ML20058E263

Forwards Addl Info Supporting Request for Exemption from App R of 10CFR50 Re Fire Protection Features.Evaluation of Deviations from App R for Each Fire Zone & Proposed Design Mods or Proposed Exemptions Provided

ML20058E263
Person / Time
Site:	Millstone
Issue date:	07/16/1982
From:	Cagnetta J, Counsil W NORTHEAST NUCLEAR ENERGY CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
A02497, A2497, NUDOCS 8207280115
Download: ML20058E263 (139)

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July 16, 1982 Docket No. 50-245 A02497 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.

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References:

(1)

W. G. Counsil letter to D. G. Eisenhut, dated March 1, 1982.

(2)

W. G. Counsil letter to Commissioner Hendrie, dated March 19, 1981.

(3)

H. R. Denton letter to W. G. Counsil, dated May 10, 1981.

(4)

R. C. Haynes letter to W. G. Counsil, dated July 2, 1982.

(5)

R. W. Starostecki letter to W. G. Counsil, dated July 7, 1982.

Gentlemen:

MILLSTONE NUCLEAR POWER STATION, UNIT NO. 1 ADDITIONAL INFORMATION SUPPORTING EXEMPTION REQUEST FROM APPENDIX R Northeast Nuclear Energy Company (NNECO) provided to the NRC Staff in Reference (1) an assessment of the fire protection features at Millstone Unit No. 1 pursuant to the requirements of 10CFR50.48 and Appendix R to 10CFR Part 50.

In addition, our evaluation of the de-viations from Appendix R for each fire zone and proposed design modi-fications or proposed exemptions from the requirements of Appendix R were also provided. NNECO had previously requested an exemption from the schedular requirements of 10CFR50.48(c)(5), specifically for additional time to complete the actions described above, in Reference (2).

The Staff granted the schedular exemption request documented in Ref-erence (3) upon the condition that the submittal be complete as defined in Reference (3). Reference (3) also provided NNECO 'a grace period of 60 days in which to provide any supplemental information to that of Reference (1) in order to comply with the requirements of the exemption.

8207290115 820716 PDR ADOCK 05000245 F

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_ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ i The purpose of this document is to provide supplemental information to complement that contained in Reference (1) such that the conditions accompanying the Ref.erence (3) exemption are fulfilled. The insight gained by interacting with the Staff on the Haddam Neck Plant has been utilized during the preparation of this submittal.

i Specifically, the following information is provided within this document.

A o

Section I/ Appendix A - Revised and expanded discussions of l

f each exemption request.

o Section II - Administrative controls, o

Section III - Discussion of intervening combustibles, o

Section IV - A revised compliance summary including a discussion of the schedule for proposed modifications.

o Appendix A - Revised safe shutdown Fire Zone Analyses.

o Appendix B - Intervening combustibles.

o Appendix C - Compliance status.

Condition (1)a of Reference (3) is fulfilled in that concise statements of NNECO's exemption requests are provided in Appendix A.

Regarding the revised discussion on the exemption requests, the information provided is intended to fulfill conditions (1) b, and (1) e of Reference (3).

Condition (2) does not apply as alternative or dedicated shutdown systems are not being proposed.

1.

Fire Zone AnalysisSection VII of Reference (1) provided an evaluation of each fire zone at Millstone Unit No. I for compliance with the provisions of Appendix R.

Where compliance with Appendix R did not exist, modifications were proposed to bring the fire zone into compliance or an exemption from specific requirements of III.G.2 of Appendix R was and is being requested pursuant to 10CFR 50.48 (c)(6) and 10CFR 50.12(a).

Since the Reference (1) submittal, each exemption request has been re-evaluated. Several revised modifications have been engineered which have resulted in compliance for several fire zones. Each exemption request is described in Appendix A with additional discussions to support NNECO's remaining exemption requests.

It should be noted that in addition to the original seven fire zones for which NNECO had requested an exemption from the specific requirements of Appendix R, re-evaluations have resulted in the need for exemptions in ten specific fire zones. This change is the result of the identification of additional safe shutdown equipment in Fire Zones R-2D, T-5C, and T-19D for which existing fire protection features have been judged to fulfill the intent of Section III.G.2 of Appendix R but for which an exemption is required.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ The fire zone analysis for each exemption is presented in a format identical to that of Reference (1). This will facilitate comparison of the discussions for each fire zone between Reference (1) and this document. Appendix A provides specific fire zone analyses for the following areas:

o Reactor Building Area R-2A R-2B R-2C R-2D o

Turbine Service Equipment Area Area T-5C o

Cable Vault Area T-16 o

Switchgear Area Area T-19A T-19D T-19B T-19E T-19C o

Control Room Area T-21 The ten exemption requests are described in Appendix A and supersede the exemption requests of Reference (1). The ten areas for which NNECO requests exemptions from specific requirements of Section III.G.2 of Appendix R are:

o Reactor Building Area R-2A R-2D o Cable Vault Area T-16 o Switchgear Areas T-19A T-19D T-19B T-19E T-19C o Control Room Area T-21 o Turbine Service Equipment Area Area T-5C II.

Administrative Controls Currently, administrative controls are used to ensure proper performance of safety systems and compliance with NRC regulations. Examples include:

maintaining proper boron concentrations and levels in various o

tanks for safety-related applications, mitigating actions in the event of undervoltage conditions, o

personnel radiation exposure limitations, and o

implementing the security plan and the safeguards contingency o

plan NNECO proposes to add a customized administrative technical specification to control the quantity and use of flammable liquids in specific fire areas at Millstone Unit No. 1.

This proposal was discussed at great lengths during a May 13, 1982 meeting with the Staff at which time the advan-tages and disadvantages were reviewed.

t NNECO proposes to restrict flammable liquids from the control room, cable vault. Specifically, Technical Specifications would require written permission from the shift supervisor or supervising control operator prior to introducing flammable liquids in excess of one-half pint into the two areas described above. The Technical Specifications would also require that these liquids to be contained in suitable containers which would be non-spillable and have flame arrestors in the nozzles. Container volume would be limited to one quart, independent of the safety features of the containers.

The key provision of these administrative controls would be the requirement to post a dedicated fire watch with appropriate fire fighting equipment to monitor the activity which utilizes the flammable liquids.

Signs would be posted at all entrance ways to the fire areas for which these requirements apply providing additional assurance that the flammable liquid restriction will be adhered to.

Elevating flammable liquid controls to the level of Technical Specifications will provide for higher visibility to both NNECO personnel as well as NRC personnel. As such, they would be more readily enforceable. Controls such as proposed herein effectively reduce the potential for fire in the two fire areas described above and add another layer of fire protection defense-in-depth to these zones. Limiting the quantity of flammable liquids available to a fire as well as providing a dedicated fire watch would limit any potential damage which may occur should a fire initiate during the use of such liquids.

As stated during the meeting, the Staff's major concern in granting any credit for such a proposal is the difficulty associated with quantifying the reduction in risk associated with the use of such controls. We recognize that the rate of success in the implementation of such controls is highly variable throughout the industry. We note that several reviews have recently been conducted at Millstone Unit No. I which focused on personnel performance. The Systematic Assessment of Licensee Performance (SALP) as well as Institute of Nuclear Power Operations (INFO) audits have been completed. The results of these audits support NNECO's pro-posal that credit for administrative controls at Millstone Unit No. I should be granted. Specifically, the following comments were taken from the SALP report for NNECO issued in Reference (4).

6.b. FIRE PROTECTION and HOUSEKEEPING "The Resident Inspectors observed housekeeping and fire protection controls during routine inspections. No items of noncompliance were identified. The response of licensee personnel, including the shift fire brigade, to several small fires was satisfactory.

Performance of the Fire Detection / Suppression Surveillance Test Program has improved.

l l The NRC has concluded in Reference (4) that NNECO's Fire Protection and Housekeeping performance level is Category 1 which states:

" Category 1: Reduced NRC attention may be appropriate.

Licensee management attention and involvement are aggressive

.and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of per-formance with respect to operational safety or construction is being achieved."

l The transmittal letter of Reference (4) states:

"Overall, we find that management attention at your facilities is aggressively oriented toward nuclear safety. Effective use of ample resources has resulted in a high level of performance in operational safety and construction activities."

In addition, a recent inspection by the office of Inspection and Enforcement was conducted at the Millstone Nuclear Power Station. The results of this inspection have been forwarded to NNECO in Reference (5) and state, in part, the following:

" Plant Housekeeping Controls Storage of material and components was observed with respect to prevention of fire and safety hazards. Plant housekeeping was evaluated with respect to controlling the spread of surface and airborne contamination. There were no unacceptable conditions identified.

Fire Protection / Prevention The inspector examined the condition of selected pieces of fire fighting equipment. Combustible materials were being controlled and were not found near vital areas. Selected cable penetrations were examined and fire barriers were found intact.

Cable trays were clear of debris. There were no unacceptable conditions identified."

In further support of our proposal, we advance our view that the credit being requested in this regard is not conceptually different from that granted by the Staff for other safety-related applications identified above.

It would be incongruous for the Staff to accept this approach for certain applications and reject it for others.

NNECO's proposed administrative controls for flammable liquids will add another level of fire protection to the control room and cable vault.

This added control on flammable liquid introduction into these areas together with the existing and proposed fire protection features described in Appendix A for these areas, will provide equivalent protection to that achieved by fulfilling the requirements of Section III.G.2 of Appendix R to 10CFR50. NNECO proposes these additional restrictive administrative controls to support the exemption requests for fire areas T-16, and T-21.

A formal license amendment application will be docketed upon resolution of the exemption requests for these fire areas.

__ _ _ _ _ _ _ __________ _____ __ _ Figures 1 and 2 are illustrative of the Technical Specification Admini-l strative Controls which have been described herein.

l III. Intervening CombustiblesSection III.G.2 of Appendix R to 10CFR50 specifies the means for en-suring that redundant. trains of safe shutdown equipment, located in the

(

same fire area, remain free of fire damage.

Item b identifies detection, automatic suppression and separation of safe shutdown equipment by 20 feet with no intervening combustibles or fire hazards as one means of compliance with Section III.G.2.

Recognizing that all materials are combustible at sufficiently elevated l

temperatures, the provision "no intervening combustible or fire hazards" l

of Section III.G.2.b of Appendix R is subject to interpretation. To ensure Staff cognizance of the approach utilized in our fire hazard evaluations, NNECO presents a discussion in Appendix B regarding the interpretation of intervening combustibles in the context of compliance with Section III.G.2.b of Appendix R.

The basis for the definition presented in Appendix B is a consideration of the credible fire which would be expected to occur in any given fire area at Millstone Unit No. 1.

Several of the conclusions presented both in Reference (1) and in Appendix A have been based on an evaluation of intervening combustibles present in each fire zone. NNECO has requested exemptions in several fire zones from the requirement of Section III.G.2.b of Appendix R for "no intervening combustibles".

In these instances, the evaluation of the specific fire zone concluded that the intervening combustibles present do not compromise the integrity of the redundant safe shutdown equipment in the zone.

IV.

Compliance Summary To complement the information presented in the Fire Zone Analyses pre-sented in Section I above, a revised synopsis of the current compliance status on a fire zone specific basis is provided as Appendix C. It is NNECO's intention to provide the Staff with a revised schedule for the completion of the modifications identified in the attached summary after a review of all fire protection modifications at the Haddam Neck Plant and Millstone Unit Nos. I and 2 can be accomplished. This review will establish an optimum fire protection modification implementation schedule for all three of the Northeast Utilities operating nuclear power plants which is compatible with each of the plant's scheduled outages.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ This approach will entble Northeast Utilities to bett:r utilize its engineering and construction manpower such that the proposed fire i

protection modifications can be implemented on a timely and cost effective schedule. The schedules for the fire protection modifications t

will be provided to the Staff following the completion of supplemental submittals for both the Haddam Neck Plant and Millstone Unit No. 2.

As a result of completing this integrated evaluation, we anticipate that additional schedular exemption requests will be necessary.

