2.5 Exemptions to Appendix R An exemption is requested from the requirement of paragraph The III.G.2 of Appendix R for full area sprinkler coverage.

existing and proposed sprinklers provide complete coverage for the safe-shutdown related cables.

The area is generally free of combustibles except for the cable trays.

The pathway 1 and pathway 2 cables needed for safe shutdown will be separated by approximately 40 ft with sprinklers over the pathway 1 and pathway 2 trays.

Therefore, the installation of a full sprinkler would not enhance fire protection safety.

O e

4-36

n

(

I s'

4.2.3 CONTROL BUILDING SWITCHGEAR HALLWAY - UNIT 2 4.2.3.1 Area Description 2

This area contains approximately 400 ft of floor area on el 130 ft.

(See figure 4-1.)

This corridor contains both safety divisions of electrical cabinets 2R25-S001 and 2R25-S002 (separated by approximately 15 ft).

The east, west, and south walls of the area are 2-h constructed, reinforced concrete with 3-h rated fire doors on the openings.

These walls separate the area from safety-related switchgear and transformer rooms.

The east portion of the north walls is reinforced concrete and separates the area from the health physics offices.

The west portion of the north wall is open to the control building south corridor.

The control building south corridor is equipped with smoke detectors and a closed head area wide sprinkler system which will act as a water curtain to separate the control building switchgear hallway (pathway 2) from the control building common corridor (pathway 1).

The combustible loading within the area consists of 333,799 Btu /ft for cable insulation.

A summary of this area is contained in table 4-10.

4.2.3.2 Fire Protection Systems 1

\\>

Smoke detectors of the ionization type are installed throughout the area near the ceiling to provide prompt notification of fire conditions within the area.

Fire suppression capability is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

In addition, two CO2 hose reels are provided for protection of this area.

Floor drains are provided throughout the area; however, flooding is of no Concern.

4.2.3.3 Safe Shutdown Analysis 4.2.3.3.1 For this area it was assumed that all of th'e pathway 2 components were lost in a fire and pathway 1 components would be used for shutdown.

The pathway 1 system that may be affected

'by a fire in this area is the instrument air system.

4.2.3.3.2 The pathway 2 raceway, circuit, and component that must be protected are:

(~'N Raceway Circuit Component

\\)

2CTA701 PJX704M01 2R25-SO41 4-37

4.2.3.4 Modifications Reroute circuit PJX704M01 to remove it from this zone.

The analog trip transmitter system (ATTS) modification design calls for the installation of two new de distribution cabinets to supply power for the new ATTS cabinets.

The two de distribution panels presently located in the Unit 2 control building switchgear hallway will be used to supply one division of ATTS, and the two new cabinets will be used to supply the redundant division of ATTS.

These new cabinets will be located in a separate area from the de switchgear hallway to meet the separation requirements of Appendix R.

4.2.3.5 Exemptions to Appendix R Paragraph III.G.2 of Appendix R requires separation of redundant safe shutdown cables and equipment by a fire barrier having a 3-h rating as fire area boundaries.

The pathway 1 components in the control building ccmmon corridor are separated from the pathway 2 components located in the Unit 2 control building switchgear hallway by the control building south corridor.

This corridor.is 25 ft long and equipped with smoke detectors and a closed head sprinkler system.

The sprinkler system will act as a water curtain between the pathway 1 and 2 components and thus provide the required separation.

Therefore, an exemption from the requirement for a 3-h fire rated barrier between fire areas is requrested on the basis that it will not enhance overall facility safety.

O 4-38

CONTROL BUILDING OIL CONDITIONER ROOM - UNIT 2' v

4.2.4

~

4.2.4.1 Area Description 2

This fire area contains_approximately 2100 ft of open area on el 130 ft.

-(See figure 4-9.)

The room contains the electrohydraulic and_ turbine lube oil reservoir and conditioner equipment and is enclosed by reinforced concrete walls or masonry walls constructed for 3-h fire resistance, except for the east wall which is at least 2-h rated.

Personnel access to the room is provided through the opening in the north wall on which is installed a double leaf swinging fire door of 3-h fire resistance.

This door is provided with a. ramp for maintenance The ramp is approximately 18 in. high and is' sized to access.

contain all oil within the room.

The west wall of this area separates the area from the outside.

The south wall separates this area from the Unit 2 condenser bay.

The east and. north walls separate this room from the safety-related switchgear room,-control building corridor, and control building heating, ventilation, and air-conditioning (HVAC) room.

A metal equipment hatch in the ceiling provides access to the turbine operating floor on el 164-ft.

Ventilation ducts in the north and east walls are provided with 3-h rated fire dampers which are. designed to close automatically upon' sensing high temperature within the duct.

A 1-in. hydrogen line (enclosed with a 2-in. guard pipe) passes through the-width.

of the room'along the west wall from the condenser bay into the control building corricor.

The combustible loading.within the area consists'of turbine line oil (6400 gal in the oil reservoir and 895 gal in the oil conditioner) for a totalffire loading of.,

558,006 Btu /ft".

In addition, approximately 795 gal of fire retardant oil (flash point 445*F) is' contained in the electrohydraulic unit.

A summary of this area.is contained in-table 4-11, 4.2.4.2 Fire Protection Systems-Primary fire suppression capability within this area is provided' by the open head, deluge water spray system installed throughout the room to provide general area protection.

Actuation of the deluge system is effected through the' operation of the thermal detectors (pilot head system) installed in the room.

Secondary suppression capability is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of this area.

In the event of a single piping failure.in the fire water supply system, supplemental hose lines can be supplied from hose stations located throughout the plant.

Floor drains provided for this room are blocked.

Flooding is of no concern for this area, except as it~ relates to preventing the spread of burning oil into the adjacent control building corridor.

The 4-39

ramp provided at the doorway opening is approximately 18 in, high and is designed to contain all oil within the room.

This ramp will prevent overflow due to the water spray system and/or hose stream use for sufficient length of time to extinguish the fire.

4.2.4.3 Safe Shutdown Analysis 4.2.4.3.1 For this area, it was assumed that all of the safe shutdown components of pathway 1 were lost in a fire and pathway 2 components would be used for shutdown.

The pathway 2 systems that may be affected by a fire in this zone are:

o Plant service water.

e RHR system.

Diesel generator 2C and power feeds.

e e

Core spray system.

4. 2. 4.3. 2 The following raceways, circuits, and components of pathway 2 must be protected:

Raceway Circuit Component 2E23313 RIE409M01 2 R23-SOO4 2E23313 RIE412M01 2R23-S004 2E23298 PEE 802C08 2P41-F037C.

2E23298 PUE805C03 2P41-F316B 2E23294 EAE886COS 2E11-COO 1D 2E23294 PUX817C04 2P41-F310 2E23294 RIE803C03 2R23-S004 2E23294 RUE 803C05 Diesel Gen. 2C 2E23294 RUE 804C04 Diesel Gen. 2C 2E23294 RUE 805C04 Diesel Gen. 2C 2E23294 RUE 807C03 Diesel Gen. 2C 2E23294 RUE 813CO3 Diesel Gen. 2C 2E23294 RUE 829CO2 Diesel Gen. 2C 2E23290 EAE888C07 2E11-COO 2B 2E23290 EFE807MO3 2E11-F201B/D 2E23290 EFE802C06 2E11-F204D 2E23290 RHE802C06 2R22-S007 2E23290 EBE802C17 2E21-C001B 2E23290

,EBE802C19 2E21-C001B 2E23290 EBE821C04 2E21-COO 1B 2E23287 EAE884C08 2E11-COO 1B 2E23287 EAE884C09 2E11-CC01B 2E23287 RUE 811CO2 Diesel Gen. 2C 2E23287 RUE 819CO2 Diesel Gen. 2C 2E23287 RUE 821P11 Diesel Gen. 2C 4-40

j 'f%

Raceway Circuit Component 2E23312 RHE202M02 2R23-S004 2E23299 PUXO44C04 2P41-N303B 2E23289 EAE888C08 2E11-COO 2B 2E23289 PUE836C12 2P41-COO 1B.

2E23289 RUE 801C08 Diesel Gen. 2C 2E23295 EAE886C09 2E11-COO 1D 2E23295 PUE814CO3 2P41-F303B 2E23295 PUE856CO2 2P41-E339B 2E23295 RUE 821F05 Diesel Gen. 2C 2E23297 EAE821C08 2E11-C002D 2E23297 RIE803E03 2 R23-SOO4 2E23297 RUE 821P13 Diesel Gen. 2C 2E22063 RXE404M01 2R24-SO18B 2E22064 RKE602M01 2R44-SOO3 4.2.4.4 Modifications The following raceways are required for shutdown and will be protected with a 1-h fire barrier:

2E23313 2E23298

/~)

2E23294 k/

2E23290 m

2E23287 2E23312 2E23299 2E23289 2E23295 2E23297 2E22063 2E22064 The wall between the oil conditioner room and the west de and 600-V switchgear rooms will be upgraded to a.3-h fire resistance construction.

[

4.2.4.5 Exemption to Appendix R None.

l t

- \\'

l 4-41 l

l v --

m m

m.,

.~..

, _ -.. ~.

4.2.5 CONTROL BUILDING STATION BATTERY ROOMS 2B AND 2A - UNIT 2 h

4.2.5.1 Area Description 2

Battery room 2B contains approximately 900 ft of floor area on el 112 ft.

(See figure 4-2.)

The room contains one safety division of station batteries and is enclosed on all four sides by reinforced concrete walls constructed for 3-h fire resistance.

The single doorway opening is provided with a watertight door.

Two ventilation ducts penetrate the east wall of the room.

Each duct penetration is provided with a 3-h rated fire damper which is designed to close automatically upon sensing high temperature within the duct.

No penetrations exist in the west wall, which separates the area from station battery room 2A.

Electrical cables within the room are installed in conduit.

The combustible loading consists of a maximum of 3.60 2

2 Btu /f t /h for hydrogen gas, 2450 Btu /ft for battery casings, and 26,184 Btu /ft' for cable insulation.

A summary of this zone is contained in table 4-12.

Battery room 2A is similar to 2B but opposite train.

4.2.5.2 Fire Protection Systems h

Smoke detectors of the ionization type are installed at the ceiling to provide prompt detection of fire conditions in the room.

The forced air ventilation system is designed to prevent explosive concentration of hydrogen gas within the room.

Failure of the normal ventilation system power in the area is designed to initiate an clarm in the control room.

Suppression capability for a fire in this room is provided by the standpipe system for fire brigade use.

Hose stations are I

prcvided for protection of area.

In the event of a single-piping failure in the fire water supply system, supplemental i

hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided for this room; however, flooding is of no immediate concern for this area, since all batteries are located in racks with tops of batteries approximately 9 ft above floor level.

In addition, curb is i

provided on the doorway opening, and a watertight door is l

installed.

l 4.2.5.3 Safe Shutdown Analysis 4.2.5.3.1 For room 2B it was assumed that all of the safe shutdown components of pathway 2 were lost in a fire and pathway 1 components were used for shutdown.

The pathway 1 system which may be affected by a fire in this area is the drywell air llh system.

For room 2A the converse case was analyzed.

No pathway 2 components require protection for a fire in room 2A.

4-42

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~

/

-es..

/

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/,

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+

O 4;2.5.3.2 The following-raceway, circuit, and component must be protected:

Circuit Component Racewey PHX719M01 2P51-C001A/B/C I

2MBOG56' s 4.2.5.4 Modifications This circuit will be rerouted from room 2B.

No modifications are proposed for room 2A.

I 4.2.5.5 Exemptions to Appendix R Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown paths.

The single doorway in each area contains a watertight door instead of a fire rated door.

Replacing these doors with fire rated doors would degrade plant safety as the watertight doors are necessary to protect the i

station batterien from circul~ating water flood.

Therefore, an exemption from the requirement of paragraph III.G.2.A_is requested for the watertight doors.

O l

1 4-43 w..,-+-.,--

,-,-y

o 4.2.6 UNIT 2 REACTOR BUILDING NORTH OF COLUMN LINE R19 4.2.6.1 Area Description The reactor building is divided into two fire areas.

The dividing line is approximately along column line R19.

The areas are separated from each other by a combination of rated fire walls, the drywell, and a proposed water curtain system.

The north fire area was analyzed for fire hazards as five fire zones, one for each level of the building, and the two diagonal rooms on the lower level.

4.2.6.1.1 Working Floor el 158 ft 2

This zone contains approximately 4300 ft of floor area.

There are pathway 1 components in the northwest part of this elevation and pathway 1 cabling throughout the elevation.

The east wall is noncombustible and separates the zone from the outside.

The north wall is a noncombustible 3-h fire resistive barrier separating the zone from the adjacent motor generator (MG) set rooms.

All penetrations in the north wall have been sealed with silicone foam to prevent the spread of smoke or flames.

The west walls consist of 3-h fire resistive barrier separating the zone from the HVAC room.

The south boundary consists of the drywell, a concrete wall north of the cleanup phase separators, and a proposed sprinkler system along column line R19 between the reactor water cleanup (RWCU) pumproom and the east wall of the area.

A 20-ft square open equipment hatch is located in the northeast corner of the zone and provides access to both el 130 ft and 185 ft.

The combustible loading in the laydown and working floor of the zone consists of 34,367 Btu /ft for cable insulation.

Clean 2

health physics supplies are located along the east wall.

A summary of this zone is contained in table 4-13.

4.2.6.1.2 Control Rod Drive (CRD) Accumulators and Working Floor el 130 ft This zone contains approximately 7500 ft: of high bay area.

(See figure 4-7. )

This zone contains one safety division of the CRD accumulators and monitors.

The floor level of the eastern half of the zone is open and is used as a laydown and working The ceiling level of the north portion of the zone area.

contains several levels of cable trays containing Division I cables.

Except for the northwest corner of the zone described in the following sentence, Division I and II cable trays are separated by a minimum of 40 ft.

The small quantity of 4-44

g

\\

)

Division II cabling located in the northwest corner of the zone is installed.in conduit or is wrapped with fire retardant ceramic fiber blankets designed to provide 1-h fire resistance rating to separate it from the Division I cabling in the area.

Remote shutdown panels 2H21-P173 and 2C82-P001 are located in the northwest corner of the zone along the west wall.

In addition, both safety divisions of the low pressure oolant injection (LPCI) motor control centers (2R24-S018A a.id'B) are located on the east side of the zone.

Division I cabling for this motor control center is located in an open tray directly above the unit.

Cabling for Division II is in conduit or is wrapped with ceramic fiber blanket material designed to provide 1-h fire resistance.

Both safety divisions of the low pressure coolant injection (LPCI) motor control centers (MCCs) (2R24-SO18A and B) are located on the east side of the zone.

Division I cabling for this MCC is located in an open tray directly above the unit.

Cabling for Division II is in conduit or is wrapped with ceramic fiber blanket material de_ signed to provide 1-h fire resistance.

The west and north walls of the zone are constructed for 3-h fire resistance and separate the zone from the control building and Unit 1 reactor building, respectively.

The entire east wall

/s) of the zone consists of a reinforced concrete wall which separates the zone from the outside.

The south boundary of the area consists of the main steam chase, the drywell, and a proposed water curtain system along column line R19.

Access to the el 87-ft corner rooms is provided through two open stairways and to el 158 ft through an open stairway in the northwest corner of the zone.