With the docketing of this submittal, NNECO concludes that the require-ments 'of 10CFR50.48(c)(5) for submitting plans to comply with 10CFR50.48(c)(2) and 50.48(c)(3) have been fulfilled. Given the extensive interrelationship between modifications resulting in com-pliance and those associated with exemption requests, it is not prac-tical to provide detailed implementation schedules at this time. For those modifications associated with fire zones involving exemption requests, we interpret 10CFR to mean that the schedule is tolled pursuant to 50.48(c)(6). For those modifications identified which would result in compliance with 10CFR50.48 and Appendix R, a schedular exemption from the requirements of 10CFR50.48(c)(5) is requested pursuant to 10CFR50.48(c)(6) and 10CFR50.12(a). We are confident that reasonable schedules can be developed promptly after the Staff responds to the proposals contained herein. Such schedules would reflect the results of an integrated evaluation of previously committed plant modifications and other resource consider-ations in concert with recently articulated Commission policy in this regard.

Subsequent to submitting the enclosed report, NNECO will continue verification of the information provided to the Staff.

In the event that any clarification of this information is found to be necessary, NNECO will provide such clarification as expeditiously as possible.

We remain prepared to interact with the Staff as necessary to bring this issue to resolution.

Very truly yours, NORTHEAST NUCLEAR ENERGY C ANY Y1 N. G. Counsil Senior Vice President J. P. dagnett Vc Preside Nuclear and Environmental Engineering

FIGURE 1 Flanenable liquid Administrative Technical Specification l

ADMINISTRATIVE CONTROLS FIANAELE LIQUID CONTROL Transient flammable liquids in volumes greater than 1/2 pint shall be restricted for the control room, cable vault, cable spreading room and switchgear room except under the following conditions:

1.

Written permission is obtained from the Supervising Control Operator or the Shift Supervisor.

2.

The flac:nable liquids are contained in a suitable container not to exceed one quart in volume, and 3.

A dedicated fire watch with fire fighting equipment is assigned to the activity e

O

FIGURE 2 Flammable Liquid Administrative Technical Specification - Reporting Note: This item is intended to provide for reporting of potentially generic problems.

b.

Thirty Day Written Reports The reportable occurrences discussed below shall be the subject of written reports to the Director of the appropriate Regional Office within thirty days of occurrence of the event. The written report shall include, as a minimum, a completed copy of a license event report form.

Information provided on the licensee event report form shall be supplemented, as needed, by additional narrative material to provide complete expalanation of the circumstances surrounding the event.

(1) Reactor protection system or engineered safety feature instrument settings which are found to be less conservative than those established by the technical specifications but which do not prevent the fulfillment of the functional requirements of affected systems.

(2) Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown by a limiting condition for operation.

Note:

Routing surveillance testing, instrument calibration, or preventative maintenance which require system configurations as described in items 2.b(1) and 2.b(2) need not be reported except where test results themselves reveal a degraded mode as described above.

(3)

Observed inadequacies in the implementation of admin'istrative or procedural controls which threaten to cause reduction of degree of redundancy provided in reactor protection systems or engineered safety feature systems.

(4)

Abnormal degradation of systems other than those specified in item 2.a(3) above designed to contain radioactive material reulting from the fission process.

Note:

Sealed sources or calibration sources are not included under this item.

Leakage of valve packing or gaskets within the limits for identified leakage set forth in technical specifications need not be reported under this time.

(5)

Unauthorized introduction of greater than 1/2 pint of flammable liquids into the control room, cable vault, cable spreading ronr. r suitchecar room.

l APPENDIX A

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. REVISED FIRE ZONE ANALYSES O

DOCKET NO. 50-245 JULY, 1982

cak-43 Millstone 1 Safe Shutdown Fire Zone Analysis i

El. 36'6" Turbine Building Fire Area No. T-21 Main Control Room Safe Shutdown Equipment 1

o Control panels M

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li Design Features o

Walls, floors and ceiling consist of reinforced concrete except the south wall is acoustic metal panel and glass separating the Unit 1 and Unit 2 control rooms.

o Doors are fire rated.

o All penetrations are sealed.

Fire dampers have been installed in ventilation duct work o

Quanjity Fire Logd Combustible Material (ft )

(Btu /ft )

Cable 100 9,900

Fira Arra No. T-21 Pcg2 2 Existing Fire Protection Early warning ionization type smoke detection system.

o One hose station and two portable carbon dioxide extinguishers.

o Compliance With' Appendix R Does not comply with Section III.G.2 of Appendix R.

Exemption requested (See proposed modification and discussion).

Proposed Modifications 1.

Customized administrative controls will be implemented to minimize introduction of flammable liquids in the control room.

(See aforementioned discussion on customized administrative controls.)

2.

Fire rated dampers or equivalent will be installed on louvered openings of the main control board and its auxiliary cabinets.

3.

All openings between the cabinets and the floor that would allow a spilled flammable liquid to enter the cabinets will be sealed.

4.

Ramps (1/8"/ foot) will be installed to divert spilled flammable liquid away from required auxiliary cabinets.

(See Attachment

1. 2, Sketch 1.)

Discussion The main control room at Millstone I was evaluated under three postulated conditions.

In order to evaluate these conditions, it was necessary to identify all safe shutdown required components and panels. Enclosed as Attachment 3 is a description of required components / panels and associated plan views and sketches which will identify all critical /

sensitive areas within the control room.

The main control room postulated fire conditions are as follows:

o Level I:

Involves a position that a major damaging fire could not result in significant damange because of unique features of control room and proposed customized administrative controls.

o Level II:

A flammable liquid spill is allowed to burn and proposed fire protection modifications prevent serious / destructive damage to control room equipment.

o Level III:

Unmitigated fire causes individual panel damage and operator action is discussed which compensate for damage.

Fire Arza No. T-21 Pag 2 3 With respect to Level I, NNECO concludes that damaging or destructive fires are those fires that go undetected for considerable periods of time, or those fires that develop rapidly because.of large quantities of combustibles such as flammable liquids.

The control room differs from all other areas of a power plant with respect to potential destructive fires. The control room has unique features which eliminate damaging / destructive fires. These unique features include the following:

1.

Control room is continuously manned by licensed operators.

2.

Control room is a restricted area and transient combustibles are controlled.

Technical Specifications require that three (3) licensed operators-be on shift in Modes 1 through 3, and two licensed operators in modes 4 & 5.

The type of fire that can be expected in the control room would be a slow smoldering fire because of the type and quantity of combustible materials present, and heat sources available. This type of incipient fire would be detected promptly by licensed personnel on duty and/or the installed ionization smoke detection system. Portable extinguishers could readily handle any control room incipient fire that could occur.

It should be noted also that many licensed operators are trained members of the plant fire brigade.

Because the control room is a locked / restricted area, the potential of introducing large quantities of transient combustibles is remote, and therefore, it is not creditable to postulate a rapidly developing, damaging, major fire.

The control room also has many other favorable features which contribute in preventing, detecting, and/or suppressing a fire.

In 1978 the NRC conducted site fire protection inspections to determine compliance with Branch Technical Position 9.5-1 Appendix A.

All fire protection recommendations generated for the control rooms by the NRC and their fire protection consultants have been implemented.

Another factor that must be considered in the defense of the control room is that no high or medium voltage power supplies exist in the control room.

The following active and passive fire protection features for the control room must be considered when as.essing the vulnerability of the control room.

1.

Uniqueness of Control Room - Continuously manned by licensed reactor operators.

2.

Hardened / secure area of the plant - Totally enclosed by reinforced concrete and restricted entry. A smoke barrier (metal and wire glass) was installed to separate HP-1 from MP-2 control room.

This was installed per NRC BTP 9.5.1 review.

Fire Ares No. T-21 Page 4 3.

No significant permanent combustibles.

4.

No high/ medium voltage power sources.

5.

Adequate fire protection for type and quantity of combustibles -

Portable extinguishers located throughout the room and hose stations available in areas outside control room.

Early warning detec' ion - Provided by Control Room licensed operators 6.

t and ionization detection.

7.

Proposed customized administrative controls to restrict flammable liquids in the control room (see attached insert on administrative controls).

The combined features listed above represent a defense-in-depth approach to fire protection by providing sufficient echelons / levels of active, passive, and administrative control features to assure the functionability of the Control Room.

With respect to Level II, a quantitative analysis was conducted to model the effects of an unmitigated transient combustible fire involving one gallon of heptane in the control room of Millstone I.

It is recognized that such a fire is an extremely unlikely event. Further, no attempt was made to postulate the scenario under which this situation may occur. Rather, the focus of this report is to demonstrate the expected survivability of critical control panel devices from the effects of an unmitigated fire and the inherent protection afforded by the existing configuration.

In modeling the postulated fire, conservative assumptions are made concerning the fires heat release rate and the heat transfer of energy to a CMC-type switch and the supporting panel. These assumptions are all oriented towards supporting a bounding calculation of the maximum surface temperatures for both the console and the model switch while limiting the flow of heat in a manner which exaggerates te overall severity of the fire scenario. A brief summary of assumptions used in this analysis includes the following considerations.

Laboratory values for the heat release rate of heptane are used. This o

assumption results in a more efficient and severe fire than has been measured in actual large-scale fires comparable to the type used in the analysis.

o Instantaneous achievement and continued maintenance of maximum fire heat release rates are postulated. This approach ensures the use of the most severe or bounding conditions in modeling the effects of the control room fire.

High values for radiation absorptivity are utilized coincidentially o

with low values for the emissivity for the subsequent reradiation.

This assumption results in the accumulation and retention of the incident radiant heat flux by the panel and switch.

Fire Arca No. T-21 Page 5 Unreasonably high air temperatures adjacent to the panel are maintained o

subsequent to fire self-extinguishment with cooling provided by natural convection.

Conduction of hea't is assumed to occur in only a single dimension up and o

away from.the panel's edge. Cooling resulting from lateral heat conduction in the panel is not considered.

The approach taken in modeling the postulated fire involves a rigorous analysis of the physics of the problem. Time dependent, finite difference solutions for the control panel surface temperature were obtained for a second-order partial differential equation with variable boundary conditions.

l The quantitative analysis conducted concluded that the postulated fire would not disable instrumentation and controls located on the main control board, thus ensuring safe shutdown capability and providing additional bases for the requested exemption.

In the Conclusion Section of the Final Report, it is noted that the analysis assumed that the ventilation slots on the lower front panels are closed off.

These louvered openings represent a difference between the actual control board configuration and the assumed analytical configuration. Since the analysis did not account for the louvered openings, it is NNECO's intention to provide a barrier that would afford equivalent or greater protection than the control panel itself.

This quantitative / analytical analysis represented a typical fire scenario for the main control board area and was not intended to account for the free-standing auxiliary cabinets which are also part of the main control room.

The unique design of the main control board does not permit switches, gages, and instrumentation to be directly exposed to heat generated at floor level (flammable liquids) and therefore the quantitative analysis proved that main control board instrumentation could serve the postulated fire. The auxiliary panels do not have this unique design feature and therefore little to no l

protection for instrumentation is provided. For this reason NNECO has proposed to provide ramps in front of these panels to assure that any flammable liquid spill would be directed away from the panel faces (see Attachment #2, Sketch 1).

NNECO concludes that the enclosed quantitative fire analysis for the main board and the proposed ramping for the balance of control room panels, that sufficient justification has been presented to demonstrate the survivability of control room required functions.

NNECO further concludes that from a fire consideration, sufficient assurance has been provided in the form of active / passive fire protection features to justify an equivalent level of protection for the control room.

Even though NNECO has provided reasonable justification and proposed modifications to assure control room survivability, the control room analysis has been carried one step further, Level (III).

This condition assumes that all of the control room active and passive fire protection features fail to function.

Fire Area Ns. T-21 Page 6 Proposed customized administrative control particularly fail.

o Proposed ramp to divert / drain a flammable liquid spill fails to o

function.

No~ operator (s) action to restrict / control the fire.

o Full credit is not taken for the quantitative fire analysis /

o model (EPM Study).

Flammable liquid spills occur and is ignited.

o Resulting fire is positioned in front of each critical panel in o

the control room. is a panel-by panel analysis of the significance of damage suffered as well as a statement regarding alternative action (s) which can be taken by the control room operator (s) to compensate for resultant damage.

The results of this Level III analysis reveals that MP-1 can successfully utilize operator action to compensate for damage to control room control panels.

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l Docket No. 50-245 1

Millstone Nuclear Power Station, Unit No. 1 Control Room Layout July, 1982

MILLSTONE I Control Room Panel (Main Control Board) 903 This panel contains the controls and Instrumentation for the Reactor Coolant squipnent (i.e., low pressure coolant injection pump control switches, core spray pump control switches).

Control Room Panel (Main Control Board) 904 This panel contains the controls and instrumentation for the Reactor Coolant squipnent (i.e., shutdown reactor cooling pump control switches, reactor water cleanup pump and valve control switches).