In addition, a 20-ft square equipment that hatch is open to upper levels of the reactor f

building is located in the northeast corner of the zone.

The combustible loading within the zone consists of cable insulation for a fire loading of 116,167 Btu /ft*,

A summary of this zone is contained in table 4-15.

i 4.2.6.1.3 Torus Room Below el 130 ft 2

l This zone contains approximately 6700 ft of high Say area surrounding the drywell below el 130 ft.

(See figure 4-8 )

The zone contains the safety-related pressure suppression chamber at el 87 ft which is a relatively open area with adequate access throughout the room.

In addition, the zone contains cabling for two RHR pumps along the east wall of the room (one pump from each corner room).

The intermediate level within the zone contains a grated walkway around the drywell and is congested above the grated walkway with safety-related piping, valves, and i

N/

safety-related cabling in trays.

The zone also includes the l

main steam pipe chase on el 130 ft and 158 ft.

4-45 l

l

The north end of this zone is enclosed by reinforced concrete h

walls which separate the zone from the two corner rooms.

Mechanical and electrical penetrations in these walls are not

~

all sealed.

The south boundary of the zone consists of the drywell and proposed water curtain systems on the last and west sides of the drywell at approximately 20 degrees counterclockwise from column line R19.

The only personnel access to the zone consists of one small hatch on the north side of the drywell on el 130 ft and direct access from the south torus fire zone.

The combustible loading within the zone consists of cable insulation for a fire loading of 50,631 Btu /ft.

A summary of this zone is contained in table 4-16.

2 4.2.6.1.4 Northeast Corner Room Below el 130 ft This zone contains approximately 700 ft of congested floor 2

area on each of four levels below el 130 ft.

(See figure 4-8.)

The zone contains one safety division of core spray pumps and associated cabling and two safety-related RHR pumps.

Reinforced concrete walls enclose the zone and separate it from the torus room and the Unit I reactor building.

Electrical and mechanical penetrations in the southwest wall separating the zone from the torus room are unsealed.

Access to the el 130-ft working floor is provided through a single open stairwell which serves as the only personnel access to the zone.

The 2

combustible loading within the room consists of 29,300 Btu /ft for cable insulation and 9191 Btu /fts for lube oil (13.25 gal in each of the three pumps).

4.2.6.1.5 Northwest Corner Room Below el 130 ft This zone contains approximately 620 ft of congested floor 2

area on each of two levels below el 130 ft.

(See figure 4-8).

Thi ' zone contains the reactor core isolation cooling (RCIC) and turbine and associated cabling and emergency cooling

pum, units.

The north and west walls of this zone consist of 3-h rated fire barriers separating the zone from the Unit I reactor l

building and control building, respectively.

The southeast wall consists of reinforced concrete with unsealed penetrations in the wall which separates the zone from the adjacent torus room.

Access to the el 130-ft working floor is provided through a single open stairway which provides the only personnel access to the zone.

The combustible loading within the zone consists of l

l 39,067 Btu /ft for cable insulation and 660 Btu /ft for the 2

2 1/2 gal of lube oil in the RCIC pump and turbine.

4-46

g 4.2.6.2 Fire Protection Systems 4.2.6.2.1 Working Floor el 158 ft ~

Fire suppression capability within the zone consists of the standpipe system for fire brigade use.

Hose stations are provided for protection of the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided for this zone; however, flooding is not of concern for equipment in this zone due.to the large floor area and open stairway.

The relative open nature of the zone and the open stairwell and equipment hatch would assist in general smoke dilution, if necessary.

4.2.6.2.2 CRD Accumulators and Working Floor el 130 ft Smoke detectors of the ionization type are installed at ceiling level to provide prompt notification of fire conditions throughout the zone.

Fire suppression capability is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the zone.

In the event of-a single piping failure in the fire water supply sy= tem, supplemental Ox' hose lines can be supplied from remote hose stations located throughout the plant.

The large volume of the zone and existence of the open equipment hatch and open stairwells would assist in general smoke dilution if necessary.

4.2.6.2.3 Torus Room Below el 130 ft Fire suppression capability consists of the standpipe system for fire brigade use.

Hose stations are provided for protection of

.the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located.throughout the plant.

Floor drains are provided; however, flooding is not of concern for i

this zone.

Excessive water in this zone vould not affect other l

areas since the only access is from el 130 ft.

l l

4.2.6.2.4 Northeast Corner Room Below el 130 ft Fire suppression capability is provided by the standpipe system

(

for fire brigade use.

Hose stations are provided for protection of the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided; however, flooding is not of

,C concern for the RHR and core spray pumps in the zone since they 7

are mounted on concrete pads above floor level.

\\

4-47

4.2.6.2.5 Northwest Corner Room Below el 130 ft Primary fire suppression capability consists of an automatic sprinkler system installed at ceiling level to provide general zone potection.

Detection of fire within the zone is provided by actuation of the thermal elements on each individual sprinkler nozzle.

Secondary fire suppression capability consists of the standpipe system for use by the fire brigade.

Hose stations are provided for protection of the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided within the zone; however, flooding is not of concern for equipment within this zone.

4.2.6.3 Safe Shutdown Analysis 4.2.6.3.1 The north half of the reactor building primarily contains components and cables of safe shutdown pathway 1.

In the event of a fire in the area (at any elevation) the loss of the pathway 1 components is assumed.

Pathway 2 will be utilized for shutdown after such a fire.

The pathway 2 systems that may be affected by a fire in this area are:

e Drywell air system.

Reactor pressure vessel (RFV) level system.

e Automatic depressurization system (ADS) e e

HPCI e

RHR.

e Diesel generator 2C.

e RCIC.

4.2.6.3.2 The following pathway 2 raceways, circuits, and components must be protected:

Raceway Circuit Component 2RDA901 BAX902C01 2B21-N027 2RDA902 BAX902C01 2B21-NO27 2MR2963 BAX902C01 2B21-NO27 0

4-48 i

__1.

~

'~

Raceway-Circuit Component-2E17040.

EDE311M03 2E41-F002 2E17041

.EDE711C10 I2E41-F002-2E17041 EDE711C11 2E41-F002 2E17042 EDE711C11 2E41-F002 2E26969 EAE858M02 2E11-F015B 2E26992 PUE836C09 2P41-C001B 2E26992 PUE836M02 2P41-C001B 2RDA705 EDE703C01 HPCI system 2RDA705 EDE703CO2 HPCI system 2RDA706 EDE703CO2 HPCI system 2RDA706 EDE703C01 HPCI system 2RDA706 BCE704CO2 ADS 2RDA706 BCE707CO2 ADS 2E26969 EAE858C06 2E11-F015B 2E26969 EAE858M02 2E11-F015B 2E22073 RXE804C01 2R24-S018B 2E22073 RXE804M02 2R24-S018B 2E26932 EAE859C05 2E11-FOO7B

.[

2E26932 EAE859C04 2E11-F007B 2E26967 EAE859C05 2E11-F007B 2E26934 EAE459M01 2E11-F007B 2E26968 EAE859C04 2E11-FOO7B 2E27027 EAE459M01 2E11-F007B l

2E27025 RXE404M01 2R24-S018B 2E27308 BHE816C01 2B31-P003B 2MR2049 TGX307M01 2T48-F027 2MR2546 TGX311M02 2T48-F026-2RAA901 BAX902C01 2B21-N027 2RAA902 BAX902C01 2B21-N027 2RAB701-EDE703CO3 HPCI system 2RAB702 EDE703CO3 HPCI system 2RAB703 EDE703CO3 HPCI system 2RBL804 EAE851M02 2E11-F024B 2RBL804 EAE851CO2 2E11-F024B l

2RBL804 EAE851C04 2E11-F024B 2RBL805 EAE851M02 2E11-F024B 2RBL805 EAE851CO2 2E11-F024B 2RBL805 EAE851C04 2E11'-F02 4B.

(}

4-49 I

.... ~

Raceway Circuit Component 2RCA701 TGX711C01 2T48-F026 2RCA701 TGX711CO2 2T48-F026 2RCA702 TGX711C01 2T48-F026 2RCA703 TGX711C02 2T48-F026 2RDA706 EDE703CO2 HPCI system 2RDA706 EDE703C01 HPCI system 2RDA707 BCE704CO2 ADS 2RDA707 BCE707CO2 ADS 2RDA707 EDE703C01 HPCI system 2RDA707 EDE703CO2 HPCI system 2RDA708 BCE702C05 ADS 2RDA708 BCE702C07 ADS 2RDA708 BCE704CO2 ADS 2RDA708 BCE707CO2 ADS 2RDA709 BCE702C05 ADS 2RDA709 BCE702C07 ADS 2RDA709 BCE704CO2 ADS 2RDA709 BCE707CO2 ADS 2RDA710 BCE702C05 ADS 2RDA710 BCE702C07 ADS 2RDA710 BCE704CO2 ADS 2RDA710 BCE707CO2 ADS 2RDA708 EDE703C01 HPCI system 2RDA708 EDE703CO2 HPCI system 2RDA710 EDE703C01 HPCI system 2RDA710 EDE703C02 HPCI system 2RDA709 EDE703C01 HPCI system 2RDA709 EDE703C02 HPCI system 2RDA901 BAX902C01 2B21-NO27 2RDC701 BCE704CO2 ADS 2RDC701 BCE707CO2 ADS 2REE301 TGX307M01 2T48-F027 2RJA801 BHE816C01 2B31-P003B 2RJA801 EAE858CO6 2E11-F015B 2RJA801 EAE858M02 2E11-F015B 2E26816 EAE868C05 2E11-F015B 2RLA701 BCE702C05 ADS 2RLA701 BCE702C07 ADS h

2RNE701 TGX707C01 2T48-F027 2RNE701.

TGX707CO2 2T48-F027 4-50 L

O(_)

Raceway Circuit Component 2RNE701 TGX711C01 2T48-F026 2RNE701 TGX711CO2 2T48-F026 2E27089 EEE805C14 2E51-F007 2E27089 EEE805C15 2E51-F007 2E25326 EDE616M05 2E41-F006 2E25326 EDE616M06 2E41-F006 2E25445 EDE818C05 2E41-F008 2E25401 EDE802C30 2E41-N015A 4.2.6.4 Modifications A.

Raceways 2E26969, 2E26992, 2E27308, 2RBL804, 2RBL805, and 2RJ801 will be protected with a 1-h fire barrier.

B.

Relocate instrument circuits of 2B21-NO27 to pathway 2 side of reactor building.

C.

Reroute HPCI Division I circuits in conduit and wrap other than the ones being rerouted by the installation of ATTS.

g.

\\

D.

Relocate control and power of HPCI valve 2E41-F002 to 2R24-S011A.

E.

Install a fire suppression system over panel 2082-POO1B.

F.

Remove power at valve 2T48-F026 and F027.

G.

Relocate circuits EDE703C01 and EDE703CO2.

H.

Protect the following raceways with a 1-h barrier:

2E22073 2E27027 2E26932 2E26816 2E26934 2E27089 2E26967 2E15326 2E26968 2E25445 2E27025 2E15401 I.

Waterproof switches of panel 2C82-P001B.

J.

During the investigation of the Appendix R rule it was determined that the safety / relief valves (S/RVs) of the ADS system were required for pathways 1 and 2.

In this l

)

area it was found that the circuits, controlling all of

[

the S/RVs located in the drywell, were routed through a

(~N single penetration such that a single fire could affect

(_)

all the S/RVs; i.e., the.ones required for pathways 1 and 2.

This problem will be resolved when the 4-51 i

installation of the low-low set relief valve logic is h

completed per the requirements of the Mark I long-term program.

This logic modification, which is being installed with the ATTS system, will separate out two S/RVs from the remaining nine, thus providing the necessary separation required by Appendix R and meeting the requirement of having separate and distinct active patnway components.

K.

Install a fire suppression system on the east side of el 158 ft, el 130 ft, and el 87 ft and on the west side of el 87 ft.

See paragraph 4.1.5.4 for a description of the extent of these systems.

L.

Install a fire suppression system over MCC 2R24-S018B.

M.

' Install a partial fire detection system on el 158 ft (east side) and on el 87 ft (east and west sides).

See paragraph 4.1.5.4 for a description of the extent of these systems.

N.

H O above el 158 ft.

2 4.2.6.5 Exemptions to Appendix 2 An exemption from the separation criteria of paragraph III.G.2 h

of Appendix R is requested for the fire area boundary between the north and south halves of the reactor building.

The proposed water curtain system and the proposed wrapping of both safe shutdown trains in the water curtain portion of the floors will assure that a fire in one area of the reactor building will not affect the safe-shutdown equipment in the other fire area.

Further, the proposed existing fire and smoke detection system will provide reasonable assurance that any fire will be detected

.early and will be extinguished by prompt fire brigade action.

An exemption from the requirement of paragraph III.G.2 of l

Appendix R for~an area wide automatic fire suppression and detection system for the reactor building is requested.

The l

relatively low combustible loading in the area poses only a minimal fire hazard.

Further, the presence of electrical components and hydraulic CRD units that could be damaged or disabled by inadvertent actuation of a water system indicates that the installation of such a system throughout the area would degrade overall plant safety.

O 4-52

a

  • ~'

=

=,.

ww.._,,,%,-

An exemption is requested for the nonfire rated enclosure of MCC 2R24-S018B and panel 2C82-POO1B, which eac?_contains an intruding pathway circuit, due to the localized fire suppression system over the MCC and panel and the area wide smoke detection.

The 2682-P001B panel contains switches which will be waterproofed to provide protection against the adverse effects of the water spray.

The MCC 2R24-S018B will also be protected from the effects of the water spray.

It should be noted as clarification that MCC 2R24-S018B is located approximately 15 ft north of R18 and is a component in the shutdown pathway generally located in the south end of the reactor building.

However, this MCC is contained within the sprinklered area.

An exemption is requested for the separation criteria of paragraph III.G.2 of Appendix R for the substantial concrete shield walls on 130 ft and 158 ft.

These walls are at least 3 ft thick but are not presently fire rated due to the presence of unsealed penetrations.

The heavy walls and relatively small penetration ensure that fire will not proprogate past these walls prior to its detection by the proposed detection systems.

-Sealing these penetrations would not materially enhance fire protection safety.

v O

4-53

4.2.7 UNIT 2 REACTOR BUILDING SOUTH OF COLUMN LINE R19 h

4.2.7.1 Area Description The south half of the reactor building was analyzed for fire hazards as eight fire zones, one for each level of the building, the HVAC room on el 164 ft, two corner rooms and the HPCI room below el 130 ft, and the upper elevations (185 ft and above).

4.2.7.1.1 Working Floor el 158 ft This zone contains approximately 4300 ft of floor area.

Thi s 2

elevation contains the open working floor.

Division II cable trays are located only in the southeast corner of the zone.

The safe shutdown cabling is separated by a clear space of apprcximately 50 ft.

All safe shutdown cables.in the eastern portion of the zone are installed in conduit.

The east half of the south wall is noncombustible and separates the zone from the outside.

The west wall consists of a 3-h fire rated barrier and separates the zone from the HVAC room.

The west half of the south wall is a 3-h fire resistive barrrier separating the zone from the adjacent radwaste building.

The zone is separated from the RWCU regenerative heat exchangers in the southwest corner of the zone by reinforced concrete walls.