Control Room Panel (Main Control Board) 905 This panel contains the controls and instrumentation for the Reactor Control squipnent (i.e., control rod drive hydraulic pump control switches).

Control Room Panel (Main Control Board) 906 This panel contains the controls and instrumentation for the Feedwater Circulation and Service Water equipment (i.e., feedwater pump control switches, sarvice water pump control switches).

Control Room Panel (Main Control Board) 907 This panel contains the controls and instrumentation for the Turbine Generator cquipment (i.e., vacuum trip control switches).

Control Room Panel (Main Control Board) 908 1

l This panel contains the controls and instrumentation for the Reactor Coolant cquipnent (i.e., gas turbine generator and diesel generator control switches).

Control Room Panel 926 This panel contains the controls and instrumentation for the Feedwater Coolant injection equipment (i.e., feedwater coolant injection selector switch).

Control Room Panel. DC-IIA-1 l

This panel contains the circuit breakers for the 125VDC service.

Control Room Panel DC-IIA-2 This panel contains the circuit breakers for the 125VDC service.

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Docket No. 50-245 Millstone Nuclear Power Station, Unit No. 1 Analysis of Control Room Fire Damage July, 1982

l The following page detallr those control room devices required for safe shutdown that are assuned to be damaged by fire in a manner which could interfere with an orderly controlled safe shutdown. Each panel or control i

l board section reviewed is marked to indicate the locations of these devices.

Numbers in paren'th' sis indicate bill of noterial designation. These numbers 1

e c1so are used on the evaluation sheets. The following guidelines were used in performing this analysis.-

1.

The fire is assured to be an exposure fire occurring outside of the confines of the various boards and panels.

i 2.

Customized administrative controls' proposed in NNECO's March,1982 submittal and further delineated in this supplement, are depended l

upon to Ilmit the magnitude of the fire as well as to prevent exposure fires internal to boards and panels. No credit is taken, however, for the posted fire watch which can realistically be expected to sxtinguish the fire prior to total consumption of the available flammable liquid. The administrative controls allowed volune of flammable liquid is assumed to be one quart. However, for the circuit analysis the fire was assuned to progress to the point of complete destruction of components as defined by items 4 and 5.

3 The control room quantitative analysis results are credited for demonstrating that a fire external to a board or panel does no damage to wiring / devices mounted within that same board or panel.

4.

Components / equipment mounted on the surface of panels of board or which penetrate to any extent the protective skin of a panel or board are assured to be failed upon exposure to the postulated external fire in a '%crst case" nenner. As an example, a required-to-be-open contact is assumed closed and vice versa, an instrument falls to present a useful indication, etc.

5.

Fires are assumed not to be started via In-situ conditions such as faults or overloads, as:

(a)

Circuits are control or instrumentation type, not of sufficient energy level to start a fire due to a fault especially without a single failure of protective devices.

Single failures are not required to be taken for Appendix R assuned events; and, (b)

Long term overloads which could challenge the installed wiring capability are excluded due to the nature of powered devices. Relays, switches, Indicating IIghts, meters, etc., do not change their characteristics such as to support long term overloads without going to a faulted condition which will be removed via circuit protective devices.

---e

MILLSTONE I NOTES:

1.

The 480VAC'swlichgear circuit breakers can be tripped and closed manually from the. front of the switchgear compartments by operation of mechanical devices.

2.

The 4160VAC circuit breakers may be manaully tripped and closed from the front of the breaker compartment by operation of mechanically operated devices.

l As these breakers are equipped with stored energy type operators, with no control power available and the breaker in the tripped position, the breaker is capable of one manual closing operation af ter which it may be tripped manually but requires manaul recharge of the closing springs prior to a subsequent closing operation.

3 The analysis has assumed that the fire could cause a short circuit around the light bulbs of indicating lights due to the manner in which they are mounted on control boards. However, because these devices have resistors mounted behind them which are connected in series with the bulbs, it is our position that a fire external to the control board is not going to cause a short across the entire bulb / resistor assemblies. Therefore, fire related Indicating light failures will not cause short circuits which could affect circuit breaker operation.

4.

If a fire related failure caused the diesel generator to operate without service water, and the service water pumps could not be restarted from the main control board, the diesel engine coolant temperature would be monitored.

If service water pumps could not be manually started before the diesel reached its alarm set point of 190', the diesel would be shut down until a service water pump is available or until a fire pump can be lined up to provide cooling.

Since the diesel would have almost no load on it, sufficient time is available to secure service water.

Additionally, the Gas Turbine Generator would be available and require no service water cooling.

5.

The control room analysis assumes the occurrence of a coincident LNP.

However, in certain cases, an LNP would not be caused by the fire under consideration.

Such cases are conservative and any evaluation should consider that most plant loads would continue to function and would be available during the plant shutdown.

PANEL:

Control Room Panel 903 AFFECTED DEVICES:

Blowdown Control Switche's, 287-301A, -301B, -301C, -301D -301E, and -301F Main Steam ~lsolation Valve Control _ Switches inboard 595-300A, -300B, -300C, and -300D Outboard 595-301A, -3018. -301C, and -301D LPCl/ Containment Cooling System Pump A (1502A) 1530-301A Pump C (1502C) 1530-301C Pump B (15028) 1530-301B Pump D (1502D) 1530-301D Selector Sw (Man / Norm) 1530-316A Selector Sw (Man / Norm) 1530-316B Selector Sw (Man Override /Off) 1530-317A Selector Sw (Man Override /Off) 1530-317B Selector Sw (Kan Override / Auto) 1530-318A Selector Sw (Man Override / Auto) 1530-318B Logic Reset Switch 1530-319A Logic Reset Switch 1530-319B Service Water PP A (1501-65A) 1530-302A Service Water PP C (1501-65C) 1530-302C Service Water PP B (1501-65B) 1530-302B Service Water PP D (1501-65D) 1530-302D Core Spray System j

Pump A (1401 A) 1430-308A l

Pump B (1401B) 1430-308B SYMPTOM:

Failure of Blowdown Control Switches would prevent remote operation of the safety cnd relief valves but would not prevent autonatic operation by spring pressure et specific set points.

Fellure of Main Steam isolation Valve Control Switches would prevent remote operation of the inboard and/or outboard mainsteam isolation valves.

Failure of Low Pressure Coolant injection Control Switches (components A and C) would prevent the operation of LPCI Containnent Cooling System 1.

Follure of Low Pressure Coolant injection Control Switches (components B and D) would prevent the operation of LPCI Containnent Cooling System 11.

Control Room Penal 903 Pcga 2 of 2 SYMPTOM - (continued) j l

Failure of Core Spray Switches (components A) would prevent the operation of Core Spray Cooling System i.

Failure of Core Spray Switches (components B) would prevent the operation of Core Spray Coolin,g System II.

1 ALTERNATE:

The six electro-pneumatic relief valves have capacities on the order of 800,000 Lbs/Hr. for each valve. All are DC-powered, but require air for opening and remaining open. The accumulators (one per valve)are sized for three openings of the associated valve. However, even in the event of the highly unlikely dual loss of the isolation condenser and the air supply to the accumulators, the combination of valve opening due to steam pressure end the Feedwater Coolant injection System (FWCI, located on Panel 906) powered via the on-site gas turbine generator will be satisfactory to depressurizer the Reactor Coolant System.

The main steam isolation valves are utilized for containment Integrity which is not required in a non accident scenario. Continuous blowdown to the main condenser enhances cooldown while main turbine stop valves (located on Panel 923) are closed preventing any carry-over into the Turbine Building.

The LPCl/ Containment Cooling System pumps water f rom the suppression pool into the reactor vessel through one of the recirculation loops into the core region. The pumps are started automatically f rom an accident signal cnd isolation valves are opened when the reactor pressure decreases to epproximately 260 psig. The required system components on Panel 903 are contained in two redundant and independent trains.

NOTE:

Panel 903 is two separate panels such as 904 and 905 are physically separate, therefore, a loss of LPCI System I would not effect the LPCI System ll operation. Each system is designed to supply sufficient cooling water by itself.

The Core Spray System consists of two independent trains (Layout is similar to the LPCI trains), each drawing water from the torus and delivering it to the vessel through dedicated spray nozzles. Each I

train which is 100% of that required by the loss of coolant accident cnalysis.

MODIFICATIONS:

None required.

PANEL:

Control Room Panel 903 (cont inued)

AFFECTED DEVICES:

Item No.

Isolation Condenser Level Indicator L-1340-2 (711)

Isolation Condenser Level Recorder L-1340-4 (712)

Rzactor Level Indicators (Cold)

L-263-106 A & B (367,368)

SYMPTOM:

Loss of isolation Condenser Level in Panel 903 Loss of Reactor Level Indication (Cold) in Panel 903 ALTERNATE ACTION:

Isolation Condenser Level can be monitored locally (Reactor Building - fourth floor) as directed in Plant Operating Procedure OP-511.

Cold Reactor Level Indication can be monitored locally (Reactor Building instrument R:ck 2251 and 2252).

MODIFICATIONS:

None required.

I PANEL:

Control Room Panel 904 4

AFFECTED DEVICES:

R2 circulation Temperature Recorder TR-260-11, item No. (334) i i

SYMPTOM:

Loss of recirculation loops A and B Water Temperature Recorder.

ALTERNATE ACTION:

Rrcirculation loop temperatures can be monitored with the computer.

RTD resistances can be measured and converted to temperature.

MODIFICATIONS:

A procedure shall be developed to direct Plant personnel to measure RTD resistances and convert to temperature.

i i

PANEL: Control Room Panel 904 (cont inued)

AFFECTED DEVICES:

Shutdown Reactor. Cooling System Pump 1A (1002A) 1020-301A Pump IB (1002B) 1020-301B Pump Suction Valve (1-50-1) 595-315 Pump Discharge Valve (1-SD-5) 595-318A Raactor Water Cleanup System Auxiliary Pump Suction Valve (1-CU-2) 595-319 Bypass Valve (1-CU-2A) 684A Recirc Pump A (1205A) 680 Recirc Pump B (12058) 681 Auxiliary Pump (1206) 682 l

l SYMPTOV:

l Failure of Shutdown Cooling System Control Switches could prevent remote operation of the system suction and discharge valves.Although both MCC's (MCCF-3 and MCCE-3) can be supplied by emergency sources, this could result in loss of system since the valves are inside contal:tnent and are, therefore, inaccessible.

Failure l

of pump control switches upuid render the system inoperative.

l Lost of the Reactor Water Cleanup (RWCU) System suction and suction bypass valve control switches would inhibit water discharging from the reactor through RWCU to the main condenser or Radioactive Waste System.

I ALTERNATE ACTION:

l If the Shutcooling System becomes inoperative, Low Pressure Coolant injection System (LPCI), located on Panel 903, can be utilized to provide core cooling.

The LPCI Cooling System is a low-pressure system which supplies makeup and cooling water af ter reactor pressure is reduced.

In the absence of the Reactor Water Cleanup System which is an alternate method, the first method is the use of relief valves (Panel 903) to relieve pressure and decrease inventory.

MODIFICATIONS:

None required.

PANEL:

Control Room Panel 905 AFFECTED DEVICES:

R7 actor Protection System Reactor SCRAM P'8 590-301A Reactor SCRAM PB 590-301B SCRAM Reset Selector Switch 590-303 Reactor Run Selector Switch 590-300 Select Rod insert Switch 590-304 Feedwater Coolant injection System (FWCI)

Air interlock Reset Switch (A) 601-303A Air Interlock Reset Switch (B) 601-303B PWCl Reset (304) 601-133 Control Rod Drive Hydraulic System Drive Water Pump A (302-3A) 545 Drive Water Pump B (302-3B) 546 Water Pressure Regulator (302-8) 550 Discharge Pressure Regulator (302-10) 551 Flow Control Selector Switch 286-300 SYMPTOM:

Failure of the Reactor Protection System SCRAM pushbuttons would prevent scraming the control rods from the Main Control Board.

A loss of FWCl reset switches would inhibit the system operation.

Fc'iveo of the Control Rod Drive Hydraulic System control switches will prohibit the il,?ity to supply water for control rod drive operation and add makeup water to the reactor.

ALTERNATIVE Manually operating the SCRAM relays (from Panel 915) 590-108A, B, C, D, E, F, G,

,cnd H, and 590-109 A, B, C, and D will SCRAM the control rods to protect the rsactor and associated equipnent in the event certain conditions are exceeded.