The north boundary consists of the drywell, a concrete shield wall north of the RWCU cleanup phase separators, and a proposed sprinkler system.

(See paragraph 4.2.6.1.1.)

An open stairwell in the southeast corner of the zone provides access to both el 130 ft and el 185 ft.

The combustible loading in the laydown and working floor of the zone consists of 34,367 Btu /ft* for cable insulation.

Clean health physics supplies are located along the east wall.

A summary of this zone is contained in table 4-13.

4.2.7.1.2 HVAC Room el 164 ft This room contains approximately 1800 ft of floor area on el 2

164 ft.

(See figure 4-6.)

This zone contains safety-related chiller units and associated cabling for the reactor building ventilation system and one safety division of cabling for steam leak detection system, CRD hydraulic system, remote shutdown and primary containment isolation systems, reactor core isolation cooling (RCIC) system, and drywell and torus pressurization.

The zone also contains both safety divisions of cabling for the RHR and main steam isolation valve (MSIV) leakage control h

systems, reactor building ventilation, standby gas treatment, 4-54

T-and drywell cooling system.

Redundant safety divisions of cabling 1are separated by a minimum of 3 ft horizontally or are separated by barriers.

In addition, thd room contains one safety division of various instrument racks and MCCs.

The north wall of this zone consists of substantial, reinforced concrete with a 3-h-fire. door on the doorway opening which provides access to the reactor. building stairwell.

The west wall consists of a 3-h fire resistive barrier separating the zone from the control and turbine buildings.

The south wall of the room consists of a. substantial reinforced concrete wall constructed for 3-h fire resistance which separates the zone from the radwaste building.

The east wall of the room consists of a 3-h constructed, reinforced concrete wall separating the zone.from the el 158-ft working floor..The combustible loading 2

within the zone consists of 34,335 Btu /ft from cable insulation.

A summary of this zone is contained in table 4-14.

4.2.7.1.3 CRD Accumulators and Working Floor el 130 ft 2

This zone contains approximately 7500 ft of high bay area.

(See figure 4-7.)

This zone contains one safety division of the CRD accumulators and monitors.

The floor level of the eastern half of the zone is open and is used as a laydown and working The ceiling level of the ' south portions of the zone

{"/)

i area.

contains several levels of cable trays containing Division II s_

cabling.

The west wall of the zone is constructed for 3-h fire resistance and separate the zone from the control building.

The west half of the south wall is constructed for 3-h fire resistance and f

separates the zone.from the radwaste HVAC room.

The remainder of the south wall and the entire east wall of the zone-consist i

of reinforced concrete walls which separate the zone from the outside.

The boundary of the area consists of the main ~ steam chase, the drywell, and a proposed water curtain system along l

column line R19.

l Access to the el 87-ft corner rooms is provided through two open l

stairways and to el 158 ft through an open stairway in the L

southeast corner of the zone.

The combustible loading within the zone consists of cable 2

insulation for a fire loading of 116,167 Btu /ft.

A summary of this zone is contained in table 4-15.

l l~

4.2.7.1.4 Torus Room Below el 130 ft This zone contains approximately 6700 ft* of high bay area surrounding the drywell below el 130 ft.

(See figure 4-8.)

The zone contains the safety-related pressure-suppression chamber at s

el 87 ft which is a relatively open area with adequate access 4-55 I

h through the room.

In addition, the zone contains cabling for two RHR pumps along the east wall of the room (one pump from each corner room).

The intermediate level within the zone contains a grated walkway around the drywell and is congested above the grated walkway with safety-related piping, valves, and safety-related cabling in trays.

The zone includes the area designated as drywell access (pipe penetration room) on el 130 ft which contains both safety divisions of RHR injection valves.

The south end of the zone is enclosed by reinforced concrete walls which separate the zone from the two corner rooms.

Mechanical and electrical penetrations in these walls are not all sealed.

The north boundary of the zone consists of the drywell and the proposed water curtain systems on the east and west sides of the drywell at approximately 20 degrees counterclockwise from column line R19.

The only personnel access to the zone consists of one small hatch on the south side of the drywell on el 130 ft and direct access from the north torus fire zone.

The combustible loading within the zone consists of cable insulation for a fire load of 50,631 Btu /ft.

A summary of this. zone is contained in table 4-16.

2 4.2.7.1.5 Southedst Corner Room Below el 130 ft h

This zone contains approximately 700 ft of congested floor 2

area on each of four levels below el 130 ft.

(See figure 4-8.)

The zone contains one safety division of core spray pumps and associated cabling and two safety-related RHR pumps.

Reinforced concrete walls surround the zone and separate it from the HPCI room and the torus room.

Electrical and mechanical penetrations in the northwest wall are unsealed.

The core spray and RHR pumps are located on el 87 ft with considerable quantities of mechanical piping, valves, electrical cables, and chillers located on three grated floor levels at el 99 ft, 108 ft, and 118 ft.

Access to the el 130-ft working floor is provided through a single open stairway which serves as the only personnel access to the zone.

The combustible loading within the zone consists 2

of 58,600 Btu /ft for cable insulation and 9191 Btu /ft for 2

lube oil (13.25 gal in each of the three pumps).

4.2.7.1.6 Southwest Corner Room Below el 130 ft This zone contains approximately 700 ft of floor area on each 2

of three levels below el 130 ft.

(See figure 4-8.)

This zone contains the safety-related CRD pumps, associated cabling, and chillers on the intermediate level at el 108 ft.

The south and west walls of the zone consist of 3-h rated fire barriers h

separating the zone from the radwaste building and turbine 4-56

('h k-)

building, respectively.

The northeast wall is a reinforced concrete barrier with unsealed wall penetrations between this zone and the torus room.

Access to the el 130-ft working floor is provided through an open stairwell which provides the only personnel access to the zone.

The combustible loading within the zone consists of 39,067 Btu /ft for cable insulation and 2

less than 2 gal of lube oil in each of the CRD pumps for an 2

additional 468 Btu /ft.

4.2.7.1.7 HPCI Room Below el 130 ft 2

This room contains approximately 1700 ft of high bay area on el 87 ft.

(See figure 4-8.)

The room contains the HPCI and associated cabling.

The only personnel access to this zone is through the 3-h rated fire door and airlock in the northeast corner of the room on el 118 ft.

The south and west walls of this room are rated for 3-h fire resistance and separate the area from the radwaste building. The east and north walls consist of reinforced concrete barriers separating the room from the outside and southeast corner of the reactor building, respectively.

Electrical and mechanical penetrations in the north wall are unsealed.

The combustible loading within the area consists of 155 gal of lube oil in the HPCI pump and turbine (14,800 Btu /ft ) and cable insulation (9322 Btu /ftz) 2 2

(~}

for a total fire loading of 24,122 Btu /ft.

V 4.2.7.1.8 Upper Levels Above el 185 ft 2 of Elevation 185 ft contains approximately 11,000 ft relatively open area.

(See figure 4-16.)

The zone contains nonessential equipment systems including the RWCU equipment and sample systems, the fan room for the reactor building air supply system, the decontamination room, and a semi-open working area.

The 203-ft elevation contains the standby liquid control equipment and reactor RBCCW, surge tank, heat exchangers, an open working floor, and a fan room associated with the refueling floor air-handling system.

No safe-shutdown related equipment is located on the upper elevations.

This zone communicates with the north and south zones on el 158 ft via open stairwells, an open hatchway, and unsealed floor penetrations.

4.2.7.2 Fire Protection Systems A(_)

4.2.7.2.1 Working Floor el 158 ft See paragraph 4.2.6.2.1.

4-57

4.2.7.2.2' HVAC Room el 164 ft Primary fire suppression capability for' general zone protection consists of a closed head, preaction sprinkler system with sprinklers installed at ceiling level throughout the room.

Where congestion due to cable trays, piping, and ventilation ducts obstruct the water distribution pattern from the ceiling level sprinklers, additional sprinklers have been installed below the obstructions.

Prompt detection of fires within the zone is provided by smoke detectors of the ionization type located at ceiling level throughout the zone.

These detectors also serve to automatically actuate the preaction sprinkler system.

Secondary suppression capability. consists of the standpipe system for use by the fire brigade.

Hose stations are provided for protection of the zone.

In the event of a single piping failure in.the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided for this zone; however, flooding is not of concern for equipment within this zone.

The relatively quick extinguishment of a fire involving transient combustibles by the preaction sprinkler system would assist in minimizing the quantities of smoke produced for a fire within this zone.

4.2.7.2.3 CRD accumulators and Working Floor el 130 ft See paragraph 4.2.6.2.2.

4.2.7.2.4 Torus Room Below el 130 ft See paragraph 4.2.6.2.3.

4.2.7.2.5 Southeast Corner Room Below el 130 ft See paragraph 4.2.6.2.4.

4.2.7.2.6 Southwest Corner Room Below el 130 ft Fire suppression capability is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor draininage is provided, however flooding is not of concern for equipment within the zone.

O 4-58

A(_)

4.2.7.2.7 HPCI Room Below el 130 ft Primary fire suppression capability consists of the sprinkler system installed at ceiling level to provide general area protection.

Fire detection within the area is provided by operation of the thermal elements on each individual sprinkler head.

Secondary suppression capability consists of the standpipe system for use by the fire brigade.

Hose stations are provided for protection of the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided within the room; however,-flooding is not of concern for equipment in the room.

The room configuration prevents flooding of adjacent areas since the only personnel access is at el 118 ft.

4.2.7.2.8 Upper Levels - Above el 185 f t Fire suppression capability for this zone is provided by the standpipe system for fire brigade use.

Hose stations are provided for pro,tection of the zone.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided for this zone;

(

however, flooding is not of concern for this zone due to the

\\_

large floor area and open stairwells.

The open nature of the zone and the existence of the open stairwells and equipment hatch would assist in smoke dilution, if necessary.

4.2.7.3 Safe Shutdown Analysis 4.2.7.3.1 The south half of the reactor building primarily contains components and cables of safe shutdown pathway 2.

In the event of a fire in the area (at any elevation) the loss of pathway 2 is assumed.

Pathway 1 will be utilized for the shutdown after such a fire.

The pathway 1 systems which may be affected by a fire in this area are:

e RHR.

e RCIC.

V[~'%

4-59

4.2.7.3.2 The pathway 1 circuits, raceways and components that must be protected are:

Raceway Circuit Component 2E26820 EAE808C08 2E11-F015A 2E26820 EAE808C22 2E11-F015A 2E16813 EAE333M01 2E11-FOl6A 2E16815 EAE733CO3 2E11-F016A 2E16816 EAE733CO3 2E11-F016A 2E16808 EAE337M01 2E11-F017A 3E16810 EAE773C01 2E11-F017A 2E16810 EAE737C05 2E11-F017A 2E16810 EAE737C06 2E11-F017A 2E16810 EAE734C01 2E11-F015A 2E16810 EAE734C05 2E11-F015A 2E16811 EAE737C05 2E11-F017A 2E16811 EAE737CO6 2E11-F017A 2E16812 EAE737C01 2E11-F017A 2E27086 EEE405M04 2E51-F007 2E22824 EEE805C14 2E51-F007 2E27087 EEE805C15 2E51-FOO7 2E27087 EEE805C16 2E51-F007 2E27089 EEE805C14 2E51-FOO7 2E27089 EEE805C15 2E51-F007 2E27088 EEE805C16 2E51-FOO7 2RBH803 EEE802C04 RCIC system 2RBC804 EEE802C05 RCIC system 2RBC803 EEE802C05 RCIC system 2RBB801 EEE802C05 RCIC system 2RBB801 EEE802CO3 RCIC system 4.2.7.4 Modifications A.

Reroute circuits EEE802CO3, EEE802C04, EEE802C05 to conduits wrapped with a 1-h fire rated barrier.

B.

Reroute power and control circuits of 2E51-FOO7 from MCC 2R24-S012 to MCC 2R24-S012B and wrap circuits with a 1-h fire rated barrief.

C.

Protect the following raceways with a 1-h fire barrier:

2E26820 2E16808 2E27079 2E16810 2E16813 2E16811 2E16815 2E16812 2E16816 l

D.

See paragraph 4.2.6.4 and 4.1.5.4 for a description of h

the water curtain system proposed for the area boundary.

4-60

I E.

A closed head sprinkler system is proposed for 185 ft north of-column line R19.

The area north of R19 will be sprinklered on this elevatio'n except for the decontamination room.

4.2.7.5 Exemptions to Appendix R Appendix R requires that fire areas containing pathway 1 and pathway 2 components that are separated by less than 20 ft of clear space be protected by a 1-h barrier, area wide fire suppression, and area wide fire detection.

An exemption from the requirement of area wide fire suppression is requested due to the 1-h barrier installed on all intruding pathway cables.

-An exemption to the requirement for area wide fire detection is requested for el 87 ft and 158 ft due to the localized fire detection of these elevations.

See paragraph 4.2.6.5 for the exemption request for the use of the water curtain system.to define the fire area boundary.

An exemption is requested from the separation criteria of paragraph III.G.2 of Appendix R for the steam blowout panels in i

the HVAC. room.

These panels are necessary to mitigate the consequences of a steam line break accident.

The removal of the

-(")

installation panels of fire resistive coatings would degrade (J

overall plant safety.

Further, the sprinkler system in the HVAC room would limit any fire spread into the area from a turbine building fire.

Therefore, modifying the panels would not enhance fire protection safety.

4-61

4.2.8 TURBINE BUILDING CONDENSER BAY - UNIT 2 4.2.8.1 Area Description This area contains approximately 23,000 fts of floor area below el 164 ft.

(See figures 4-14).

The zone contains the turbine steam condenser and drain coolers associated with the steam turbine located on el 164 ft.

The ceiling height in the area is 54 ft.

The southwest corner of the area contains the drain cooler equipment located on a concrete mezzanine deck.

The north and south ends of the area contain electrical cabling in trays.

The main turbine front standard panel is located at the north end of the area.

Hydrogen piping of 1-in. diameter (enclosed with a 2-in. guard pipe) passes through the area along the west wall.

Lube oil piping associated with the electrohydraulic control reservoir passes through the area ceiling level along the east wall.

Personnel access to the zone is provided through a large extranceway on the north and south walls at el 112 ft and a doorway on the south wall at the 130-ft elevation.

In addition, an open stairwell in t,he southwest corner of the area provides access to the turbine operating floor on el 164 ft.

The south and east walls of the area are constructed of reinforced concrete and separate the area from the condenser pump area and the east corridor, respectively, on el 112 ft and from the working floor and east cableway, respectively, on el 130 ft.

The west wall is reinforced concrete and separates the area from the west cableway and from the outside on el 112 ft, respectively.

Electrical penetrations in the west wall are not all sealed.

The north wall is rated for 3-h fire resistance and separates the area from the control building.

The unprotected steel at ceiling level within the area supports the turbine operating floor above.

Unsealed mechanical penetrations in the ceiling communicate with both reactor feedwater pumprooms on el 164 ft.

Clean health physics materials are stored in the northeast corner of the area.

The combustible loading in the area consists of 337,694 Btu /ft for potential turbine lube oil 2

2 spill accumulations in the area and 22,044 Btu /ft for cable insulation.

f 4.2.8.2 Fire Protection Systems Localized fire suppression capability for the oil spill protection portion of the area (west and north of the condenser) is provided by the preaction sprinkler system that is installed to provide localized protection above the drain cooler area in l

l l

4-62 i

. o

/"1

\\ s' the southwest corner of the area.

The sprinkler system is m

actuated by thermal detectors (pilot head system) installed near the ceiling in the localized portions of the area previously described and by the fusing of the thermal elements within each individual sprinkler head.

Fire suppression capability for general area protection is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of this area.

In the event of a single piping failure in the fire water system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

The floor drains-provided for this area are blocked; however, flooding is of no concern for equipment within this area.

4.2.8.3 safe Shutdown Analysis For this area, It was assumed that all of the components of pathway 1 were lost in a fire and pathway 2 components would be used for shutdown.

There are no pathway 2 components in this area that are required for safe shutdown using pathway 2.

4.2.8.4 Modifications A

None.

4.2.8.5 Exemptions to Appendix R Appendix R requires fire areas to be enclosed by 3-h fire rated walls.

An exemption from this requirement is requested for the nonrated walls enclosing this area due to the localized fire suppression capability, area wide fire suppression system in the adjacent cableways, and absence of redundant safe shutdown circuits within the area.

(

0

'v 0067n(13) 4-62a J

, -a

,,,,.-.,-r.

,w-r---.

-n.

O 4.2.9 TURBINE BUILDING EAST CABLEWAY - UNIT 2 4.2.9.1 Area Description This area contains approximately 3900 ft of floor area on el 8

130 ft.

(See figures 4-1 and 4-9.)

The cableway contains-safety-related and nonessential electrical cables in horizontal trays affixed to both sides of the corridor.

Both safety divisions of cabling are-located at the north end of.the area.

One safety division of cabling in this area is wrapped with a ceramic fiber blanket material designed to provide 1-h fire resistance.

The reactor feed pump oil conditioner unit is located at the south end of the area.

A curb 8 in. high has been provided around the perimeter of the area to confine any oil leakage in the immediate area.

The east wall of the area is constructed for 3-h fire resistance and separates the area from the Unit 2 reactor building and i

radwaste building.

The north end of the area is separated from the Unit 1 east cableway by a 3-h wall with a 3-h rated fire door on the doorway opening.

The north portion of the west wall is constructed for 3-h fire resistance and separate the area from the c.ontrol building.

All door. openings in the east wall are provided with 3-h rated fire doors.

Cable penetrations into the reactor building and control building are sealed with.

s/

material rated for 3-h fire resistance.

The south end and the south portion of the west wall of the area communicate with the working floor and train bay at floor level with no partition separating this area from the' working floor.

The area communicates with the east corridor on el 112 ft through the open stairwell at the north'end of the area.

The combustible loading within the area consists of 115,785 Btu /ft* for oil in the immediate area of the reactor feed pump oil unit and 223,526 Btu /ft for cable insulation.

A summary 2

of this area is contained in table 4-17.

4.2.9.2 Fire Protection Systems Primary fire suppression capability for general area protection consists of the automatic sprinkler system installed at ceiling level in this area.

Smoke detectors of the ionization type are installed at ceiling level throughout the north end of the area to provide. prompt notification of fire conditions in this area.

Fire suppression capability for the oil conditioner unit is provided by an open head, deluge water spray system with water spray nozzles located immediately above the unit.

Detection of fire in the reactor feed pump oil conditioner unit is provided by the thermal detector (pilot head system) located above the unit.

4-63 i

Secondary suppression capability for the zone is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains in this area are blocked; however, flooding is not of concern for the area since all cables are located a minimum of 2 ft above floor level.

4.2.9.3 Safe Shutdown Analysis 4.2.9.3.1 For this area, it was assumed that all of the pathway 2 components were lost in a fire and pathway 1 components would be used for shutdown.

The pathway 1 systems which may be affected by a fire in this area are:

e RCIC.

e Plant service water, Diesel generator 2A/1B/2C.

e 4.2.9.3.2 The pathway 1 raceways, circuits, and components that must be protected are:

Raceway' Circuit Component 2CDA801

'EEE823C02 2E51-F105 2E22824 EEE805C14 2E51-F007 2CFA802 RCX806C01 Diesel Gen. 2A/1B/2C 2CFA802 RCX806C04 Diesel Gen. 2A/1B/2C 2GFA801 RCX806C01 Diesel Gen. 2A/1B/2C 2GFA801 RCX806C04 Diesel Gen. 2A/1B/2C 2CFA801 RCX806C01 Diesel Gen. 2A/1B/2C 2CFA801 RCX806C04 Diesel Gen. 2A/1B/2C 2E12076 RXE303M01 2R24-S018A 2E12082 RXE701C01 2R24-S018A 2E12084 RXE703C01 2R24-S018A 2E12085 RXE701C01 2R24-S018A 2MR2543 TGX711C01 2T48-F026 2MR2594 TGX311M01 2T48-F026 0

4-64

b)

\\~/

4.2.9.4 Modifications The following raceways will'be protected with a 1-h fire' barrier:

2'KA701 C

2CLA701

~

2CMA701 2E12076 2E12082 2E12084 2E12085 2E22824 2MR2543 2MR2544 2CDA801 4.2.9.5 Exemptions to Append.ix R An exemption from the barrier requirements of paragraph III.G.2 of Appendix R is requested for the opening to the turbine building and the nonrated wall between the cableway and the turbine building condenser bay.

The presence of the sprinkler system in the cableway will assure that any fire in the. turbine building can not damage the cables.

The intrusion of smoke from C')

such a fire is of no consequence as the only safe shutdown components in the area are cables.

Thus, the installation of a fire rated barrier would.not enhance fire protection safety.

4-65 l

4.2.10 DIESEL BUILDING SWITCHGEAR ROOM 2G - UNIT 2 4.2.10.1 Area Description This area contains approximately 1070 ft on el 130 ft.

(See 2

figure 4-10.)

The room contains safety-related switchgear associated with emergency diesel generators unit 2C.

The enclosing walls are constructed for 3-h fire resistance with all penetrations sealed with a material designed to provide a 3-h fire barrier.

Doors providing access to this area from the diesel generator room and the battery room are rated for 3-h fire resistance.

In addition, personnel access is available through doors in the east wall which separate the area from the outside.

The combustible loading within the room consists of 53,460 Btu /ft for cable insulation.

A summary of this area 2

is contained in table 4-18.

4.2.10.2 Fire Protection Systems Smoke detectors of the ionization type are installed at ceiling level to provide prompt notification of fire conditions throughout the area.

Fire suppression capability consists of hose reel located in the southwest corner of the zone the CO2 for use by the fire brigade.

In addition, fire hydrants which can be used, if necessary, to provide supplemental hose streams W

are located outside the building.

A thermal detector is provided at ceiling level within the Actuation of the d.etector initiates ventilation fans in room.

the room.

4.2.10.3 Safe Shutdown Analysis 4.2.10.3.1 For this area, it was assumed that all of the pathway 2 components were lost in a fire and pathway 1 components would be used for shutdown.

The pathway 1 system that may be affected by a fire in this area is the diesel 1B.

O 4-66

[

4

%/

4.2.10.3.2 'The following-raceways, circuits, and components of pathway 1 must be protected:

Raceway Circuits Component 2ESB170

.PUEB41M01, RHEBO8MO2

' Diesel IB

'2ESB168 PUED41CO2, PUED41C04, PUED41H02 Diesel 1B 2ESB168 PUED57C01, PUED57M01, RIE036C01 Diesel 1B 2ESB168 RIE036CO3, RIE036M04, RTED09C01 Diesel 1B 2ESB168 RTED10C01 Diesel 1B 2ESB167 RHED08C04, RHED08C05, RHED08C06 Diesel 1B 2ESB167 RHED01C07, RTED01C08, RTED01C11 Diesel 1B 2ESB167 RTED01C12, RTED04C01, RTEDO4CO2 Diesel.1B-2ESB167 RTED04CO3, RTEDO5C01, RTED08C01 Diesel 1B 2ESB167 RTED13C05, RTED22C01 Diesel'1B 4.2.10.4 Modifications Protect the following pathway 1 raceways with a 1-h fire barrier:

2ESB170 2ESB168 2ESB167 r

Ev 4.2.10.5 Exemptions to Appendix R The proposed modification meets Appendix R, paragraph III.G.2.C, with'the exception of an automatic fire suppression system.

An exemption to the requirement for an automatic suppresssion system is requested due to the low combustible loading in-the The proposed 1-h fire barrier will ensure the area.

availability of the pathway 1 components.

. O 4-67

4.2.11 4160-V TRANSFORMER ROOM - UNIT 2 4.2.11.1 Area Description This area contains approximately 250 ft of open area on el 2

130 ft.

(See figure 4-9).

The room contains one 4160/600-V switchgear transformer which is enclosed cn the north, east, and west sides by walls rated for a minimum 2-h fire resistance, separating the araa from the switchgear rooms.

The north wall contains a doorway opening protected by a 3-h rated sliding fire door to separate the area from the control building corridor.

The south wall is a 3-h rated wall separating the area from the condenser bay.

Ventilation duct penetrations in the east and aest walls are provided with 3-h rated fire dampers which are designed to close automatically upon sensing excessive temperatures within the ducts.

Combustible loading in the area consists of cabling in conduit and noncombustible transformer oil for a negligible fire loading.

4.2.11.2 Fire Protection Systems A fire detector of the ionization type is installed to provide prompt notification of fire within the area.

Primary fire suppression for this area is provided by two CO hose reels for 2

fire brigade use.

In addition, hose stations are provided in the corridor near the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Flooding is of no concern for this area since the transformer is pad mounted above floor level.

4.2.11.3 Safe Shutdown Analysis For this area it was assumed that all safe shutdown components in pathway 2 were lost in a fire and pathway 1 components would' be used for cold shutdown.

There are no pathway 1 components located in this area that require protection.

4.2.11.4 Modifications None.

4.2.11.5 Exemptions to Appendix R Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown pathways.

The north, east, and west walls of this fire area have a minimum 2-h rated fire wall.

An exemption is requested for these walls based upon the very low combustible loading inside the area.

4-68 L

rq k/

4.2.12 WEST de SWITCHGEAR ROOM - UNIT 2 4.2.12.1 AREA DESCRIPTION 2 of floor area on el This area contains approximately 300,ft 130 ft.

(See figure 4-9).

The area contains one division of 125/250 V-dc switchgear which is enclosed on the north, east, and south sides by walls rated for a minimum 2-h fire resistance, separating the zone from the control building corridor and the 600-V switchgear.. The west wall is a 3-h rated wall separating the zone from the oil conditioner room.

The doorway opening on the east wall is provided with a 3-h rated sliding fire door.

Ventilation duct penetrations in ti.e east and west walls are provided with 3-h rated fire dampers designed to close automatically upon sensing excessive temperature within the ducts.

The redundant civision of de switchgear is provided in a separate enclosure on the same elevation.

The combustible 8

loading within the area consists of 47,520 Btu /ft of cable insulation.

4.2.12.2 Fire Protection Systems A fire detector of the ionization type is installed at ceiling f'

level to provide prompt notification of a fire ceiling level to provide prompt notification of a fire within the area.

Primary suppression capability for a fire in this area is provided by hose reels for fire brigade use.

In addition, hose-two CO2 stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

No floor drains are provided for this area; however, flooding is of no concern for the area.

4.2.12.3' Safe Shutdown Analysis For this area it was assumed that all safe shutdown components in pathway 1 were lost in a fire and pathway 2 components would be used for cold' shutdown.

There are no pathway 2 components located in this area that require protection.

4.2.12.4 Modifications None.

r~N 4-69

4.2.12.5 Exemptions to Appendix R -

Appendix R, paragraph III.G.2.A, require's a 3-h barrier between redundant shutdown pathways.

The north, east, and south walls of this fire area have a minimum 2-h rated fire wall.

An exemption is requested for these walls based upon the very low combustible loading inside the area.

O O

4-70

/ '

4.2.'13~

EAST de SWITCHGEAR ROOM - UNIT 2 4.2.13.1-Area Description This area contains approximately 300 ft of floor area on el 2

130-ft.

(See figure 4-9.)

The area.contains one division of 125/250 V-dc switchgear which is enclosed by 3-h rated fire barrier on the east side, sephrating the area from the east cableway.

The-north, south, and west walls are rated for a minimum 2-h fire resistance and separate the area from the 600-V switchgear health physics offices and from the control building corridor.

The doorway opening on the west wall is provided with a 3-h rated sliding fire door.

Ventilation duct penetrations a

through the east, west, and south walls are provided with 3-h rated fire dampers designed to close automatically upon sensing high temperature within the duct.

The redundant safety division of de switchgear'is provided in a separate enclosure on the same elevation.

The combustible loading within the area consists of-41,876 Btufft of cable insulation.

4.2.13.2 Fire Protection Systems A fire detector of the ionization type is installed at ceiling

/

level to provide prompt notification of a fire within the area.

\\.

Primary fire suppression capability for this area is provided by two CO -hose' reels for fire brigade-use.

In addition, hose 2

stations are provided for protection of the area.

In the event of 'a single piping failure in this fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

No floor drains are provided for this area; however, flooding'is of no concern for the area.

I

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4.2.13.3 Safe Shutdown Analysis For this area it was assumed that all safe shutdown components in pathway 2 were lost in a fire and pathway 1 components would be used for cold shutdown.

There are no pathway 1 components located in this area that require protection.

4.2.13.4 Modifications None.

4.2.13.5 Exemptions to Appendix R Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown pathways.

The north, west, and south walls of this fire area have a minimum 2-h rated fire wall.

An l

4-71

exemption is requested for these walls based upon the very low combustible loading inside the area.

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4-72

~. _ _

4.2.14 WEST 600-V SWITCHGEAR ROOM - UNIT 2

]

4.2.14.1 Area Description

.This area contains approximately 500 ft ' of floor. area on 'el 2

130 ft.

(See figure-4-9.): This room contains one division of 600-V switchgear which is enclosed on the west ~and south ~ sides 4

by 3-h rated fire barriers, separating this area.from the oil i -

conditioner room'and the Unit 2 condenser. bay, respectively.

DThe north and east walls are rated for a minimum 2-h fire resistance,and separate the room from the west de switchgear and transformer room.

The doorway opening.in; the north wall is provided with a 3-h rated sliding fire door to separate this area from the control building corridor.. Ventilation ducts.

penetrate the east and west walls.

Each duct penetration is provided with a 3-h rated fire damper designed to close 4

automatically upon sensing high temperatures within.the duct.

l The combustible loading within the room consists of 25,533

{

Btu /ft2 for cable insulation.

f I

4.2.14.2 Fire Protection Systems I

Fire detectors of the ionization type are installed at ceiling Llevel to provide prompt notification of fire conditions within i

the room. ' Primary fire suppression capability is provided by.

hose reels for fire brigade use.

In addition, hose two CO2 stations are provided.for protection of the area.

In the event of a single piping failure in the fire water supply system,

~

j supplemental hose lines can'be supplied from remote hose stations located throughout the plant.

Floor drains are not 4

provided.for this area; however, flooding is no concern for the r'

area.

i 4.2.14.3 Safe Shutdown Analysis For this area it was assumed that all safe shutdown components l

in pathway 1 were lost in a fire and pathway 2 components would l

be used for cold shutdown.

There are.no pathway 2 components located in this area that require protection.

4.2.14.4 Modifications f

None.

4.2.14.5 Exemptions to Appendix R

1..