FWCl System utilizes normal plant equipment to supply makeup to the core from the main condenser. This system may be substituted via Panel 903 with core spray providing ADS has lowered reactor pressure to a permissive level for core spray operation.

Loss the the Control Rod Drive System will not inhibit the SCRAM function as discussed above. Each control rod hydraulic accumulator is charged with compressed nitrogen which provides the energy for drive-in insertion during a SCRAM condition.

The LPCl/ containment cooling with associated automatic depressurization provides an citernate supply for reactor cooling water.

MODIFICATIONS None required. _

PANEL:

Control Room Panel 905 (continued) t AFFECTED DEVICES:

Rsactor Level Indicators (Hot) L-263-100 A and B, item fio. (328).

SYMPTOM:

Loss of Reactor Level Indicators in Panel 905.

ALTERNATE ACTION:

Rzactor level (hot) can be monitored:

1.

Panel 980 (ATi!S) Level Instruments Ll-266 A - D.

2.

Reactor building local instrument racks 2205 and 2206.

MODIFICATIONS:

None required.

{

PANEL:

Control Room Panel 905 (continued)

AFFECTED DEVICES:

Rsactor Vessel Pressure Recorder P-640-28, item No. (323)

R2 actor Vessel Pressure Indicator SYMPTOM:

Loss of Pressure Recorder and Indicator in Panel 905 ALTERNATE ACTION:

Raactor Pressure can be monitored:

1.

Panel 980 (ATUS) Pressure Instruments PI-265 A - D.

2.

Reactor building local instrument racks 2205 and 2206.

MODIPICATIONS:

None required.

T'ANEL:

Control Room Panel 906 AFFECTED DEVICES:

Fsedwater System -

Reactor Feed Pump A (H2-10A) 368 -V7f Reactor Feed Pump B (M2-10B) 369-471 RFP Lube Oil Pump A 371 - Y/S' RFP Lube Oil Pump B 372-4/4 RFP Seal Water injection (M2-17A) 374 - Y/J RFP Seal Water injection (H2-178) 375-t/Y RFP Seal Water Return (M2-18A) 378 -y/7 RFP Seal Water Return (M2-188) 379-y/t Condensate Pump A (M2-6A) 356 yyt Condensate Pump B (M2-6B) 357-973 Condensate Booster Pump A (H2-7A) 362-YWo Condensate Booster Pump B (H2-78) 363-Y77 Emergency Condensate Transfer Pump (M7-28) 335-JF4 Cooling Water Systems Service Water Pump A (M4-7A) 151-/43 Service Water Pump B (M4-78) 152 -f4 4 Service Water Pump C (M4-7C) 153 -t'dl Service Water Pump D (M4-7D) 154

'40 Reactor Building Cooling Water Pump A (M4-10A) 148 - Vf f Reactor Building Cooling Water Pump B (M4-10B) 149 - f14~

SYMPTOM:

Follure of the Feedwater System Control Switches would render the normal Racctor Feedwater and FWCl Systems inoperative.

i Th2 loss of either RBCCW or CW Systems (Cooling Water Systems) results in loss of Shutdown Cooling System capabilities and possibly subsequent reheating of tha reactor coolant.

ALTERNATIVE:

The Feedwater and FWCl Systems use nornal plant equipment, (i.e., Reactor Feed Pumps, Condensate Booster Pumps, and Condensate Pumps) pumping from the main condenser hotwell through the Condensate /Feedwater System to the reactor vessel.

LPCI or core spray, located on Panel 903 can adequately mitigate the consequences from the loss of the feedwater trains.

With the loss of the Cooling Water Systems, utilization of the isolation condenser via Panel 903 can provide the necessary cooling to the core.

MODIFICATIONS:

None required.

PANEL:

Control Room Panel 906 (continued) 4 AFFECTED DEVICES:

Crndensate Storage Ta7k Level Indicator L-7-50, item No. (336)

SYMPTOM:

Loss of Level Indication ALTERNATE ACTION:

Level will be monitored at Local Indicator.

MODIFICATIONS:

A local mechanical indicator will be installed by LT-7-50 transmitter located in the condensate blockhouse.

PANEL:

Control Room Panel 907 AFFECTED DEVICES:

Turbine Vacuum Trip #1 71 Vacuum Trip #2 72 SYMPTOM:

Failure of the Turbine Vacuum Trip Control Switches would prevent remote operation of tripping the main trubine due to loss of condenser vacuum.

ALTERNATE ACTION:

The main turbine is capable of being tripped at the turbine front standard.

I l

MODIFICATIONS:

None Required.

t

= _.

PANEL:

Control Room Panel 908 AFFECTED DEVICES:

Gtnerator Control Switches Gas Turbine Generator 1070D Diesel Generator 132D SYMPTOM:

Loss of the Generator Control Switches would prevent remote actuation of the gas turbine and diesel generator automatic starting sequencing.

ALTERNATE ACTION:

The two on-site emergency power supplies, diesel generator and gas turbine gsnerator, provides the required electrical power used for safe shutdown.

These power sources can be started and controlled locally.

MODIFICATIONS:

None required.

PANEL:

Control Room Panel 908 (continued) 4160 & 480V Emergency Power AFFECTED DEVICES:

Control switches for Circuit Breakers which must operate for safe shutdown are:

B:nch Section Bus 3 - Bus 7 tie breaker CS-908-111 Bus 1 - Bus 7 tie breaker CS-908-110 Synch breaker CS-908-271 480V Swgr #2 CS-908-300 Synch breaker CS-908-131 Bus 6 - Transf. 2A feeder breaker CS-908-283 480V Swgr #2A CS-908-311 Vartical Section MCC-2-3 CS-908-304 MCC-2-5 LS-908-306 MCC-2A-4 CS-908-315 NCC-2A-5 CS-908-316 SYMPTOM:

A failure of the control switch could cause a breaker to be permanently tripped, therefore, losing power supply to emergency buses.

ALTERNATIVE ACTION:

Tha breakers can be manually reclosed at the switchgear cubicles with mechanical devices. The trip coils can be deenergized by pulling the fuses.

Sse Notes 1, 2, 3, 4, and 5.

MODIFICATIONS:

N:ne required.

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PANEL:

Control Room Panel 926 AFFECTED DEVICES:

Feedwater Coolant injection (FWCl) System I

(

FWCR Train Selector Switch 325

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Failure of the FWCl Train Selector Switch would Inhibit the selection of a desired feedwater train.

ALTERNATE ACTION:

The Selector Switch determines which Reactor Feed Pump, Condensate' Pump, and Condensate Booster Pump will be utilized. The Control Switch selects the "A" or "B" pump string for the FWCl mode, if "A" string is selected, the "B" string does not provide a backup; therefore, "B" string may be operated local / remote from Panel 906.

MODIFICATIONS:

None required.

l

PANEL:

Control Room Panel DC-11A-2 Electrical Aux. Panel AFFECTED DEVICES:-

Distribution Panel DC-11A2, CKT ?_1, power to ADS Valves SYMPTOM:

Fire to panel, could cause loss of operability of the ADS valves.

ALTERNATE ACTION:

Provide alternate shutdown capability with Feedwater Coolant injection (FWCI)

MODIFICATIONS:

N:na required, t

cak-43 Millstone 1 Safe Shutdown Fire Zone Analysis El. 25'6" Turbine Building Cable Vault Fire Area No. T-16 Safe Shutdown Equipment o

S-1 and S-2 power train control cables associated with hot and cold shutdown equipment (FWCI, LPCI, Isolation Condenser, ADS Valves).

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Design Features o

Walls 1.

South - reinforced concrete with sections of solid concrete block in excess of 5 feet thick.

2.

North - reinforced concrete and solid concrete block in excess of 27 inches thick.

3.

West - reinforced concrete and solid concrete block in excess of 18 inches thick.

4.

East - reinforced concrete with sections of solid concrete block in excess of 18 inches thick with an interface with the stairwell (6 inch thick concrete block).

Fira Ares Ns. T-16 Pege 2 Floor consists of reinforced concrete 12 inches thick.

o Ceiling consists,of reinforced concrete 18 inches thick.

o Penetrations in floor and ceiling are sealed.

o Doors'a'e'.1-1/2 hour fire rated.

o r

Cabie trays are. totally enclosed.

o Fire dampers are installed in ventilation ducts.

o o

Ceiling Heights - 11' Room Volume - 58,000 ft.3 o

Ventilation - Supply Air 5650 CFM - Exhaust Air 5650 CFM o

Combustible Material quantity Cables Not inventoried Existing Fire Protection Early warning ionization detection.

o 1" marinite boards on top of trays in cable vault.

o An independent smoke and heat removal system.

o o

Hose stations at both entrances.

A fire equipment cabinet with fire fighting equipment exclusively o

for cable tray fires located immediately outside area (T-17).

o Portable extinguishers at both entrances.

Compliance With Appendix R Does not comply with Sectio'n III.G.2.c of Appendix R.

Exemption requested from the requirement for a one-hour rated barrier for one train of safe shutdown related cabling (see proposed modifica-tions and discussion).

Proposed Modifications Install an automatic fire suppression system.

o

Fir 2 Arts No. T-16 Pega 3 Customized administrative controls will be implemented to restrict the o

introduction of flammable liquids in the cable vault.

t Discussion I

(

It should b'e noted that the color-coded drawing of the cable vault may lead the. reviewer to believe redundant cables (green and red) may run in the same trays. As noted on the drawing, these cables run in different trays with a minimum vertical seperation of approximately one foot.

f Figure T-16.1 provides further clarification.

The sketch also shows the placement of the 1" thick marinite boards in the room which provide a one-hour fire barrier.

l l

l The extent of the exemption is that the cable trays that contain all S-1 and S-2 cables are not totally enclosed with a one-hour fire barrier.

The tops are protected with marinite. The sides of the trays are not protected.

With the proposed installation of an automatic fire suppression system and the implementation of administrative controls, post-fire shutdown capability is assured.

Following the Browns Ferry fire of 1975, Millstone Unit #1 conducted an evaluation of the cable vault area and incorporated the following active and passive fire protection features:

(a) A new early warning ionization smoke detection system.

(b) An independent smoke removal system.

(c) A second entrance through which a fire hose station can be used.

(d) Additional fire rated dampers were installed to provide better isolation.

(e) A fire equipment cabinet with cable vault fire fighting tools and equipment has been provided.

Note that the fire protection for this area concentrated on upgrading manual fire fighting capability.

The reason for this emphasis was that the Millstone 1 cable vault design features lends itself to manual fire fighting. The cable vault is relatively free of obstructions and fire fighting mobility is not restricted (see attached photo). The cable tray system is totally enclosed in steel trays. A fire in any tray would be slow in developing (lack of oxygen) and the enclosed tray design would assist in containing the fire. An early warning ioniza-tion detection system would alarm in the early stages of a fire and the plant fire brigade would respond.

A smoke removal system was installed exclusively to support manual fire suppression for this fire zone.

The proposed modification to implement customized controls to restrict /

control the introduction of flammable liquids will add another level of

y Fira Area No. T-16 Page 4 protection to supplement other defense-in-depth fire protection features in this area.

To add another echelon / dimension of fire protection for the cable vault, NNECO proposes to install an automatic suppression system.

'NNECO concludes that the summation of existing fire protection features and proposed fire protection modifications including the concept of customized administrative controls, add sufficient defense-in-depth to warrant an exemption from the requirement of Section III.G.2.c of Appendix R.

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cok-43 Millstone 1 Safe Shutdown Fire Zone Analysis El. 14'6" Reactor Building Fire Area No. R-2A Northwest Corner 1

l Safe Shutdown Equipment (Required for hot and cold shutdown)

CRD liydraulic Units MCC 2-3 (S-1)

Cables o ADS power and controls (S-2) o Instrumentation cabling for Racks 2205 and 2206 o Isolation condenser level instrumentation o Emergency condensate transfer pump (power) (S-1) o Isolation Condenser valve IC-3 (S-2) o Power and controls to Emergency Condensate Transfer Pump Discharge Valve (V7-143) (S-1)

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The area is bounded on the north and west by the reinforced concrete walls of the reactor building.

o There is a personnel airlock in the northwest corner.

o Sections of the north wall are solid concrete block in excess of 2 feet thick.

Fir 2 Aram No. R-2A PIga 2 o

On the south is the primary containment shield wall and the wall of the traversing incore probe room, forming an effective barrier with a labyiinth entrance.