Appendix R, paragraph III.G.2.A, requires a 3-h barrier between l

redundant shutdown pathways.

The north and east walls of this 4-73 i

.. ~...

. - _..~.__.__._,:.,_..__.__.-_,._._,_.._-__-.....,,

fire area have a minimum 2-h rated fire wall.

An exemption is requested for these walls based upon the very low combustible loading inside the area.

l t

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l i

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O 4-74

4.2.15 EAST 600-V-SWITCHGEAR ROOM --UNITL2 4.2.15.1-Area Description This~ area contains approximately.500;ft* of floor area on el 130 ft.

(See figure 4-9.)

The room contains one division of 600-V switchgear which=is enclosed on the east and south sides-by 3-h rated fire barriers, separating this area from the east cableway and Unit-2 condenser bay, respectively.

The north and-west walls are rated for a minimum 2-h fire resistance and separate the room from the. east de switchgear room and transformer room.

The doorway opening in the north wall is' i

provided with a 3-h rated-sliding fire door to separate the zone from the control building corridor.

Ventilation ducts penetrate the north, east, and west walls.

Each duct penetration is-i provided with a 3-h rated fire damper designed'to close automatically upon sensing high temperatures within the duct.

I The combustible loading within the room consists of 21,384 Btu /ft* for cable insulation.

i i

~4.2.15.2 Fire Protection Systems l

Fi-re detectors-of the ionization type -are installed at _ ceiling

[

level to provide prompt notification of fire conditions within i

the room.

Primary fire suppression capability is provided by

~

' hose reels for fire brigade use.

In addition, hose two CO2 stations are provided'for protection of-the area.

In the event i

of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose

~

stations located throughout the plant.

Floor drains are not provided for this area; however, flooding is of no concern for I

the area.

1 4.2.15.3 Safe Shutdown Analysis For this area it was assumed that all safe shutdown components in pathway 2 were lost in a fire and pathway 1 components would be used for cold shutdown.

There are no pathway 1 components located in this area that require protection.

4.2.15.4 Modifications i-None.

4.2.15.5 Exemptions to Appendix R O--

Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown pathways.

The north and west walls of this l

4-75

l l

l fire area have a minimum 2-h rated fire wall.

An exemption is requested for these walls based upon the very low combustible loading inside the area.

O OO68n 4-76

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4.3 SAFE SHUTDOWN ANALYSES OF AREAS COMMON TO-UNITS 1 AND 2 1

4 '. 3.1 CONTROL BUILDING LPCI INVERTER ROOM, COMMON

?

4.3.1.1 Area Description 2

j This area contains.approximately 1000 ft of open floor area on el 147 ft.

(See figure 4-11.)

This area contains both.

j safety divisions of the'dc/ac inverters for the low pressure coolant injection (LPCI) system motor control centers'(MCCs) for both units.

The walls enclosing this area are constructed for-3-h fire resistance.

This area-is separated from the cable spreading room on the north wall by a 3-h rated fire door.

Access to the operating floor of.the Unit 2 turbine building is provided through an open stairwell enclosed at the 164-ft elevation with a nonrated metal-framed structure.

Ventilation duct penetrations through the walls enclosing this area-are provided with 3-h rated fire dampers designed-to close automatically upon sensing high temperature within the duct.

Three lube oil vapor vent-lines-pass through this room near ceiling level directly above the inverters.

All cabling within the room is enclosed in conduit..

The combustible loading.within E

this area is negligible.

A summary of this area is contained in table 4-19.

4.3.1.2 Fire Protection Systems l

Fire suppression capability for this area is provided by the

~

standpi'pe system for fire brigade use.

Hose stations are i-provided for protection'of the area.

-In the event of a single:

piping failure in the fire water supply system, supplemental' 1

l-hose lines can be supplied from remote hose stations located throughout the plant.

Floor ~ drains are provided for this area; i

-however, flooding is of no concern for-this area since the inverters are mounted on concrete pads. above floor level and since excess water'could flow under the door into the cable spreading ~ room.

Two means of access are provided for the area.

E to' facilitate fire brigade operations.

4.3.1.3 Safe Shutdown Analysis f

A fire within this area could damage the dc/ac inverters for the l.

l LPCI system for both units.

However, an alternate power source is available to the LPCI MCCs from the emergency power system.

A fire within this area would not be expected to spread beyond the room due to the relatively low fire loading and the fire resistance of the barrier walls.

4-77

4.3.1.4 Modifications To promply alert the operators of a fire in this area, so that

~

the transfer can be accomplished from the control room, fire detectors will be added to this area.

4.3.1.5 Exemptions to Appendix R None.

1 f

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i l

9 4-78 l

4.3.2 CONTROL BUILDING CORRIDOR, COMMON ll 4.3.2.1 Area Description This area contains approximately 3800 ft* of floor area on el

~130 ft with a' ceiling height of approximately-16 ft.

'(See

' figure 4-1.)

The corridor contains both' safety divisions of cabling for Unit 1 and Unit 2 which are located adjacent to one

-another throughout most of the length of the corridor.

Th'e north and south sides 6f the area are separated from the oil conditioner rooms by 3-h fire-resistive walls.

The area is separated from the health physics laboratory and the Unit 1 and Unit 2 annunciator rooms in the center of the corridor by 3-h fire resistive walls.

All doorway openings leading directly off this area are provided with-rated fire doors.

All ventilation penetrations in the north, e a s t,' and south walls of the corridor area are provided with 3-h rated fire dampers designed to close automatically upon sensing'high temperatures within the ducts.

.The east portion of the south. wall of the area is open and communicates with the Unit 2 control building switchgear hallway.

A-large opening'in the east wall connects the area to a fan room in the service building which is open to.the outside via large air intake. grills.

The north side of the west end of the corridor is separated from a freight elevator and' enclosed.

stairwell by 2-h fire resistive walls with 1 1/2-h rated fire i

doors on the openings.

The stairwell and elevator provide access to all other elevations of the control building.

The combustible loading of the corridor consists of 333,799 Btu /ft for cable insulation.

In addition, a 1-in. hydrogen 2

~

gas line (concentrically enclosed by a 2-in. protective pipe) passes along the west wall of'the corridor from the Unit 1 oil conditioner room on the north wall to the Unit 2-oil conditioner room on the south wall.

A compressed gas cylinder containing a mixture of 10-percent methane and 90-percent argon is located in the center of the area in a concrete block enclosure.

A summary of this area is contained in table 4-20.

-4.3.2.2 Fire Protection Systems Smoke detectors of the ionization type are installed near ceiling level to provide prompt notification of fire conditions throughout-the area.

Primary fire suppression capability in the north and south ends corridor is provided by a preaction sprinkler system installed at ceiling level.

Additional sprinklers are installed beneath the lowest cable trays in the north corridor and are designed to protect against exposure fires.

Actuation of the preaction sprinkler system is effected by operation of the smoke detectors and by operation of the thermal-element within each sprinkler nozzle.

}

4 i-4-79 i

t

Secondary suppression capability is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

In addition, two carbon dioxide (CO2) hose reels are provided for protection of this area.

Floor drains are normally covered; however, flooding is of no concern for this area.

The corridor is accessible from either end to facilitate fire brigade operations.

4.3.2.3 Safe Shutdown Analysis 4.3.2.3.1 Safe Shutdown Analysis, Unit 1 Components 4.3.2.3.1.1 For this area, it was assumed that all of the safe shutdown components in pathway 1 were lost in a fire and pathway 2 components would be used for cold shutdown.

The pathway 2 systems which may be affected by a fire in this area are as follows:

Suppression chamber level.

e e

Residual heat removal (RHR) room coolers.

Plant service water.

e Diesel generator (DG) 1C and its power feeds.

High pressure coolant injection (HPCI).

e Suppression chamber temperature.

e e

Reactor recirculation.

Automatic depressurization system (ADS).

e e

Core spray system.

Instrument air to the drywell.

e e

125 V-dc cabinet R25-S002 0

4-80

4.3.2.3.1.2 The raceways and circuits and affected components must be protected or repaired to attain hot or cold shutdown as indicated in the following list:

Raceway Circuit Component i

TM08-01 R23-S004-ES8-C14 T48-N010B TEJ8-02' (Torus water TEA 8-03 level)

TEA 8-04 TM08-01 R23-S004-ES8-C14 T41-B003B TEJ8-02 (RHR and core TEA 8-03 spray room-TEA 8-04 coolers)

TMO8-01 R23-S004-ES8-C14 P41-F036 TEJ8-02 (Service water to TEA 8-03 TEA 8-04 T41-B003B)

TM08-01 R23-S004-ES8-C14 R24-S012 TEJ8-02 (Power feed to T41-B003B and TEA 8-03 TEA 8-04 E41-F111 (pas-sive))

(}

TM08-01 H21-P202-ESC-RM03C R43-POO1C TEJ8-02 (DG IC control TEJ8-02 H11-P652-ESC-C35 panel)

.TMO8-01 H21-P23-ESC-C07 H11-P627 (Channel B TEJ8-01 core spray control room panel)

TM08-01 H11-P652-ESC-C35 R43-S001C TEJ8-01 H11-P652-ESC-C37 (DG 1C H11-P652-ESC-C39 skid)

H11-P652-ESC-C47 H11-P652-ESC-C28A TM08-01 H11-P652-ES8-C52 R23-S004 (600-V DG switchgear 1D)

TM08-01 H21-P232-ESC-C28 R23-S007 TEJ8-01 (600-V DG switchgear IC)

TM08-01 H11-P652-ESC-C47 H21-P232 TEJ8-01 (Local relay s

panel for DG 1C) 4-81

h Raceway Circuit Component TEJ8-01 H21-P202-ESC-PO1A H11-P625 TEH8-03 H21-P202-ESC-P02A (Control room electrical auxiliary panel)

TEJ8-02 H23-S004-ES8-CO6 R41-LOO 3B TEA 8-03 (Cooling water TEA 8-04 to RHR service water pump motors)

TML8-01 R25-S002-ES8-M10 HPCI turbine ESS-II-242 stop and TEB8-02 control valves TML8-01 R25-5065-ES8-M21 E11-F065B TEB8-04 E11-F065D (RHR pump suction valves)

TEH8-02 R23-S004-ES8-CO8 R24-SO18B TEB8-01 (600-V TEA 9-04 essential MCC 1E) h TEH8-01 R22-S007-ES8-C01 E11-C002B R22-S007-ES8-COS (RHR pump B)

R22-S007-ES8-COSA H11-P618-ES8-C073 H11-P618-ES8-C074 H11-P618-ES8-C075 H11-P618-ES8-C083 TML8-01 R25-SO65-ES8-M15 T48-N009D l

TEB8-04 T47-P612 (Suppression chamber switch and recorder)

TML8-01 R25-S065-ES8-M15 T48-N009B TEB8-04 T47-R612 TEB8-03 (Suppression chamber switch and recorder) 4.3.2.3.2 Safe Shutdown Analysis, Unit 2 Components 4.3.2.3.2.1 For this area, it was assumed that all of the safe lh shutdown components in pathway 1 were lost in a fire and 4-82

pathway 2 components would be used for shutdown.

The pathway 2 k

systems which may be lost in a fire in this area are:

e RHR system.

e Plant service water.

Diesel generator 2C and power feeds.

e Core spray system.

e Drywell air.

o HPCI.

4.3.2.3.2.2 The following raceways, circuits, and affected components of pathway 2 must be protected.

~ Raceway Circuit Comconent 2CVA801 AAE807M06 2T48-F104 2CVA801 AAX816M01 2C71-P001B 2CVA801 AAX831M01 2E11-F023 2CVA801 BBE806M01 2E41-F003 2CVA801 CMX802M01 2C71-P001B-w_

2CVA801 EAX813M01 2E21-F019B 2CVA801 EFE807M04 2E11-F210B/D 2CVA801 GEX809M01 2R25-S063 2CVA801 GEX809M02 2R25-S063 2CVA801 PEE 801M01 2P41-F037B/C 2CZA801 EAE812C07 2E11-COO 2B 2CZA801 EAE884C07 2E11-C001B 2CZA801-EAE886C07 2E11-C001D 2CZA801 EAE888C06 2E11-C002B 2CZA801 PEE 802C09 2P41-F037C 2CZA801 PUE805C06 2P41-F316B l

2CZA801 PUE814C04 2P41-F303B 2CZA801 PUE834C04 2P41-F316B 2CZA801 PUE836C16 2P41-C001B 2CZA801 PUE856C01 2P41-F339B 2CZA801 PUX817C05 2P41-F310 2CZA801 RIE803C04 2R23-S004 l

2CZA801 RIE803E02 2R23-S004 2CZA801 RUE 803CO6 Diesel Generator 2C 2CZA801 RUE 804C05 Diesel Generator 2C 2CZA801 RUE 805C05 Diesel Generator 2C 2CZA801 RUE 807C04 Diesel Generator 2C 2CZA801 RUE 813CO2 Diesel Generator 2C 2CZA801 RUE 829CO3 Diesel Generator 2C 2CZB801 RUE 801C09 Diesel Generator 2C 2CZB801 RUE 811CO3 Diesel Generator 2C 2CZB801 RUE 819CO3 Diesel Generator 2C 4-83

Raceway Circuit Component 2CZB801 RUE 821F06 Diesel Generator 2C 2CZB801 RUE 821PO2 Diesel Generator 2C 2CZB801 RUE 821PO4 Diesel Generator 2C 2CZB801 RUE 821CO3 Diesel Generator 2C 2CZB801 EFE807MO4 2E11-F210B/D 2CZB801 PEE 802C07 2P41-F037B 2CZB801 RHE802C04 2R22-SOO7 2CZB801 EBE821C10 2E21-COO 1B 2CZB801 EBE821COS 2E21-COO 1B 2CZB801 EBE802C18 2E21-COO 1B 2CZB801 EBE802C2O 2E21-COO 1B 4.3.2.4 Modifications The following raceways are required for hot shutdown and will be protected with a 1-h fire barrier.

The existing sprinkler system will also be extended over the affected areas; however, certain equipment will be shielded from the direct impingement of water.

This will prevent the water from adversely affecting this equipment.

Unit 1 Unit 2 TMO8-01 2CVA801 TEJ8-02 2CZA801 TEA 8-03 2CZB801 TEA 8-04 TEJ8-01 TEH8-03 ESS-II-242 TML8-01 TEB8-02 TEB8-02 TEH8-01 TEB8-03 TEB8-04 TEH8-02 TEB8-01 The sprinkler systems presently installed in the north and south corridors will be extended to provide full sprinkler coverage in the west corridor area.

The north corridor sprinkler system will be extended to cover the eastern end of the north corridor adjacent to the health physics area.

4.3.2.5 Exemptions to Appendix R An exemption is requested from the barrier requirements of paragraph III.G.2 of Appendix R for the fan room opening.

The opening is necessary for the heating, ventilation, and air-4-84

s

~

conditioning-(HVAC)~ system function.

A fire outside the area

~.

would be controlled by the presence of the full sprinkler system in the corridor.

A similar exemption is requested for the open fire area boundary between the common corridor and_the Unit 2 switchgear hallway.

The sprinkler system will act as a water curtain in a manner similar to the water curtain systems proposed for the reactor building.

A. fire barrier is proposed for de panel R25-S002.

The proposed barrier will consist of a rated fire door.and support walls constructed of 1-h fire rated construction.

The barrier will be open on the top but will extend from floor' level to the top of the cabinet.

It is noted that the proposed and existing sprinkler systems do not provide full coverage for the fire area; that is, the restrooms and decontamination rooms in the health physics area and the HVAC room will not be sprinkled.

No safe shutdown or safety-related equipment is in any of these rooms.

An exemption from the full coverage interpretation of Appendix R is requested for these rooms as the extension of the sprinklers into the rooms would not affect fire protection safety.

Two safety-related de panels (R25-S001 and R25-S002) are located in the north hallway approximately 13 ft apart.

(')

R25-5001 is a pathway 1 panel; R25-S002 contains pathway 2

\\_/

circuits required for safe shutdown for a fire in this area.

The corridor is sprinklered in the area of the panels and will be fully sprinklered when the proposed sprinkler system extensions are completed.

Ionization smoke detection and the high traffic through the area assure that any fire will be rapidly detected and extinguished prior to damaging both panels.

The essential panel (R25-S002) will be protected by_a barrier.

The top of this barrier will not be closed; therefore, the barrier will not be fire rated.

The construction'of the barrier and the fire ~ door will be of at least 1-h fire rated construction except for the open top.

As the open top is needed for ventilation, the closure-of the top would degrade overall plant safety.

An exemption from the 1-h fire rated barrier requirement of paragraph III.G.2.c of Appendix R is requested for the proposed panel enclosure.

O 4-85

4.3.3 RPS AND VERTICAL CABLE CHASE ROOMS - COMMON h

4.3.3.1 Area Description This area contains approximately 700 ft of area on el 130 ft.

(See figure 4-1.)

The room contains cabling of both shutdown pathways for both Unit 1 and Unit 2.

The proposed fire door addition will isolate the large concentration of cables in the vertical cableway at the east end of the area from the other components.

(See modifications.)

This will also isolate the redundant pathways except as noted in paragraph 4.3.3.4.1.

This area is enclosed by 3-h fire resistive barriers on all four sides.

Two doorway entrances on the west wall of the area provide access to the control building corridor and are provided with 3-h rated fire doors.

Ventilation duct penetrations between the reactor protection systems (RPSs)-rooms and the control building corridor are provided with 3-h rated fire dampers which are designed to close automatically upon sensing high temperature.

The north and south walls separate this area from the Unit 1 and 2 annunciator rooms, respectively.

The east wall separates the area from the health physics laboratory.

Vertical cable trays penetrate the floor and ceiling at the east end of the area.

All penetrations are or will be sealed with a 3-h rated material.

The combustible loading within the area consists of 900,397 Btu /ft for cable insulation in each h

2 unit.

A summary of this area is contained in table 4-21.

4.3.3.2 Fire Protection Systems Smoke detectors of the ionization type are installed to provide prompt notification of fire throughout the area.

Primary fire suppression capability in the vertical cable chase at the east end of the area is provided by a preaction sprinkler system.

Actuation of this sprinkler system is effected by operation of the smoke detectors and by actuation of the thermal element within each water spray nozzle.

Secondary suppression capability is provided for the cable chase and for other portions of the area by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located'throughout the plant.

No floor drains are provided for these rooms; however, flooding is of no concern in this area.

O 4-86

4.3.3.3 Safe Shutdown Analysis

'4.3.3.3.1 Safe Shutdown Analysis, Unit 1 Components 4.3.3.3.1.1 For this fire area, it was assumed that the area is separated into two' areas for analysis.

The first area is the RPS room in which it was assumed that all pathway 2 components would be lost in a fire and the pathway 1 components would be used for shutdown.

The second area is the vertical cable chase in which it was ' assumed that all pathway 1 components would be lost in a fire and the pathway 2 components would be used for shutdown.

The pathway 1 or pathway 2 systems which may be affected by a fire in these areas are as follows:

Pathway 1 Pathway 2 Drywell air HPCI MCC R24-S018A Drywell air Reactor pressure vessel (RPV) level 4.3.3.3.1.2 The following Unit i raceways, circuits, and

'()

affected components must be protected or repaired to attain hot

~

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or cold shutdown:

Raceway Circuit Component ESS-I-499 R22-S016-ES7-C23 R24-S018A ESS-I-499 R25-S064-ES7-M33 R24-S018A ESS-I-499 R25-S064-ES7-M44 R24-S018A TEN 7-01 R25-S064-ES7-M25 B21-N027 TEN 7-02 R25-S064-ES7-M25 B21-R605 l

TEN 7-01 R25-S064-M08 B21-NO26B TEN 7-02 R25-5064-M08 B21-R604B TEN 7-01 R25-S064-ES7-M22 E41-N602A TEN 7-02 R25-5064-ES7-M22 E41-N610A l

4-87

o 4.3.3.3.2 Safe Shutdown Analysis - Unit 2 Components 4.3.3.3.2.1 For this area, it was assumed that all of the safe shutdown components in pathway 1 were lost in a fire and pathway 2 components would be used for shutdown.

The pathway 2 systems which may be affected by a fire in this area are:

e Drywell air.

e RHR.

e HPCI.

e Plant service water.

4.3.3.3.2.2 The following Unit 2 raceways, circuits, and affected components of pathway 2 must be protected:

Raceway Circuit Component 2CUA701 AAE706M09 2T48-F104 2CUA701 AAX713M01 2E11-F023 2CUA701 BBE706M01 2R25-SO64 2CUA701 DAX704M01 2R25-S015 2CUA701 TBE701M01 2R25-S064 2CVA801, 2CVA802 AAE807M06 2R25-S065 2CVA801, 2CVA802 AAX831M01 2R25-S065 2CVA801, 2CVA802 BBE806M01 2R25-S065 2CVA801, 2CVA802 EFE807M04 2R25-S065 2CVA801, 2CVA802 GEX809M02 2R25-S063 2CVA801, 2CVA802 PEE 802M01 2R25-S065 2CVA801, 2CVA802 PME802M01 2R25-S065 2CVA801, 2CVA802 RKE802M04 2R25-S065 2E22072 RXE804M02 2R25-S065 4.3.3.4 Modifications 4.3.3.4.1 Unit 1 Raceway ESS-I-499 is required for safe shutdown and will be protected with a 3-h barrier in the RPS room.

A 3-h fire rated door will be added to separate the, vertical cable chase from the north RPS room.

This will separate the pathway 1 affected circuits from the pathway 2 affected circuits except for ESS-I-499.

As indicated in paragraph 4.1.3, the power circuits for the above listed instrumentation will be routed from an isolated instrument bus or routed separately from the pathway 1 circuits in the vertical cable chase.

4-88

I 4.3.3.4.2 Unit 2 Add a 3-h fire rated door to separate the vertical cable chase from the south RPS room.

4.3.3.5 Exemptions to Appendix R None.

1 I

O 4-89

4.3.4 EAST CABLEWAY - COMMON 4.3.4.1 Area Description This area contains approximately 3500 ft of floor area on el 2

130 ft.

(See figure 4-1.)

The cableway contains safe shutdown electrical cables in horizontal trays affixed to both sides of the corridor for Unit 1 and Unit 2.

These safe shutdown cables are located in the south end of the area.

One safety division of the Unit 1 cabling in this area has been wrapped with a ceramic fiber blanket material designed to provide 1-h fire resistance.

The east wall of the area is constructed for 3-h fire resistance and separates the cableway from the Unit 1 reactor and radwaste building.

The south end of the area is separated from the Unit 2 east cableway by a 3-h fire wall with a 3-h rated fire doorway on the doorway openings.

The south portion of the west wall is constructed for 3-h resistance and separates the area from the control building.

The north portion of the west wall is reinforced concrete and separates the area from the condenser bay.

All door openings, except the entrance to the turbine building in the east and west walls, are provided with 3-h rated fire doors.

lh Cable penetrations into the reactor, radwaste, and control buildings are sealed with material rated for 3-h fire resistance.

The north end of the area communice.tes directly with the turbine building working floor around the railroad bay at floor level with no partition separating this area from the working floor.

At ceiling level the area is separated from the turbine building northeast switchgear mezzanine by a reinforced concrete wall with unsealed cable penetrations.

The combustible 2

loading within the area consists of 223,526 Btu /ft for cable insulation.

A summary of this area is contained in table 4-22.

4.3.4.2 Fire Protection Systems Primary fire suppression capability for this area consists of the autcmatic sprinkler system installed at ceiling level A noncombustible barrier shield is throughout the area.

installed to separate the two safety divisions of cabling where they are located in close proximity at the south end of the area.

A*, this point, additional sprinklers are installed on both sides of the barrier to ensure that a single fire will not damage both safety divisions of cabling.

Smoke detectors of the ionization type are installed at ceiling level throughout the area to provide prompt notification of fire conditions.

Secondary suppression capability for this area is provided by l

l the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single 4-90

O piping failure in the. fire water supply system, supplemental hose : lines can be supplied from remote hose stations located throughout the' plant.

Floor drains in this area are. blocked; however,' flooding is of no concern for this area since all cables are located a minimum of.18 in. above floor level.

4.3.4.3

' Safe Shutdown Analysis 14.3.4.3.1 Safe Shutdown Analysis, Unit 1 Components 4.3.4.3.1.1 For this area, it was assumed that all of the safe shutdown components in pathway 2 were lost in a fire and pathway 1 components would be used for cold shutdown.

The pathway'1 systems which may be affected by a fire in this area are as follows:

o Plant service water.

e RHR.

e-Reactor core isolation cooling (RCIC).

o ADS.

o Instrument air to drywell.

4.3.4.3.1.2 The analysis-has shown that only the following.

raceways, circuits, and the affected components must be protected or repaired to. attain' hot or cold shutdown:

Raceway Circuit Component TCWO-1.

H11-P614-ESO-C116 E51-N602B (Temperature switch that detects-steam leaks) 4.3.4.3.2 Safe Shutdown Analysis, Unit 2 Components 4.3.4.3.2.1 For this area, it was assumed that all of the safe shutdown components of pathway 1 were lost in a fire and pathway 2 components would be used for shutdown.

The pathway 2 system that may be affected by a fire in this area is the drywell air system.

4-91

4.3.4.3.2.2 The following raceways, circuits, and components h

must be protected:

Raceway Circuit Component 2MR2543 TGX711CO2 2T48-F026 2MR2544 TGX311M01 2T48-F026 4.3.4.4 Modifications 4.3.4.4.1 Unit I raceway TCWO-01 is required for hot shutdown and will be protected with a 1-h fire rated barrier.

4.3.4.4.2 Pathway 2 component (Unit 2) 2T48-F026 must stay open for pathway 2 operation.

This valve shall be locked in the open position.

4.3.4.5 Exemptions to Appendix R Appendix R, paragraph III.G.2.A, requires a 3-h barrier between redundant shutdown pathways.

The wall separating the east cableway on el 130 ft and the condenser bay is not 3-h rated due to the unsealed penetration.

There are no safe shutdown circuits located in the condenser bay, and the east cableway contains a complete area sprinkler system and detection system south of column line T4.

The east cableway on el 130 ft is open to the turbine working floor north of T4.

There are no safe shutdown circuits located north of T7 or on the turbine working An floor (approximately 90 ft down the sprinklered corridor).

exemption is requested for the non 3-h wall and the opening to the turbine working floor.

The presence of the sprinkler system in the corridor will assure that any fire in the turbine building cannot damage the safe shutdown cables.

The intrusion of smoke from such a fire into the corridor will be of no consequence as the only components in the corridor are cables.

Thus, the installation of a raced fire barrier at the end of the corridor and the sealing of the penetration to the turbine building would not enhance fire protection safety.

O 4-92

U 4.3.5 RIVER INTAKE STRUCTURE 4.3.5.1 Area Description This area contains approximately 3200 ft of floor area on el 2

111 ft.

(See figure 4-12.)

The building contains both safety divisions of RHR service water pumps and associated cabling and the MCCs for-both units.

In addition, the area contains both safety divisions of plant service water pumps and associated cabling and the MCCs for both units.

Cabling is located at ceiling level both in conduit and in cable trays.

The diesel generator 1B service water pump is located at the north end of the building.

The intake structure is well separated from other buildings at the plant and is, therefore, not subject to fire exposure from surrounding areas.

The enc 1'osing walls are reinforced concrete and separate the area from the outside.

Four RHR service water pumps and four plant service water pumps are provided for each unit.

Two pumps of each type are required to ensure safe plant shutdown for each unit.

Concrete curbs 6 in. high are provided around the perimeter of each safety division (two pumps) of RHR pumps.

Each curb is designed to prevent oil leakage from one safety division of pumps from spreading to the redundant safety division of RHR pumps located

(~}

adjacent to the area.

RHR and plant service water pumps for N-Unit 1 are located on the west wall with Unit 2 pumps located on the east wall.

The two units are separated by approximately 30 ft.

The eight plant service water pumps are located adjacent to one another (4-ft separation) along the south wall of the building.

Safety-related cabling is routed both in cable trays and in conduit.

As much as practical, Division 1 and Division 2 cabling is located on opposite sides of the structure.

When both safety divisions of cabling are located in close proximity to one another and where divisional interactions occur, one safety division of cabling has been wrapped with a ceramic fiber blanket material designed to provide a 1-h fire resistance rating.

No redundant circuits in conduit pass over the opposite division of cable tray.

The combustible loading within the zone consists of 42,570 Btu /ft for cable insulation, and 12,440 2

Btu /ft for oil (24 gal in each RHR service water pump and 6 2

gal in each plant service water pump).

A summary of this area is contained in table 4-23.

4.3.5.2 Fire Protection Systems Smoke detectors of the ionization type are installed at ceiling level to provide prompt notification of fire conditions

/~

throughout the area.

Primary fire suppression capability for

(_}/

localized protection of RHR and plant service water pump motors 4-93

is provided by a wet pipe sprinkler system with directional h

closed nozzles installed immediately above each pump and motor unit.

Actuation of the sprinkler system is effected upon actuation of the individual thermal element within each water spray nozzle.

Water spray barriers are installed to separate each safety division of RHR and plant service water pumps (two pumps in each safety division) to ensure that water spray over one safety division of pumps will not impair the operation of the redundant safety division of pumps.

A water spray barrier has also been installed between each unit of four RHR service water pumps and its associated MCCs to prevent water spray system discharge from inadvertently spraying MCCs.

In addition, a 1/2-in. steel plate barrier has been installed to separate RHR service water p' umps and MCCs for each unit and to separate the plant service water pumps from the remainder of the equipment in the structure.

These barriers do not extend fully from ceiling to floor but are partial barriers designed primarily to confine water spray to the intended area of operation.

Secondary suppression capability for the safety-related pumps and fire suppression capability for general area protection is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from adjacent yard O

hydrants.

Floor drains are provided; however, flooding is not of concern for the equipment in this area.

Electrical panels are pad mounted above floor level.

The concrete curbs provided around each safety division of RHR and plant service water pump are designed to contain any oil leakage to the area immediately surrounding the affected safety division of pumps.

Two means of access are provided to facilitate fire brigade operations.

A fire in this area could damage one safety division of RHR or' plant service water pumps and associated cabling and the MCCs for either unit.

Such a fire would not be expected to spread to the redundant safety division of RHR pumps, and resultant damage would be expected to be minimized due to the protection afforded by the water spray systems and the confinement provided by the concrete curbs.