The ceiling and floor are reinforced concrete, and there are open o

stairways leading to area R-19 on the floor above and area R-6 below.

The'following equipment is protected where necessary from damage o

resulting from the initiation of the fire suppression system:

a.

Motor control center 2-3 (R-2AA) b.

Motor control center 2-3NE (R-2AA) c.

Scram solenoid fuse panels d.

SRM/IRM drive control cabinet e.

CRD accumulator monitor rack f.

SRM/IRM preamplifier rack o

Ceiling Height - 28' Room Volume -105,000 ft.3 o

o Ventilation - Supply Air 1200 CFM - Exhaust Air 1600 CFM Quangity Fire Logd Combustible Material (ft )

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Cables 265 36,900 Existing Fire Protection o

Two hose stations (Nos. 113 and 116) and one 10-pound type B/C dry powder extinguisher (No. 152) are located in this zone.

o In each of the adjacent zones R-2B and R-19 there is a hose station and a 10 pound type B/C dry powder extinguisher that could be employed in fire zone R-2A.

o Early warning ionization detection.

o A wet pipe sprinkler system designed for cable tray protection exists.

o MCC-2-3 is located in an Environmental Enclosure (Fire Sub-Area R-2AA). This enclosure was designed and installed as part of NNECO's response to the environmental qualification issue to ensure that a mild environment would be maintained for this device during accident conditions.

Fira Arso No. R-2A Page 3 Compliance With Appendix R Does not comply with Section III.G.2.b of Appendix R.

l Exemption requested (see discussion) from the requirement for no intervening combustibles.

Proposed Modifications 1)

Enclose DC control power feed from HCC-DC-11A1 to MCC-2-3 with a 1-hour fire barrier.

2)

Install fire stops in intervening cable trays.

Discussion It should be noted that one cable run in this zone was not identified in l

Ref. (1) as being required for a safe-shutdown option. This cable supplies DC control power for a valve associated with the FWCI safe-shutdown option. Figure R-2A.1 provides further clarification of this control power feed throughout the 14'6" elevation of the reactor building.

The extent of the exemption is the presence of intervening combustibles between cables associated with safe shutdown options. Specifically between power and control cables for the emergency condensate transfer

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pump and valve and cables associated with the Isolation Condenser and

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ADS systems (see Figure R-2A).

i With the proposed alternatives of (1) the installation of fire stops in intervening cables trays and (2) the enclosure of the DC control power feed from MCC-DC-11A-1 to MCC-2-3 with a 1-hour barrier, post-fire shutdown capability is assured.

(See generic position as stated in Appendix B of this submittal.)

Fire Zone R-2A is located in the northwest corner of the 14'6" elevation of the reactor building. An early warning ionization detection system and an automatic suppression system is already installed in this area.

As mentioned, the extent of the exemption is the presence of intervening combustibles (open cable trays) between redundant shutdown cables. The redundant cables are separated by a minimum horizontal distance of approximately 25 feet and located about 16 feet off of the floor (see Figure R-2A2). With the installation of fire stops, a fire will not be able to propagate along the trays destroying the redundant cables. MCC-2-3 is protected by an Environmental Enclosure, also the MCC is located cpproximately 25' (horizontal) from redundant shutdown cables. With the installation of the proposed alternatives, the intent of Section III.G.2.b of Appendix R is more than met and the exemption is warranted.

Reference Drawings 34026, 34027, 34028, 34029

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cak-43 Millstone 1 Safe Shutdown Fire Zone Analysis El. 14'6" Reactor Building Northeast Corner Fire Area No. R-2B Safe Shutdown Equipment (Required for hot and cold shutdown)

MCC-DC-11A-1 Cables o LPCI Pumps B and D (S-1 Train) o Instrumentation cabling for Racks 2205 and 2206 o Isolation condenser level instrumentation o RBCCW pump A o Power and control to ADS valves o I-IC-3 valve control o Control power from MCC-DC-11A-1 to MCC-2-3 for Valve luimused If U

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The zone is bounded on the north by the reinforced concrete outer wall of the reactor building and on the east by the reactor building outer wall and the railroad airlock steel door.

o On the south and west, the zone is bounded by the dryvell and is open to zones R-2C and R-2A.

Fira Area No. R-2B Page 2 The floor and ceiling are constructed of reinforced concrete, and o

there is an open equipment hatch, measuring approximately 20 x 20 feet, leading to,the upper floors of the building.

In the northeast corner is an open stairway leading down to area o

R-9.

Measures h~ ave been taken to protect the core spray and containment o

spray pumps in area R-9 from water damage.

Motor control center DC-IIA-1 is protected, where necessary, from o

damage resulting from the initiation of the fire suppression system.

All cable penetrations in the ceiling are provided with appr9priate o

fire stops.

o Ceiling Height - 28' Room Volume - 76,500 ft.3 o

o Ventilation - Supply Air 1000 CFM - Exhaust Air 1600 CFM Quangity Fire Logd Combustible Material (ft )

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Cables 229 40,000 Existing Fire Protection o

One hose station (No. 114) and one 10-lb type B/C dry powder extin-guisher (No. 151) are located in this zone.

o Available equipment in adjacent zones is as follows:

Zone R-2A:

Two hose stations and one 10-lb type B/C dry powder extinguisher.

Zone R-2C:

One hose station and one 10-lb type B/C dry powder extinguisher.

o Early warning ionization detection.

A wet pipe sprinkler system designed for cable tray protection.

o o

MCC-DC-11A-1 is located in an Environmental Enclosure (Fire Sub-Area R-2BB). This enclousre was designed and installed as part of NNECO's response to the environmental qualification issue to ensure that a mild environment would be maintained for this device during accident conditions.

Fire Aras Ns. R-2B Page 3 Compliance With Appendix R Compliance with Section III.G.2.c of Appendix R will be achieved with implementation of preposed modifications.

Proposed Modifications 1)

Enclose DC control power feed from MCC-DC-11A-1 to MCC-2-3 and DC feed from DC-IA to MCC-DC-11A-1 with a 1-hr. fire barrier.

Discussion It should be noted that one cable run in this zone was not identified in Ref. (1) as being required for a safe-shutdown option. The cable supplies DC control power for a valve associated with the FWCI safe-shutdown option. Figure R-2B.1 provides further clarification of this control power feed throughout the 14'6" elevation of the reactor building.

Fire Zone R-2B is located in the northeast corner of the 14'6" elevation of the reactor building. An early warning ionization detection system and an automatic suppression system is already installed in this area.

With the installation of the 1-hour fire barrier around the two DC cables; compliance with Section III.G.2.c of Appendix R will be achieved.

Reference Drawings 34026, 34027, 34028, 34029.

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Safe Shutdown Fire Zone Analysis l

El. 14'6" Reactor Building Southeast Corner Fire Area No. R-2C Safe Shutdown Equipment (Required for hot and cold shutdown)

Cables o CRD Pumps A (S-1 Train) o CRD Pumps B (S-2 Train) o ADS valves (power and control) o I-IC-3 valve control o LPCI's B and D (S-1 Train) o RBCCW A (S-1 Train) o Instrumentation Rack 2205 o Control power for Valve V7-143 (51)

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Design Features The zone is bounded on the south and east by the reinforced concrete o

walls of the reactor building and to the northwest by the primary containment shield wall.

To the north and west the zone is open to adjacent zones R-2B and o

R-2D.

Fira Ara No. R-2C Pag 2 2

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The ceiling and floor are reinforced concrete, with an open stairway j

in the southeast corner leading to other lower and upper elevations.

l Measures have been taken to protect the CRD pumps in area R-8 from o

water damage.

The SRM/IRM preamplifier rack is protected, where necessary, from o

damage res'ulting from the initiation of the fire suppression system.

All cable penetrations in the ceiling are provided with appropriate o

fire stops.

o Ceiling Height - 28' Room Volume - 76,500 ft.3 o

l Ventilation - No supply or exhaust air registers in this area.

o Quangity Fire Logd Combustible Material (ft )

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Cables 149 26,000 Clothing 20 3,000 l

f Miscellaneous plastic and rubber 20 4,300 L

Existing Fire Protection This zone is provided with one hose station (No. 115) and one 10-lb o

type B/C dry powder extinguisher (No. 174).

A hose station and a 10-lb type B/C dry powder extinguisher are o

located in each of the adjacent zones (R-2B and R-2D).

o Early warning ionization detection exists.

A wet pipe sprinkler system designed for cable tray protection has o

been provided.

Compliance With Appendix R Compliance with Section III.G.2.c of Appendix R will be achieved with implementation of proposed modifications.

Proposed Modifications Enclose DC power feed from DC-1A to MCC-DC-11A-1 with a 1-hr. fire barrier.

I i

Fire Arca No. R-2C Pegs 3 Discussion It should be noted that one cable run in this zone was not identified in Ref. (1) as being required for a safe-shutdown option. The cable supplies DC control power for a valve associated with the FWCI safe-shutdown cption.

Figure R-2C.1 provides further clarification of this control power feed throughout the 14'6" elevation of the reactor building.

Fire Zone R-2C is located in the southeast corner of the 14'6" elevation of the reactor building. An early warning ionization detection system and an automatic suppression system is already installed in this area.

With the installation of the 1-hour fire barrier around the two DC cables; compliance with Section III.G.2.c of Appendix R will be achieved.

Reference Drawings 34027, 34029.

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cak-43 Millstone 1 Safe Shutdown Fire Zone Analysis El. 14'6" Reactor Building Southwest Corner Fire Zone No. R-2D Safe Shutdown Equipment (Required for hot and cold shutdown)

CRD hydraulic units Cables o LPCl Pump A & C (S-2 train) (power cables) o Power and control to ADS valves o LPCI pumps B and D (S-1 Train) (power cables) o RBCCW pump A (power cables) o CRD pump A (power cables) o Shutdown pump A (power cables) o Shutdown pump B (power cables) o DC power from DC-1A to MCC-DC-11A-1 enummiinni h5 k."' Il

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,r Ala Design Features This zone is bounded on the west and south by the reinforced concrete o

walls of the reactor building and on the north by the wall of the shutdown cooling pump room and the drywell shield wall, The shutdown cooling pump room wall has an open doorway, with a o

masonry curtain wall, leading into the room.

Fire Arca No. R-2D Pega 2 o

Both walls are reinforced concrete.

o On the east, this zone is open to zone R-2C.

o The floor and ceiling are reinforced concrete, and there is an open stairway leading to area R-7.

All. cable penetrations in walls and ceiling are provided with o

appropriate fire stops.

o Ceiling Height - 28' Room Volume -105,000 ft.3 o

o Ventilation - Air Supply 1400 CFM - exhaust air, no exhaust registers in this zone.

Quangity Fire Logd Combustible Material (ft )

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Cables 91.4 21,400 Existing Fire Protection o

One hose station (No. 117) and one 10-lb type B/C dry powder extinguisher (No. 149) are located in this zone.

Two hose stations and five portable extinguishers in zones R-2B and o

R-2C are available for use in this zone.

o Early warning ionization detection exists.

Compliance With Appendix R Does not comply with Section III.G.2.(b & c) of Appendix R.

An exemption is requested from the requirement for automatic suppression and no intervening combustibles.

(see proposed modifications and discussion)

Proposed Modifications 1.

Enclose DC power feed from DC-1A to MCC-DC-11A-1 with a 1-hr. fire barrier to a point twenty feet past the cable tray containing the cable for the ADS valves.

2.

Install fire stops in intervening cable trays.

Discussion It should be noted that one cable run in this zone was not identified in Ref. (1) as being required for a safe-shutdown option. The cable supplies

Fira Area No. R-2D Pag? 3 DC control power for a valve associated with the FWCI safe-shutdown cption. Figure R-2D.1 provides further clarification of this control power feed throughout the 14'6" elevation of the reactor building.

With the proposed alternative of installing a 1-hr. fire barrier around the DC feed from DC-1A to MCC-DC-11A-1 and the installation of cable tray fire stops, post-fire shutdown capability is assured.

Fire Zone R-2D.1 is located in the southwest corner of the 14'6" elevation of the reactor building. An early warning ionization detection system is already installed in this area.

NNECO's position is that an automatic suppression system is not necessary for this area due to its low combustible loading relative to the high degree of fire protection afforded by the proposed one-hour fire rated cable enclosure and the installation of fire stops in cable trays.

(see generic position as stated in Appendix B of this submittal and Figure R-2D.2)

NNECO has concluded that the protection afforded by the combination of the one hour fire rated enclosure cable tray fire stops, the inherent spatial separation, the existing ionization detection system and the subsequent fire brigade response using in-situ manual fire suppression equipment more than compensate for the requirements for total compliance with the regulation.

Reference Drawings 34029, 34028, 34027, 34026.

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cok-43 Millstone 1 l

Safe Shutdown Fire Zone Analysis f

l l

El. 14'6" Turbine Building I

Turbine Service Equipment Area Fire Area No. T-5C Safe Shutdown Equipment Motor control center 2-4 and 2A-4 (H&C)

Cables o Gas turbine generator train associat:.d power and control cabling (S-1)(H&C) o Emergency service water pump B and D (S-1 Train)(C) o Emergency service water pump A and C (S-2 Train)(C) o Service water pump C (S-1 Train) and D (S-2 Train)(C) o MCC 2-4 (S-1)(H&C) o MCC 2A-4 (S-2)(H&C) o DC control power feeds (S-1)(H&C) o Diesel generator power and control cables (S-2)(H&C) o Power feed for diesel fuel oil transfer pump A (S-2)(H & C) o Power feed for diesel fuel oil transfer pump B (S-2)(H & C)

Note: H - hot shutdown equipment C - cold shutdown equipment

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Fire Ara No. T-5C Peg 2 2 Design Features I

)

On the east the. zone is bounded by a 1-foot-thick reinforced-con-o l

crete-block wall.

On the north the partial wall is 3-ft reinforced concrete, with a o

doorway aild a concrete-block plugged access hatch fitted with a 48 inch exhaust fan.

The south wall, separating this zone from the diesel generator l

o room, is a 1-ft-thick reinforced-concrete-block wall with a 3-hour rated fire door. The remainder of the wall is 8-inch reinforced concrete block. The personnel door leading into the machine shop is a 1-1/2 hour rated steel door, and the overhead door is of heavy l

steel construction.

o The wall between this area and the decontamination room is 8 inch concrete block, with double doors.

On the west, the wall is 8-inch reinforced concrete block, with o

steel doors.

The ceiling is a 6-inch reinforced concrete slab on steel Z-decking o

supported by I-beams. At the northwest corner a section (approximately 40 x 50 feet) of the ceiling is lowered by 3 ft 6 in., providing a gap of approximately 3 feet between it and the remaining floor.

o The floor is the ground-floor concrete slab.

All cable penetrations in walls and ceiling have appropriate fire o

stops.

The hydrogen seal oil unit has been curbed / diked to contain an o

oil spill or break.

A fire stop to cable system was installed to prevent flame spread o

to zone T-5B.

o Ceiling Height - 20' o

Room Volume - 170,000 ft.3 Ventilation - Supply Air 8500 CFM - Exhaust Air 33,000 CFM o

Fire Logd Combustible Material Quantity (Btu /ft )

3 Cables 523.3 ft 29,900 Lubricating oil 1,864ga}*

32,400 Locker contents 100 ft 4,900 Air compressor lubricating oil 14 gag 200 Health physics gear 50 ft 2,500

• Maximum credible spill.

Fira Arco No. T-5C i

l Paga 3 Existing Fire Protection

)

o This zone is provided with two 10-lb type B/C dry powder extinguishers (Nos. 143 and 145) and three hose stations (Nos. 112, 104 and 105).

o Additional hose stations and dry powder extinguishers are available in adjacent areas T-5B, T-9, and T-19E.

o The hydrogen seal oil unit is protected by an automatic water deluge system initiated by a local heat rate-of-rise sensor.

One portable fire extinguisher is installed in the general vicinity o

of the decontamination room access door.

o Early warning ionization detection.

Compliance With Appendix R Does not comply with Section III.G.2 (c) of Appendix R.

An exemption is requested from the requirement for automatic suppression and no intervening combustibles.

Proposed Modification 1

1.

Enclose AC power feed from 480V #2A to MCC-22A-1 with a one-hour fire barrier throughout the zone (cable supplies power for diesel

(

fuel oil transfer pump A).

2.

Install fire stops in intervening cable trays.

Discussion It should be noted that two cable runs through this zone were not identified in Ref. (1) as being required for safe shutdown. The cables supply power to diesel fuel oil transfer pumps (pumps A and B), either of which can pump fuel to the diesel fuel tank.

It should be noted that these pumps need not operate until eight hours after the diesel generator is started.

It should be noted that all the other safe shutdown equipment and cables located in this zone have redundant components in other areas.

With the proposal of installing a one-hour fire barrier around the feed for pump A, and the installation of cable tray fire stops, post fire shutdown capability is assured.

Fire zone T-5C is located in the south end of the 14'-6" elevation of the turbine building. An early warning ionization detection system is already installed in the area.

NNECO's position is that an automatic suppression system is not necessary for this area due to its low combustible loading relative to the high degree of fire protection afforded by the proposed one-hour fire rated cable enclosure and the installation of fire stops in cable trays.

Fira Area No. T-5C Pega 4 NNECO has concluded that the protection afforded by the combination of the one-hour fire rated enclosure, cable tray fire stops, the inherent spatial separation, the existing ionizat. ion detection system and the subsequent fire brigade response using in-situ manual fire suppression equipment more than compensate for the requirements for total compliance with the regulation.

Reference Drawings 34004, 34008, 34009

cak-43 Millstone 1 Safe Shutdown Fire Zone Analysis El. 34'6" Turbine Building Switchgear Area Fire Area No. T-19A Safe Shutdown Equipment (All hot shutdown equip. except as noted) 4160-V Switchgear 5 (Train S-1) 480-V Switchgear 2 (Train S-1)

Vital AC motor generator set VAC MG-1 Cables o Associated with diesel generator, 4kV Bus #6 and 480V load center #2A (All S-2) o Associated with service water 1r C'

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Design Features The zone is bounded as follows:

1.

On the north is a 6-inch concrete-block wall, except for the wall to the telephone room, which is constructed of 8-inch concrete block.

2.

The wall between this zone and the office area (zone T-19G) is 4-inch concrete block.

Fira Area No. T-19A Paga 2 3.

A 3-foot-thick reinforced concrete wall separates this zone from area T-1.

I 4.

This zone is open to zone T-19B, except for 8-inch concrete-block fire-barrier wing walls extending beyond each switchgear.

5.

This zone is open to zone T-19F by a passageway and a ventilation duct located over the north access door.

In this area the wall between zones T-19A and T-19F is partial and does not extend to the ceiling.

6.

The floor and ceiling are reinforced concrete, with numerous hatches plugged with concrete plugs or steel plates. The hatchway in the floor leading to the lubricating-oil room is plugged with a fireproof hatch cover.

7.

Cable and pipe penetrations through floor, walls, and ceilings have been provided with appropriate fire stops.

8.

Raceway system fire stops have been installed to prevent the spread of fire to or from zone T-19B.

l 9.

Ceiling Height - 20' 3

10. Room Volume - 150,000 ft

11. Ventilation - Supply Air 10,500 CFM - Exhaust Air 13,166 CFM Quangity Fire Logd Combustible Material (ft )

(Btu /ft )

Cables 482.0 32,300 Existing Fire Protection o

One 10-lb carbon dioxide extinguisher.

o One 30-lb B/C dry powder extinguisher.

o Three hose stations.

o Early warning ionization detection.

Hose stations and additional portable extinguishers are available o

in adjacent fire zones.

Fire Aras No. T-19A Page 3 Compliance With Appendix R Does not comply with.Section III.G.2 of Appendix R.

Exemption requested (see proposed modifications and discussion).

Proposed. Modifications 1.

Enclose train S-2 cable tray with I hour rated fire barrier from fire zone T-19B to a point twenty feet past the 4kV #5 switchgear (S-1).

2.

Install additional fire stops in intervening cable trays.

3.

A water curtain spray system will be installed to provide separation between redundant 4kV and 480V switchgear.

(T-19A from T-19B) 4.

A curb / dike will be installed to assure that a flammable liquid spill would not effect redundant 4kV and 480V switchgear.

Discussion The extent of the exemption is 3-fold.

(1) The acceptance of a curb / dike and water curtain spray system as an alternative to a three-hour fire barrier.

(2) The presence of intervening combustibles between cables associated with safe-shutdown options.

(3) The absense of an automatic suppression system in areas where redundant safe-shutdown equipment will be separated by 20 feet or a 1-hr. fire barrier. The precise nature of the exemption varies as a function of location within this fire zone.

Details are provided in the following paragraphs.

With the installations of the proposed modifications, as well as credit for the extensive manual suppression equipment in the zone, it is NNECO's position that post-fire shutdown capability is assured.

Fire zone T-19A is of an L-shaped configuration located in the northeast corner of the 34'6" elevation of the turbine building. Refer to Figure 1 for discussion of this zone. The assumption that a fire would engulf l

the whole zone is not credible due to the large area of the zone. The zone extends nearly 160 feet, both in the westerly and southerly directions from the northeast corner. The Design Features section of this Safe Shutdown Fire Zone Analysis provides some insight into the existing characteristics of this zone. Particular attention should be paid to items 4, 6, 9, and 10.

Concerning Item 4, the reason a block wall is not extended all the way across the walkway is to allow transfer of the large transformers through the zone for maintenance during refueling outages. Equipment and cables that are located in the zone which provide safe shutdown capability are 4160 and 480 VAC S1 switchgear and the control cables for the 4160 and 480 VAC S2 switchgear.

The S1 switchgear is located at the extreme south end of the zone. The S2 control cables run the entire east-side length of the room in one cable tray.

In the

l Firo Area Ns. T-19A Page 4 northeast corner the tray penetrates the floor into Fire Zone T-17 (Mezzanine) before entering the cable vault. The cable tray is run at'a l

height of 11 feet above the floor. The central area within the zone is where the S2 cable tray passes above the walkway between the S1 4.16KV cnd 480V switchgear.

\\

As previously discussed; it is not credible to assume that a single fire would destroy the whole of fire zone T-19A. For this reason, NNECO treated the review of this zone as though it was divided into three s.311er areas hereafter described as the south end, west edd and northeast co t at7.

Applying the 20 foot seperation criterion to determine the commen buendaries of these areas, a fire was postulated in the areas, cne at a time, to determine wich shutdown cipsbility would be lost and to identify alternative capability. With the incorporation of the above identified modifications, destruction of each ' area would be acco.nodated es follows:

g i

Table 1 i

Area Destroyed Shutdown Train Remaining Intact South End S2 (cables'through'soath end are protected by one hour fire enclosute) N West End S1 and S2 op,tions both available Northeast Corner S1 option remains intact It should be noted that the cables for redunthnt' shutdown cooling pumps are also located in this area. The pumps provide cold shutdown capability f

with the use of the isolation condenser.

Repa*r' procedures are not required for these cables because the Emergency Service Water system provides alternate cold shutdown capability and are located in other areas.

The following discussion details NNECO's proposed modifications. 'Modifi-cation #1 provides for the eTclosure of the S2 cable tray with a 1-hr.

fire barrier from the border of Fire Zone T-19B to a point 20 feet past the north corner of the SI switchgear. This provides fire protection for a fire in the South End area.

Proposed modification #2 provides for-I the installation of additional fire stops in intervening cable trays in,

e manner so as to prevent propagation of a fire from the South End to the Northeast Corner. This modification directly addresses the intervening combustibles portion of the exemption and it is NNECO's conclusion that the concern for fire spread along raceway paths is fully addressed by this treatment.

Proposed modification #3 will incorporate a water curtain between the S-1 and S-2 redundant switchgear units.

The water curtain would be a wet pipe system and would provide directional spray over the wing walls and curbed area as shown on supplemental sketch. This would selectively >

apply water to provide a barrier only and not spray water over vital equipment. The proposed water curtain and curbing would be'provided to eeparate fire zone T-19B from both T-19A and T-19C.

The proposed wet N;

Fira Arac Ns. T-19A Pcga 5 pipe water curtain sprinkler system would add another dimension to the j

d:fense-in-depth concept, not only from the suppression consideration,

)

but also from its detection capability. Should the early warning ioniza-tion detection system fail, the fusible link element of the water curtain w:uld activate under a fire condition, water would flow, and the water flow alarm would annunciate in the control room. Modification #4 will

?

cesure that a postulated large flammable liquid spill would be restricted / contained to the fire area in which the spill occured.