The water spray shields provided should confine water spray to only one safety division of pumps at any given time, thereby ensuring operability of the redundant RHR and plant service water systems.

A fire in this area could damage one safety division of cabling associated with the RHR or plant service water pumps for either unit but would not be expected to spread to the redundant safety division of cableline due to prompt fire detection, effective action of the fire brigade, and the protection afforded by the ceramic fiber wrapping in addition to spatial separation.

O 4-94

[)

\\_/

4.3.5.3 Safe' Shutdown Analysis With one exception (conduit 2ESB231) and in the vicinity of the separation of pathway 1 and pathway 2 raceways.for Unit 2

pumps, is provided.

This separation varies from greater than 20 ft to 8 ft.

The circuits for Unit 1 are routed in cable trays with limited separation.

4.3.5.4 Modifications Protect co'nduit 2ESB231 in a 1-h fire barrier.

Protect all Unit 1 cable trays with a 1-h fire barrier.

4.3.5.5 Exemptions to Appendix R The proposed modification meets Appendix R, paragraph III.G.2.C with the exception of an automatic fire suppression system.

An exemption to the requirement for an automatic suppression system is requested due to the low combustible loading in the area as a result of wrapping all cable trays in the area.

The automatic suppression system provided_for the pumps will provide protection for the redundant pathway of pumps.

The combustible loading for the area would be 12,440 Btu /fta for oil following

("}

the modification.

'w./

d 1

4-95

4.3.6 EAST CORRIDOR, CONTROL AND TURBINE BUILDING AND CONDENSATE PUMP AREA el 112 ft 0 in.

4.3.6.1 Area Description 2

This area contains approximately 20,400 ft of floor area on el 112 ft.

(See figures 4-2 and 4-15.)

The north portion of this area is in the control building and contains the Unit 1 water analysis room and the corridor connecting the turbine building.

This control building portion is enclosed by 3-h rated walls on the north, east, and west sides.

The turbine building portion of this area contains the condensate pump area and the narrow hallway, beneath the east cableway, connecting the control building portion to the condensate pump area.

The turbine building portion is separated from the reactor building by 3-h fire rated walls and all other adj acent rooms by reinforced concrete walls.

There is an open stairway in this area that connects to the Unit 2 east cableway.

The combustible loading for this area is 33,650 Btu /ft'.

4.3.6.2 Fire Protection Systems Fire suppression capability for this area is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remo.te hose stations located throughout the plant.

Floor drains are provided; however, flooding is not of concern for the area.

4.3.6.3 Safe Shutdown Analysis l

For this area, it was assumed that all of the pathway 1 components were lost in a fire and pathway 2 components would be used for shutdown.

There are no pathway 2 components in this area that are required for shutdown using pathway 2.

4.3.6.4 Modifications None.

4.3.6.5 Exemptions to Appendix R Appendix R requires that fire areas be surrounded by 3-h fire rated barriers.

An exemption from this requirement is requested for the nonrated walls separating this area from the condenser area and the west cableway.

Also an exemption is requested for h

the open stairway connecting to the east cableway.

The east 4-96

O.

cableway has an area wide sprinkler-system that would prevent the spread of a fire up this open stairway.

The spread of smoke into the cableway would be of no consequence as the only safe shutdown components in the cableway are cables.

G

-O d

u 9

0 4-97

4.3.7 TURBINE BUILDING WEST CABLEWAY el 112 ft 4.3.7.1 Area Description This area contains approximately 7500 ft of floor area on el 2

112 ft.

(See figures 4-14 and 4-15.)

This area is a long, narrow cableway with electrical cabling in horizontal trays affixed to both sides of the corridor.

The west wall o~f the area separates the cableway from the outside (below grade location).

The east wall between the cableway and the control building is a 3-h fire rated wall.

The remaining walls are nonrated concrete walls separating the cableway from the main condenser areas and the steam jet air ejector areas.

4.3.7.2 Fire Protection Systems Primary fire suppression capability for this area is provided by a closed head sprinkler system installed at ceiling level throughout the area.

Fire detection for the area is provided by the thermal elements in each sprinkler head.

Secondary suppression capability is provided by the standpipe system for fire brigade use.

Hose stations are provided for protection of the area.

In the event of a single piping failure in the fire water supply system, supplemental hose lines can be supplied from remote hose stations located throughout the plant.

Floor drains are provided; however, flooding is of no concern for this area since all cables are located in trays a minimum of 2 ft above floor level.

4.3.7.3 Safe Shutdown Analysis For this area, it was assumed that all of the pathway 1 components were lost in a fire and pathway 2 components would be used for shutdown.

There are no pathway 2 components in this area that are required for safe shutdown by pathway 2.

Additionally, there are no pathway 2 components in the adjacent rooms that are necessary for shutdown using pathway 2.

4.3.7.4 Modifications None.

4.3.7.5 Exemptions to Appendix R Appendix R requires fire areas to be enclosed by 3-h fire rated walls.

An exemption from this requirement is requested for the nonrated walls separating this area from the turbine building The sprinkler system in the area will prevent damage to areas.

the cables should hot gases from a fire in the adjacent area 4-98

enter through the unsealed penetrations.

The entrance of smoke into the area is of no consequence as the only safe shutdown related components in the area are cables.

I O

I

(

4 O

4-99

(~

km TABLE 4-1 AREA DESCRIPTION -'4160-V TRANSFO'RMER ROOM, UNIT 1 Building:

Control building, el 130 ft i'

Construction:

Walls - Reinforced concrete with masonry block around fire rated sliding door Floor - Reinforced concrete Ceiling - Reinforced concrete i

Ceiling height:

16 ft Room volume:

4000 ft' Ventilation:

9600 ft'/ min Congestion and accessibility:

Very low congestion due to cables Combustibles:

Negligible combustible loading Existing fire protection systems:

Ionization type smoke detectors, CO hose reels, 2

hose stations I

l t

4 l

lO

TABLE 4-2 N

AREA DESCRIPTION - WEST 600-V SWITCHGEAR ROOM, UNIT 1 Building:

Control building, el 130 ft Construction:

Walls - Reinforced concrete and reinforced concrete block walls Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

16 ft Room volume:

9600 f t' Ventilation:

9600 ft'/ min Congestion and accessibility:

Moderate congestion near ceiling 2

Combustibles:

25,533 Btu /ft

('S Existing fire protection systems:

Ionization type smoke hose reels, N

detectors, CO2 hose stations e

9 V

TABLE 4-3 AREA DESCRIPTION - ANNUNCIATOR ROOM, UNIT 1 Building:

Control building, el 130 ft l

Construction:

Walls - Reinforced concrete and concrete block Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

16 ft Room volume:

4000 ft' Ventilation:

1200 ft'/ min Congestion and accessibility:

Moderately congested near ceiling Combustibles:

81,852 Btu /ft* for cable insulation Existing fire protection systems:

Ionization type smoke I. O-detectors, hose stations, CO2 hose reels l

1 t

t I

i -

'd TABLE 4-4 AREA DESCRIPTION -

CONTROL BUILDING WORKING FLOOR (el 112 ft), UNIT 1 Building:

Control building, el 112 ft Construction:

Walls - Reinforced concrete and concrete block Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

16 ft Room volume:

144,000 ft' Ventilation:

Not applicable Congestion and accessibility:

Pad mounted air compressors, three for each unit in this zone,moder-ate congestion due to cable trays

[~)

between el 120 ft and el 123 ft

\\/

easily accessible.

Combustibles:

34,799 Btu /ft for cable insulation, 1160 2

Btu /ft for flammable gas potential 2

Existing fire protection systems:

Localized closed head, water.

spray protection ionization type smoke detectors, general zone protection by standpipe system O

TABLE 4-5 ZONE DESCRIPTION -

REACTOR BUILDING WORKING FLOOR (el 158 ft)

AND HVAC ROOM (el 164 ft), UNIT 1 Building:

Reactor building, el 158 ft and 164 ft (north and south)

Construction:

I Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

25 ft (el 158 ft) and 19 ft (el 164 ft) 2 Room volume:

238,000 ft Ventilation:

Not applicable Congestion and accessibility:

Moderate congestion due to

~

stacked cable trays between el

('

176 ft 6 in, and el 178 ft.

x Easily accessible Combustibles:

13,635 Btu /ft for cable insulation and a 2

concentration of clean health physics supplies along the east wall of the working floor.

For the HVAC room, the loading is 34,335 Btu /ft* for 2

cable. insulation and 106,950 Btu /ft for charcoal in filters.

Existing fire protection systems:

Standpipe system for use by the fire brigade.

Hose stations provided throughout the working floor.

Closed head sprinkler coverage and detection system for the HVAC room., Deluge system on the charcoal filters.

TABLE 4-6 ZONE DESCRIPTION - REACTOR BUILDING CRD ACCUMULATORS AND WORKING FLOOR (el 130 ft), UNIT 1 Building:

Reactor building, el 130 ft (north and south)

Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

26 ft 8

Room volume:

390,000 ft Ventilation:

Not applicable Congestion and accessibility:

Very congested near the ceiling, moderate congestion in the general area.

Combustibles:

105,262 Btu /ft for cable insulation 2

Existing fire protection systems:

Ionization type smoke detectors, standpipe system for fire brigade use, hose stations O

(~~\\

'\\ /

TABLE 4-7 ZONE DESC'RIPTION - TORUS ROOM, UNIT 1 Building:

Torus room, reactor building below el 130 ft (north and south)

Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

40 ft' Room volume:

536,000 ft' Ventilation:

Not applicable Congestion and accessibility:

Only access to the zone is via two hatches on the north and south sides of the 130-ft

')

elevation.

The floor area below f'/

's.

the torus at the floor is low congestion.

The ceiling above the torus is highly congested.

Combustibles:

Combustible loading consists of cable insulation.

Existing fire protection systems:

Hose stations D

b 4

TABLE 4-8 AREA DESCRIPTION -

CONTROL BUILDING ANNUNCIATOR ROOM, UNIT 2 Building:

Control building, el 130 ft Construction:

Walls - Reinforced concrete and concrete block Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 14 ft 0 in.

Room volume:

Approximately 3500 ft' Ventilation:

3-h rated fire dampers Congestion and accessibility:

Moderately congested near' ceiling 2

Combustibles:

Cable insulation 81,852 Btu /ft O-Existing fire protection systems:

Smoke detectors, hose I

stations, standpipe system for fire brigade use, Co2 hose reels 4

I f

O

....-y..

/" *N TABLE 4-9 AREA DESCRIPTION -

CONTROL BUILDING HEALTH PHYSICS AREA, UNIT 2 Building:

Control building, el 130 ft Construction:

Walls - Reinforced. concrete and masonry Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 14 ft 0 in.

Room volume:

Approximately 47,600 ft' Ventilation:

3-h fire rated damper Congestion and accessibility:

Moderate congestion due to numerous offices and laboratories

()

2 Combustibles:

5160 Btu /ft Existing fire protection systems:

Smoke detectors, standpipe system for fire brigade use, hose hose stations, two CO2 reels I

i

\\-

TABLE 4-10 AREA DESCRIPTION -

CONTROL BUILDING SWITCHGEAR HALLWAY, UNIT 2 Building:

Control building, el 130 ft Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 14 ft 0 in.

8 Room volume:

Approximately 5600 ft Ventilation:

Not applicable Congestion and accessibility:

Moderately congested near ceiling Combustibles:

Cable insulation 333,799 Btu /ft:

Smoke detectors, standpipe Existing fire protection systems: _ system for fire brigade use, hose hose stations, 2-ft CO2 reels i

l l

4 r--,yrt---


rv+w--

,,-c--+-

-".-~m*,-r-ec-e w

  • =.--,,r-e-

,-,,--,re-c.,r-er

---n---=

w-.-

w--

+

r,-

- - - - + + - - -

w

(~)

TABLE 4-11 AREA DESCRIPTION -

CONTROL BUILDING OIL CONDITIONER ROOM, UNIT 2 Building:

Control building, el 130 ft Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 14 ft 0 in.

Room volume:

Approximately 29,400 ft' Ventilation:

3-h rated fire dampers.

Congestion and accessibility:

Low congestion, easily accessible 2

Combustibles:

Turbine lube oil 558,006 Btu /ft (N

\\-

Existing fire protection systems:

Open head deluge water spray system, thermal detectors, standpipe system for fire brigade use, hose stations S

TABLE 4-12 AREA DESCRIPTION -

CONTROL BUILDING STATION BATTERY ROOM 2B, UNIT 2 I

Building:

Control building, el 112 ft Construction:

Walls - Reinforced concrete floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 15 ft 0 in.

Room volume:

Approximately 13,500 ft' Ventilation:

3-h rated fire damper Congestion and accessibility:

Low congestion, easily accessible 2

Combustibles:

Hydrogen gas 3.60 Btu /ft /h

/^)

Battery casings 2450 Btu /ft*

8

(_/

Cable insulation 26,184 Btu /ft Existing fire protection systems:

Smoke detectors, standpipe system for fire brigade use, hose stations O

.. ~,.., -.,

r~W k-TABLE 4-13 ZONE DESCRIPTION'-

REACTOR BUILDING WORKING FLOOR (el 158 ft), UNIT 2 Building:

Reactor building, el 158 ft (north and south).

Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 25 ft 5 1/2 in.

2 Room volume:

Approximately 219,300 ft Ventilation:

Not applicable Congestion and accessibilityi Congested near ceiling, easy accessibility

N Combustibles:

Cable insulation 34,367 Btu /ft*

(d Existing fire protection systems:

Standpipe system for fire brigade use, hose stations P

O

O#

TABLE 4-14 ZONE DESCRIPTION -

REACTOR BUILDING HVAC ROOM, UNIT 2 Building:

Reactor building, el 164 ft Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 19 ft 0 in.

Room volume:

Approximately 53,200 ft' Ventilation:

Not applicable Congestion and accessibility:

Congested near ceiling, easy accessibility 8

()

Combustibles:

Cable insulation 34,335 Btu /ft Existing fire protection systems:

Smoke detectors, hose stations, preaction sprinkler system, standpipe system for fire brigade use 4

I f

r-

,.---e, s--

w

>,-m--

,,.m er e e

,-,--,,,.,,-----~~,w-r-~-

- -, ~, - - - -

Os TABLE 4-15 ZONE DESCRIPTION --

REACTOR BUILDING WORKING ELOOR, UNIT 2 Building:

Reactor building, el 130 ft (north and south)

Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 24 ft 0 in.

l Room volume:

Approximately 360,000 ft' Ventilation:

Not applicable Congestion and accessibility:

Heavily congested near ceiling, easy accessibility 2

(

Combustibles:

Cable insulation 116,167 Btu /ft Existing fire protection systems:

Smoke detectors, hose stations, standpipe system for fire brigade use f

O

l O

TABLE 4-16 ZONE DESCRIPTION -

REACTOR BUILDING TORUS AREA, UNIT 2 Building:

Reactor building, below el 130 ft (north and south)

Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 40 ft 5 1/2 in.

Room volume:

Approximately 542,700 ft' Ventilation:

Not applicable Congestion and accessibility:

Heavily congested near ceiling, accessible only through 2 openings in the el 130-ft floor 2

Combustibles:

Cable insulation 50,631 Btu /ft Existing fire protection systems:

Hose stations, standpipe system for fire brigade use O

p. w e 4..w O

TABLE 4-17 AREA DESCRIPTION -

TURBINE BUILDING EAST CABLEWAY, UNIT 2 Building:

Turbine building, el 130 ft Construction:

Walls - Reinforced concrete and masonry Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 14 ft 0 in.