The installation of an automatic suppression system throughout the cable tray system in the switchgear room is not feasible for the following reasons.

1.

A water spray suppression system is not compatible with the type of equipment located in the area.

Water dropping from overhead on indoor switchgear could cause faults and tripping of power to vital shutdown loads; thus compromising plant safety.

In the context of 10CFR50.48, installation of a sprinkler system in this fire zone would be detrimental to overall plant safety.

2.

An automatic suppression system using CO2 gas would be ineffective due to the fact that the volume of the switchgear room is too I

large.

,\\

The nature of the switchgear room lends itself to manual suppression.

3.

(a) The room is very accessible to fire brigades and (b) water would not be sprayed indiscriminately throughout the room.

I NNECO concludes that with the installation of the proposed alternative, i

l the intent of Section III.G.2 of Appendix R is achieved.

l Reference Drawings 1

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cak-43 Millstone 1 Safe Sutdown Fire Zone Analysis El. 34'6" Turbine Building S-2 Switchgear, Area Fire Area No. T-19B Safe Shutdown Equipment 4160-V Switchgear 6 (S-2) 480-V Switchgear 2A (S-2) Cables o associated with 480V #2 feed to MCC 2-5 (S-1) o All S-2 related cabling o Control cables for service water pump A, B o VAC MG set DC and AC feeds r- . rw.ar l 9 T 158 ...==m-1 Q~~_- n -, -e n m~ m.- s l _l J L DB=. ~. l"Of3 _, n I f ~ _]_MM p p., .y, l h. =** I t-'e' I 'g-eg m. e.pl _L____ ='

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. n =-r ue.- ;. _. mu.. 2-L J =a-T *- es.. Design Features _] l _ l %l 1 1. East and west walls, ceiling and floor are constructed of reinforced concrete. 2. North and south sections of this zone are open to adjacent areas. 3. Eight-inch concrete-block fire barrier wing walls are installed between 4 kV switchgear 5 (S-1) and 6 (S-2) and between 4KV switchgear

1. 6 (S-2) and #1 (S-1) and between 480V switchgear #2 (S-1) and #2A (S-2).

4. Fire stops to prevent the spread of fire to or from fire zones T-19A and T-19C along the raceway path. 5. Ceiling Height - 20' 3 6. Room Volume - 18,000 ft 7. Ventilation - Supply Air 2000CFM - Exhaust Air 3333CFM

Fira Arac No. T-19B Pega 2 Quangity Fire Logd Combustible Material (ft ) (Btu /ft ) Cables 89.0 51,900 Existing Fire Protection Portable carbon dioxide extinguishers located in adjacent zones. o 1 o Hose stations in fire zone T-19A and T-19E. o Early warning ionization detection. Compliance With Appendix R Does not comply with Section III.G.2.(a, c) of Appendix R. Exemption requested (see proposed modifications and discussion). Proposed Modification 1. The AC feeder from 480V switchgear #2 to MCC 2-5 will be enclosed with a one hour rated fire barrier from fire zone T-19A to fire zone T-19C. 2. A water curtain spray system will be installed to provide separation between fire zone T-19B and the adjoining T-19A and T-19C zones. 3. Curbs / dikes will be installed to separate fire zone T-19B from T-19A and T-19C. Discussion The extent of the exemption is 2-fold. (1) The acceptance of curb / dike cnd water curtain spray system as an alternative to a three-hour fire barrier. (2) The absence of an automatic suppression system in an area where redundant safe-shutdown equipment and cables have a 1-hour fire barrier. It is NNECO's position that incorporation of the proposed modifications together with fire brigade use of the locally housed manual fire suppression equipment will result in a degree of protection equivalent to that efforded by strict compliance with Appendix R options. Fire zone T-19B is a 25 foot square area located on the east side of the 34'6" elevation of the turbine building. As shown on Figure T-19A.1, post-fire shutdown capability is achieved by S-1 systems. Fire zone T-19B contains the diesel generator (DG/S-2) 4kV and 480V emergency switchgear. This equipment is located in close proximity to

Fira Arcs No. T-19B Pega 3 the AC feed from 480V #2 to MCC 2-5 (S-1) (see referenced drawing #34013). Because MCC 2-5 provides power to the Gas Turbine Generator (S-1) DC switchgear, and a fire in T-19B could destroy the ability to charge both station batteries which provide long-term DC control power supply, the MCC2-5 AC feed must be protected. The proposed witer curtain and curbing would be provided to separate fire zone T-19B from both T-19A and T-19C. The proposed wet pipe water curtain sprinkler system would add another dimension to the defense-in-depth concept, not only from the suppression consideration, but also from its detection capability. Should the early warning ionization detection system fail, the fusible link element of the water curtain .would activate under a fire condition, water would flow, and the water flow alarm would annunicate in the control room. Proposed modifications #1, #2 and #3 will assure that at least one safety division will remain functional following a fire. NNECO concludes that with the installation of the proposed alternatives, the intent of Section III.G.2 of Appendix R is met. Reference Drawing 34013 i

SUPPJ mI.MTPL SKETtR l St.ock tolet& LDALLS, l / \\ 3 SWsn# 5 9 KV SWSE

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esk-43 Millstone 1 Safe Shutdown Fire Zone Analysis El. 34'6" Turbine Building f Switchgear Area Fire Area No. T-19C Safe Shutdown Equipment (hot and cold shutdown equipment) 4i60-V Switchgear 3 4160-V Switchgear 1 Motor control center 2-5 Motor control center 2A-5 S-2 Bus Duct Tie Between 4 4kV #7, #3 and #1 o Cables l r_-?**** I i-c* 1 g, o Associated with Various [l ~,,,,,, S-2 switchgear and pumps g l.l J a g o AC feed 480V #2 to MCC 2-5 g j f o MCC 2-5 feed to Battery L'[ F -- *.- 1, Charger #1A M] g }=-a g,=j D-.. TJ ". l

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k$ E f . T-t9E i ~ -j j-Design Features 1. East wall is 12 inch thick reinforced concrete block wall. 2. Concrete block fire barrier wing walls separate 4 kV switchgear #6 (S-2), and 4 kV switchgear #1 (S-1). 3. 4160-V Switchgear 3 is partially enclosed on three sides by 8 inch concrete block walls with a 1-1/2 hour rated fire door in the south wall. 4. To the north and south the zone is partially open to zones T-19B i and T-19E. 5. Fire stops have been installed to prevent the spread of fire to adjacent zones along raceway paths. 6. Ceiling Height - 20' 3 7. Room Volume - 28,125 ft 8. Ventilation - Supply Air 5000CFM - Exhaust Air 10,000CFM

Fira Zan2 T-19C P:ga 2 Quangity Fire Logd Combustible Material (ft ) (Btu /ft ) Cables 71.3 38,400 Existing Fire Protection o Portable carbon dioxide extinguishers in adjacent zones T-19A and T-19D. o Hose stations in zones T-19A and T-19E. o Early warning ionization detection. Compliance With Appendix R Does not comply with Section III.G.2 of Appendix R. Exemption requested (see proposed modifications and discussion). Proposed Modifications (For proposed modifications - see generic discussion) Discussion (See generic discussion) Reference Drawing 34013

esk-43 Millstone 1 Safe Shutdown Fire Zone Analysis El. 34'6" Turbine Building Fire Area No. T-19D Switchgear Area Safe Shutdown Equipment (hot and cold shutdown equipment) 4kV Bus #7 Bus Duct Tie to 4kV Bus #3 (S-1) Cable p o Associated with DC-1 feed to control room l r" y' ** I l-T' I dist, panel DC-11A2 L-.j'."_] - L,~ (ADS valves) (S-2) M g [- M L i r. _. ? I a< k '"' I "N T ':- "" \\ _T N.s' k >L -l 1

I-!NJ Design Features 1.

The zone is bounded on the east by a 1-foot-thick external reinforced-concrete-block wall. 2. To the south the wall in common with the battery room is 1-foot-thick reinforced concrete block, and the remainder is 8-inch-thick reinforced concrete block. A 3-hour rated fire door leads to the battery room. 3. To the west and north are 8-inch-thick concrete-block fire barriers separating each switchgear. The north wall is provided with a 1-1/2 hour rated fire door leading to 4160-V switchgear 3. 4. Fire stops have been installed in the raceway system to prevent the spread of fire to adjacent areas. 5. Ceiling Height - 20' 3 6. Room Volume - 28,125 ft 7. Ventilation - Supply Air 3000CFM - Exhaust Air OCFM

Fira Arco No. T-19D Pcg2 2 Quangity Fire Logd Combustible Material (ft ) (Btu /ft ) Cables 27.1 14,600 Existing Fire Protection Hose stations and portable extinguishers located in adjacent areas. o o Early warning ionization detection. Compliance With Appendix R Does not comply with Section III.G.2 of Appendix R. Exemption requested (see proposed modifications and discussion). Proposed Modification (For proposed modifications - see generic discussion.) Discussion (See generic discussion.) Reference Drawing 34013

) cak-43 Millstone 1 Sefe Shutdown Fire Zone Analysis El. 34'6" Turbine Building Fire Area No. T-19E Switchgear Area Safe Shutdown Equipment (hot and cold shutdown equipment) 125-VDC Switchgear DC-1 and DC-1A 125-VDC Motor control center DC ll-A-3 Battery chargers 1, lA, and 11A 4160-V Switchgear 7 4kV Bus Tie from Bus #7 to Bus #3 Cables o Associated with S-1 and S-2 control power feeds o Emer. Serv. Water pumps A, C (S-2) (Cold shutdown equipment) o Serv. water pump D (non-c; T-34 m... safety) (cold shutdown 3 Y I'#' I M' equipment) b, o DC-1 feed to Dist. Pal. ~~ ~" -==== DC-11A2 (ADS valves, S-2) _ _ ~ _. I-ER b

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Fire Aron No. T-19E Pege 2 Design Features 1. On the east this zone is open to zones T-19C and T-19D, with the exception of the 8 inch concrete-block fire barrier wing walls. The battery room wall is 1-foot-thick reinforced concrete block with one 3-hour rated fire door. There is also a ventilation duct in this wall, with an automatically closing fire damper on the inside of the battery room. 2. On the north the area is bounded by the condenser bay reinforced concrete shield wall. A 48 inch ventilation fan exhausts into the condenser bay. 3. The south wall is external metal insulated siding. 4. The west wall is 1-foot-thick reinforced concrete block. 5. The floor is reinforced concrete on steel decking. There is a large hatchway (approximately 12 x 20 ft) covered by steel diamond plate in the center of the area. In the northeast corner a section of the floor is lowered, leaving an opening of about 3 ft to zone T-5C. 6. The ceiling is the reinforced concrete floor of the turbine operating deck. 7. Ceiling Height - 20' 3 8. Room Volume - 150,000 ft 9. Ventilation - Supply Air 6000 CFM - Exhaust Air 1000 CFM Fire Logd Combustible Material Quantity (Btu /ft ) Lubricating oil (hydrogen seal oil unit) 650 gal. 14,300 Cables 156.4 11,300 Lubricating oil (lift pumps) 25 gal. 600 Existing Fire Protection o Two hose stations, o One 10-lb carbon dioxide extinguisher.