Room volume:

Approximately 54,600 ft' Ventilation:

Not applicable Congestion and accessibility:

Congested alcag walls, easy accessibility 2

()

Combustibles:

Cable insulation 223,526 Btu /ft 2

oil 115,785 Btu /ft Existing fire protection systems:

Smoke detectors, hose sta-tions, automatic sprinkler system, open head deluge water spray systems, thermal.

detectors, standpipe system for fire brigade use O

')

TABLE 4-18 AREA DESCRIPTION -

DIESEL BUILDING SWITCHGEAR ROOM 2G, UNIT 2 Building:

Diesel building switchgear room 2G Construction:

Walls - Reinforced concrete i

Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 20 ft 0 :ba.

Room volume:

Approximately 21,400 ft' Ventilation:

4000 ft'/ min room ventilator Congestion and accessibilit'y:

Congested near ceiling, easy accessibility 2

Combustibles:

Cable insulation 53,460 Btu /ft Existing fire protection systems:

Smoke detectors, Co2 hose reel, fire hydrants, thermal detector 9

O

TABLE 4-19' AREA DESCRIPTION'-

CONTROL BUILDING LPCI INVERTER ROOM Building:

Control building, el 147 ft Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

Approximately 14 ft 0 in.

Room volume:

Approximately 14,000 ft' Ventilation:

3-h fire rated dampers-Congestion and accessibility:

Heavily congested, easily accessible Combustibles:

Negligible Existing fire protection systems:

Standpipe system fbr fire brigade use, hose stations O

(~

\\m/

TABLE 4-20 AREA DESCRIPTION -

i CONTROL BUILDING CORRIDOR 4

Building:

Control building, el 147 ft 1

Construction:

Walls --Reinforced concrete or masonry block Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

16 ft Room volume:

60,800 ft' Ventilation:

Not applicable Congestion and accessibility:

Very congested along the narrow corridor 2

Combustibles:

333,799 Btu /ft for cable insulation l

Existing fire protection systems:

Ionization type smoke

]

detectors, preaction sprinkler system, hose hose reels stations, two CO2 I

r

C:)

l

r I

TABLE 4-21 AREA DESCRIPTION -

4 RPS AND VERTICAL CABLE CHASE ROOMS Building:

Control building, el 147 ft Construction:

Walls - Reinforced concrete and masonry block 4

Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

16 ft Room volume:

14,400 f t' I

Ventilation:

4000 fts/ min -

]

Congestion and accessibility:

Moderate congestion near ceiling in the RPS room, highly congested j

i in the vertical cable room 2

Combustibles:

900,397 Btu /ft for cable insulation Existing fire protection systems:

Ionization type smoke detectors, sprinkler system, hose stations, CO hose reels 2

I l

4 O

I i

4

,--,c, n..-,..

,,.,,,n.

.,.,,-,n,

,,,,.n

-,n.n.

l em k

TABLE 4-22 w

AREA DESCRIPTION -

EAST CABLEWAY Building:

Turbine building east cableway, el 130 ft Construction:

Walls - Reinforced concrete and masonry block Floor - Reinforced concrete-Ceiling - Reinforced concrete Ceiling height:

16 ft 2

Room volume:

56,000 ft 2

Ventilation:

4300 ft / min Congestion and accessibility:

Extremely congested near ceilings and on walls.

Easily accessible Combustibles:

223,526 Btu /fta for cable insulation Existing fire protection systems:

Automatic sprinklers, hose stations, and noncombustible barriers are installed to separate the two divisions.

O

3 O

TABLE 4-23 AREA DESCRIPTION -

l RIVER INTAKE STRUCTURE Building:

Intake structure Construction:

Walls - Reinforced concrete Floor - Reinforced concrete Ceiling - Reinforced concrete Ceiling height:

15 ft Room volume:

48,000 ft' 8

Ventilation:

190,000 f t / min maximum Congestion and accessibility:

This zone is highly congested.

Combustibles:

42,570 Btu /ft for cable insulation and 12,440 2

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O 5.0 APPLICATION OF NATIONAL FIRE PROTECTION ASSOCIATION gNFPA) 5.1 GENERAL The proposed additional fire detection and suppression systems I

will be installed at Plant Hatch following the special hazards design basis technique allowed by the National Fire Protection Codes.

This technique will utilize a combination of NFPA 13, 15, 72A, 72B, 72C, 72D, and 72E to ensure the maximum effectiveness of the system to limit'the fire hazard at Plant Hatch and to take into account the unique structural configuration and protection problems inherent in a power plant.

These codes and regulations are basically tailored for protection of rooms or areas with relatively regular surfaces and features.

This is a situation seldom realized in the highly congested conditions encountered in the majority of the rooms in a power plant.

In recognition of such conditions and of the special hazards encountered in a nuclear power plant, sound engineering judgment must be exercised in the design and installation of.its fire protection systems rather than routine, absolute compliance with rules which are not always appropriate to the situation.

occasionally, minor deviations from the codes, principally in

.O sprinkler head or detector placement relative to the ceiling, must be taken because of congestion; e.g.,

cable trays, piping, ducting,-in the area of a suppression system.

Such deviations are taken only when they will result in equal or superior protection to that which would result from an inflexible conformance to codes or regulations, if such were possible.

5.2 SPECIFIC CODE DEVIATIONS The following paragraphs outline certain general code deviations

_that have been necessary in past installations of fire protection systems.

Nuclear Regulatory Commission (NRC) approval of these deviations from NFPA codes is requested.

Each of the following paragraphs contains a justification-for the requested code deviation.

5.2.1 DEPARTURE FROM NFPA 13, 14, AND 15 WITH RESPECT TO HANGER SELECTION AND SPACING NFPA critsria governing the hanger design, selection, and spacing criteria for fire suppression systems outlined in NFPA 13, 14, and 15 do not provide for a seismic hanger support system.

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5.2.3 DEPARTURES FROM NFPA 13 AND 15 WITH RESPECT TO SPRINKLER HEAD / NOZZLE PLACEMENT Sprinkler head / nozzle placement do not follow NFPA 13 and 15 criteria in all locations.

Deviations exist where congestion will not allow placement of the device within NFPA allowable tolerances.

An engineering analysis (as permitted by the special hazards philosophy discussed in the NFPA codes) is performed on each head / nozzle that cannot be located per NFPA guidelines.

This analysis is performed on a case by case basis to ensure that the system performance meets or exceeds NFPA criteria.

Sprinkler head placement was selected with consideration for water distribution requirements, head obstruction, heat stratification, and heat banking as a result of excessive congestion of ductwork, trays, and piping to ensure timely delivery of a sufficient heat flux level such that the sprinkler head actuates.

In addition, the sprinkler densities and the selection of 3-wer operating temperature elements, which exceed the minimum dd

tions provided by NFPA, were incorporated to maint i acceptable time lag for suppression system operation.

In view of the material presented above, the system departures from NFPA ara judged equal or better than the location criteria outlined for conventional structures through the applicable sections of NFPA 13 and 15.

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5.2.4 DEPARTURES FROM NFPA 72E WITH RESPECT TO DETECTOR PLACEMENT Smoke / heat / fire detector placement does not follow NFPA'72E criteria in all locations.

The location of each detector utilized several variables, such as smoke and heat stratification, heating, ventilation, and air conditioning (HVAC) airflow (s), ceiling congestion, distance from floor to ceiling as well as the building's configuration and the manuf acturer's recommendations (as instructed by NFPA 72E) when placing the detectors.

Detectors are placed per NFPA 72E when the engineering analysis provides an acceptable system performance.

The NRC recognizes the lack of solid criteria provided by NFPA 72E as well as the limited state of the art knowledge in fire detection equipment and location.

In view of this art of detection, the detection equipment and installation is judged as equal to the NFPA 72E series with respect to installed equipment.

" Acceptance and Verifications for Early Warning Fire a.

Detection Systems," prepared by the NRC by the Reactor s

Engineering Analysis Group, Department of Nuclear Energy, s_,

Brookhaven National Laboratory, Upton, N.Y.,

May 1980.

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5.0 APPLICATION OF NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) 5.1 GENERAL The proposed additional fire detection and suppression systems will be installed at Plant Hatch following the special hazards design basis technique allowed by the National Fire Protection Codes.

This technique will utilize a combination of NFPA 13, 15, 72A, 72B, 72C, 72D, and 72E to ensure the maximum effectiveness of the system to limit the fire hazard at Plant Hatch and to take into account the unique structural configuration and protection problems inherent in a power plant.

These codes and regulations are basically tailored for protection of rooms or areas with relatively regular surfaces and features.

This is a situation seldom realized in the highly congested conditions encountered in the majority of the rooms in a power plant.

In recognition of such conditions and of the special hazards encountered in a nuclear power plant, sound engineering judgment must be exercised in the design and installation of,its fire protection systems rather than routine, absolute compliance with rules which are not always appropriate to the situation.

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Occasionally, minor deviations from the codes, principally in

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sprinkler head or detector placement relative to the ceiling, must be taken because of congestion; e.g.,

cable trays, piping, ducting, in the area of a suppression system.

Such deviations are taken only when they will result in equal cr superior protection to that which would result from an inflexible conformance to codes or regulations, if such were possible.

5.2 SPECIFIC CODE DEVIATIONS The following paragraphs outline certain general code deviations that have been necessary in past installations of fire protection systems.

Nuclear Regulatory Commission (NRC) 2 approval of these deviations from NFPA codes is requested.

Each of the following paragraphs contains a justification for the requested code deviation.

5.2.1 DEPARTURE FROM NFPA 13, 14, AND 15 WITH RESPECT TO HANGER SELECTION AND SPACING NFPA criteria governing the hanger design, selection, and spacing criteria for fire suppression systems outlined in NFPA 13, 14, and 15 do not provide for a seismic hanger support system.

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7 In order to achieve the necessary system integrity for a Class 1 support system, the piping configuration is subjected to a sophisticated rigid analysis for hanger' location.

The type of hanger assemblies required to withstand the excessive loads and movement above NFPA allowances results in each hanger assembly as a unique design requirement.

The resulting installation is an engineered system of superior integrity as opposed to the generalized instructions set forth by NFPA for such structures as warehouses, health care facilities, and general office structures.

It is, therefore, necessary to depart from these codes for pipe supports.

5.2.2 DEPARTURE FROM NFPA 13, 14, AND 15 WITH RESPECT TO COMPONENT SELECTION The NFPA codes specify the use of components listed for fire service by Underwriters Laboratory (UL).

Components listed by UL will be used to the extent practicable, but not all compo.nents will be UL listed.

Underwriters Laboratory does not list every component utilized in the fire protection systems.

In selected cases, more stringent operability requirements, contrary to fire protection desires, dictate the selection of nuclear grade devices.

However, in each case, an engineering evaluation is performed to ensure all criteria is satisfied prior to the final selection.

Closed head directional spray nozzles are utilized because of the ability of the nozzle to deliver better water dispersion with the excessive congestion that exists.

The directional spray nozzles were reviewed by the NRC and accepted for use in the subject utility during the initial Fire Protection Reevaluation.

Additicnal considerations for head selection included overspray control for equipment and devices not involved with the specific hazard.

The component selection is judged equal and better than NFPA guidelines due to the ability to provide water coverage and protection for the hazard while controlling water overspray and flooding potential.

Multibushing reductions were used in a limited number of cases due to nonavailable American Society of Testing Materials (ASTM)

A-234 forged steel reducing fittings and excessive congestion for the pipe runs.

Flow capability and pressure retention is verified at the conclusion of installation by flow test and hydrostatic pressure tests.

In light of the quality control provisions required for this facility, fabrication mat rial, acceptance testing and frequency of inspection, each system is set forth judged superior in quality and exceeds the provisions by NFPA guidelines.

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5.2.3 DEPARTURES FROM NFPA 13 AND 15 WITH RESPECT TO SPRINKLER HEAD / NOZZLE PLACEMENT Sprinkler head / nozzle placement do not follow NFPA 13 and 15 criteria in all locations.

Deviations exist where congestion will not allow placement of the device within NFPA allowable tolerances.

An engineering analysis (as permitted by the special hazards philosophy discussed in the NFPA codes) is performed on each head / nozzle that cannot be located per NFPA guidelines.

This analysis is performed on a case by case basis to ensure that the system performance meets or exceeds NFPA criteria.

Sprinkler head placement was selected with consideration for_ water distribution requirements, head obstruction, heat stratification, and heat banking as a result of excessive congestion of ductwork, trays, and piping to ensure timely delivery of a sufficient heat flux level such that the sprinkler head actuates.

In addition, the sprinkler densities and the selection of lower operating temperature elements, which exceed the minimum directions provided by NFPA, were incorporated to maintain acceptable time lag for suppression system operation.

In view of the material presented above, the system departures from NFPA are judged equal or better than the location criteria outlined for conventional structures through the applicable

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sections of NFPA 13 and 15.

V 5.2.4 DEPARTURES FROM NFPA 72E WITH RESPECT TO DETECTOR PLACEMENT Smoke / heat / fire detector placement does not follow NFPA'72E criteria in all locations.

The location of each detector utilized several variables, such as smoke and heat stratification, heating, ventilation, and air conditioning (HVAC) airflow (s), ceiling congestion, distance from floor to ceiling as well as the building's configuration and the manuf acturer's recommendations (as instructed by NFPA 72E) when placing the detectors.

Detectors are placed per NFPA 72E when the engineering analysis provides an acceptable system performance.

The NRC recognizes the lack of solid criteria provided by NFPA 72E as well as the limited state of the art knowledge in fire detection equipment and location.

In view of this art of detection, the detection equipment and installation is judged as equal to the NFPA 72E series with respect to installed equipment.

a.

" Acceptance and Verifications for Early Warning Fire

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Detection Systems," prepared by the NRC by the Reactor

(_

Engineering Analysis Group, Department of Nuclear Energy, Brookhaven National Laboratory, Upton, N.Y.,

May 1980.

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5.2.5 MISCELLANEOUS DEPARTURES FROM NFPA 13, 14, 15, 20, and 24 5.2.5.1 Exemption is requested from the performance of an annual sprinkler / spray system main drain test as specified by NFPA 13 and 15.

This test is performed to ensure the quality of the water supply from the controlled source.

The following.

reasons are justification from the exemption of the testing requirement:

A.

Quality control of the water supply during construction which includes flushing and hydrostatic testing.

B.

Makeup water is filtered and supplied from the well system at Plant Hatch.

C.

Underground main inspection and flushing on a routine basis.

D.

Additional strainer capabilities which exceed code requirements.

E.

Plant Hatch is a private facility with an independent water supply and distribution sustem.

F.

Hose station risers and control stations are connected to a looped piping system that is fed from two directions.

5.2.5.2 Exemption is requested from the no welding provisions of NFPA 13, 14, 15, and 20.

Justifica~ tion for this exemption resides in the controls required for hot work activities, which are in accordance with other NFPA guidelines.

These controls and the requirements for Seismic Class 1 installation and restricted movement during modification or maintenance activities often require welded assemblies.

These features in conjunction with the fire watch and extensive training of site personnel assure that potential fire conditions are controlled in an acceptable manner.

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