l Fire Arca No. T-19E Pega 3 o One 150-lb wheeled dry chemical extinguisher. o Hose stations and portable extinguishers available from other areas. 1 A pre-action sprinkler system protects the bearing lift pumps and o seal oil kir detraining tank. Eariy. warning ionization detection. o Compliance With Appendix R Does not comply with Section III.G.2. of Appendix R. Exemption requested (see proposed modifications and discussion). Proposed Modifications (For proposed modifications see generic discussion) l Discussion (See generic discussion) Reference Drawings 34013, 34014 1 1

cck-43 Millstone Unit I Generic Discussion for Switchgear Room Fire Zones T-19C, T-19D, & l T-19E l Because of the' unusually complex physical layout of these three fire zones, the description of NNECO's proposed alternatives is provided i below to facilitate staff review. Refer to Figures T-19.1, T-19.2 and T-19.3 as a clarification to reference drawings 34013 and 34014. These zones were handled with the same philosphy as Fire Zone T-19A. The extent of NNECO's exemption request for these three areas is three-fold and consists of the following: (1) Appendix R Section III.G.2.a requires a 3-hour rated barrier between fire zones. NNECO proposes to substitute, as an alternative to this requirement, the installation of a curb / dike and water curtain spray system to protect fire zone T-19C from fire zone T-19B and vice-versa. (2) Appendix R Section III.G.2.b requires a minimum of 20 feet separa-tion with no intervening combustibles in addition to installed fire detection and automatic suppression systems. NNECO has concluded that the presence of intervening cable systems utilizing the types of insulation and jacketing material in service at Millstone Unit No. 1 constitutes an " intervening combustible" hazard. NNECO further concludes that the judicious placement of fire stops or breaks in the raceway system effectively nullifies this hazard and proposes this modification as an equivalent means of compliance with Section III.G.2.b. (3) Appendix R Section III.G.2.c requires an installed automatic suppres-sion system in addition to a one-hour fire barrier between redundant components. NNECO has concluded that the protection afforded by a one-hour fire barrier, the early warning ionization detection system, inherent but limited (not 20 feet) spatial separation and the use of manual fire fighting equipment by a trained fire brigade is the equivalent of the protection provided by strict compliance with Section III.G.2.c requirements. l l Proposed Modifications for Fire Zones T-19C, T-19D, and T-19E 1. Enclose the cables listed below in a 1-hr fire barrier as shown in Figure T-19.3. a) DC-1 feed to dist. pnl. DC-11A-2 (ADS Valves) b) DC-1 feed to MCC-DC-11A-2 (Iso. Cond. 1-IC-3 Valve) c) DC Control Power feeds to 4kV Emer. Bus #6 and 480V load center #2A (S2 safe-shutdown options) d) 480 VAC load center #2A feed to MCC-2A-4 (S2 DC Power) e) 480 VAC feed from MCC-2A-4 to Battery Charger #1 (S2 DC Power for S2 safe-shutdown options)

Note: Emergency Service Water Pumps A&C and Service Water Pump D power cables from 4kV switchgear #6 (S2) shall be protected in 1-hr barrier in parts of Fire Zones T-19C and T-19E. 2. Install fire stops in intervening cable trays. I 3. Install a' water curtain spray system to seperate Fire Zone T-19C from T-19B. 4. Install a curb / dike to separate Fire Zone T-19C from T-19B. With the installations of the proposed modifications and utilization of the extensive manual suppression equipment in the zone, it is NNECO's position that post-fire shutdown capability is assured. Fire Zones T-19C, T-19D and T-19E encompass most of the south end of the 34'6" elevation of the turbine building. Figure T-19.1 shows the fire zone layout of the south end of the 34'6" elevation. The zones cover an area of 75 feet by 150 feet. It should be noted that Fire Zones T-22, 23 and 24 are separated from the zones of discussion by 1-foot thick reinforced concrete walls and 3-hr rated doors. The Design Features Section of the three zone analysis provides some insight into existing characteristics of these zones. Particular attention should be paid to items T-19C.1, 2, 4, 5, T-19D.1, 2, 4 and T-19E.1, 2. Those particular design features provide some existing fire protection which can be credited for partial Appendix R compliance. Another design feature, which is not apparent on the reference drawings, is an existing 8" reinforced concrete wall that extends to a point 3' past the west end of 4kV SWGR #7 (See figure T-19.D). The reason block walls were not extended all the way across walkways between fire zones is to allow transfer of large transformers for maintenance purposes. Equipment and cables, which provide hot and cold shutdown capability, that are located in these fire zones are as follows: S1 Equipment 1) Battery Charger #1A 2) DC Switchboard #1A f 3) 4.16 kV SWGR. #1 4) 4.16 kV SWGR #3 5) 4.16 kV SWGR #7 6) MCC 2-5 S1 Cables 1) 4160 Volt Bus Duct 2) 480V#2 to MCC2-5 3) MCC2-5 to Bat. Chgr #1A 4) S1 DC Control Power Feeds 5) S1 Battery Tie to DC Swbd. #1A

S2 Equipment 1) Battery Charger #1 2) DC Switchboard #1 3)

• MCC2A-5 located in area, but not required if fire is located in SWGR. Room.

S2 Cables e 1) 4160 Volt Power from 4kV SWGR #6 to Intake Structure (cold shutdown) 2) 480V#2A to MCC2A-4 3) 480V#2A to MCC2A-5 *not vital if fire in SWGR. Room 4) MCC2A-4 to Bat. Chgr #1 5) S2 DC Control Power Feeds 6) S2 DC Power Feed to MCC-DC-11A-2 (1-IC-3 Valve) 7) S2 DC Power Feed to Dist. Pal. DC-11A-2 (ADS Valves) 8) S2 Battery Tie to DC Swbd. #1 9) MCC2A-5 to Standby Battery Charger #11A *not required if fire in SWGR. Room At this stage of the discussion, the reader should refer to the reference drawings for the actual routings of cables. Particular attention should be paid to S2 de control power cables that run in close proximity to S1 switchgear and cables. NNECO has identified these Appendix R interferences and has proposed modifications to meet the intent of Appendix R. The assumption that one fire would engulf the whole area covered by the three zones is incredible due to the large area of the zones. For this reason NNECO treated the review of these zones as though the whole area was divided into four smaller areas (See Figure T.19.2). Applying the 20 foot separation criterion as well as placement of one-hour fire barriers to determine the common boundaries or tnese areas, a fire was postulated in the areas, one at a time; to determine which shutdown capability would be lost and to identify alternative capability. With the incorporation of the above identified modifications, destruction of each area would be accomodated as follows: Table 2 Area Fire Zones Shutdown Capability l 1 T-19C, T-19D & portion of T-19E S2 Shutdown Capability (LPC1/ ADS or Iso. Cond/ ADS) 2 portions of T-19E (north side of S1 Shutdown Capability (FWC1) DC equipment room) 3 portion of T-19E (south side of S2 Shutdown Capability (LPCI/ ADS or DC equipment room) Iso. Cond/ ADS) 4 West end of T-19E S1 and S2 options l

The following discussion details NNECO's proposed modifications. Proposed Modification #1 provides for enclosure of several S2 cables in a 1-hour rated fire barrier. Figure T-19.3 diagrams the proposed reroute and fire protection of these cables throughout the area. It should be noted that S2 cable protection stops at the point near the 3-hour wall that separates the cable fr.om 4kV Switchgear #7. This proposed modification provides fire protection in areas 1 and 3 of the 3 fire zones. Proposed Modification #2.provides for the installation of fire stops in intervening cable trays in "a manner so as to prevent propagation of a fire from Fire Zone T-19B to area 1 and from area 1 or 3 to area 2. This modification l directly addresses the intervening combustibles portion of the exemption. l Proposed modification #3 will be incorporated to provide a water curtain between the S-1 and S-2 redundant switchgear. The water curtain would be a wet pipe system and would provide directional spray over the wing walls and curbed area as shown on supplemental sketch. This would selectively apply water to provide a barrier only and not spray water over vital equipment. The proposed water curtain and curbing would be provided to separate fire zone T-19B from both T-19A and T-19C. The proposed wet pipe water curtain sprinkler system would add another dimension to the defense-in-depth concept, not only from the suppression consideration, but also from its detection capability. Should the early warning ionization detection system fail, the fusible link element of the water curtain would activate under a fire condition, water would flow, and the water flow alarm would annunciate in the control room. Modification #4 will assure that a postulated large flammable liquid l spill would be restricted / contained to only one safety division area. The installation of an automatic suppression system throughout the cable tray system in the switchgear room is not feasible for the following reasons. 1. A water spray suppression system is not compatible with the type of equipment located in the area. Water dropping from overhead on indoor switchgear could cause faults and tripping of power to vital shutdown loads, thus compromising plant safety. In the context of 10CFR50.48, installation of a sprinkler system in this fire zone would be detrimental to overall plant safety. 2. An automatic suppression system using CO2 gas would be ineffective due to the fact that the volume of the switchgear room is too large. 3. The nature of the switchgear room lends itself to manual suppres-sion. (a) The room is very accessible to fire brigades and (b) water would not be sprayed indiscriminate 1y throughout the room. NNECO concludes that with the installation of the proposed alternatives, the intent of Section III.G.2 of Appendix R is achieved. Reference Drawings 34013, 34014

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) s s .. s 4 APPENDIX B INTERVENING COMBUSTIBLES 9 s s N I ~ s' DOCKET No. 50-245 JULY, 1982 s

l GENERAL POSITION ON INTERVENING COMBUSTIBLES Appendix R, Section III.G.2.b provides an NRC acceptable option which will assure that one redundant safety train is free of fire damage. It states: " Separation of cables and equipment and associated non-safety circuits of redun' ant trains by a horizontal distance of more than 20 feet with d no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed f in the fire area." l The intent of this option is obvious--provide assurance that a fire cannot spread to redundant safety divisions by propagating through the mechanism of intervening combustibles. s The term " intervening combustibles" has not, to our knowledge, been i specifically defined in any NRC publications, either in the form of regulation or guidance documents. In absence of clear definitions or guidelines on the subject of intervening combustibles, it was necessary for NNECO to develop and apply its own methods and criteria for utilizina Option III.G.2.b of Appendix R. ( In developing these criteria, the most conservative approach was first l evaluated. For this case it was postulated that safety systems com-ponents/ cables could be located literally hundreds of feet apart with t l a 1/4" diameter telephone cable connecting or extending to a point within the 20 feet allowed separation. A strict interpretation of Option III.G.2.b would conclude that this telephone cable was an in-tervening combustible and therefore the regulation would not recognize this situation as an acceptable configuration. Since this type of conservatism is built into Appendix R, then this Option III.G.2.b is effectively useless within the availability and use of a rational exemption evaluation process. From a realistic and practical viewpoint, it can be concluded that a fire involving one safety division will not propagate hundreds of feet via the referenced intervening combustible to damage its redundant counterpart. As discussed above, a strict interpretation of intervening combustibles could render this option useless and therefore reasonable judgment should be applied during the exemption review process. The intent of Appendix R Option III.G.2.b is to assure that fire will not damage a safe shutdown system and then propagate through intervening com-bustibles and damage a redundant division located 20 feet or more apart. With this clarification the following are the guidelines / parameters used by NNECO during its Appendix R review involving NRC Option III.G.2.b. s a

l 1 GENERAL POSITION ON INTERVENING COMBUSTIBLES - Page 2 1. Intervening combustibles are assumed to be installed (in-situ) combustibles. Considerations of transient combustibles renders Section III.G.2.b' option useless as intervening transient com-bustibleh can be postulated for any nituation; thus, we have concluded that in-situ combustibles represent a reasonable interpretation. ( ce2. Electrical cables classified as " flame retardant" and having been demonstrated to successfully pass the flame test specified in IEEE Standard 383 can be considered to be " intervening combustibles," but are recognized as fire retardant and l represent a significantly reduced threat to safe shutdown l integrity.

• • 3.

Non-fire retardant cables such as PE/PVC insulated and jacketed cables which are protected with a flame retardant mastic (such as (Flammastic) applied per approved procedures are considered the equal of IEEE Standard 383 qualified fire retardant cables, and as such can be " intervening combustibles," but are con-sidered fire retardant as discussed above for IEEE 383 cables. 4. Cabling installed in conduit is not considered " intervening combustibles" regardless of the fire retardant characteristics of the cable insulation and jacketing system. f

• • Additional information to support guidelines #2 and #3 is attached.

THE MERITS OF 383 CABLE AS A FLAME RETARDANT IEEE Standard 383 (1974) prescribes the method for testing grouped cables via the vertical tray flame test to determine relative ability to resist fire. Specifically, the flame test is intended to demonstrate that a test specimen does not propagate fire under conditions'of'; installation, even if its outer covering and insula-tion have been destroyed in the area of flame impingement. Please note this test represents worst case condition by testing cables in a vertical position. Cables which propagate the flame and burn the total height of the tray above the flame source fail the test (total height is six feet above the flame source). Cables which self-extinguish when the flame source is shut off are allowed to burn out in order to determine the extent of damage. If the damage extends beyond six feet, the cables fail the test. l Therefore, IEEE 383 qualified cables installed in a vertical tray, can withstand severe localized fire damage without danger of excessive fire propagation along their lengths, once the source of fire is removed / extinguished. Independent tests have demonstrated that when IEEE 383 qualified cables are installed in horizontal trays, fire propagation is even less credible. More significantly, tests have also demonstrated that the fire retardant characteristics of IEEE 383 cables permit them to maintain electrical circuit integrity for up to ten minutes into the most severe fire condition. Pasem on IEEE 383 testings, it is concluded that cabling qualified by the 383 test can be considered fire retardant and that it does restrict or retard fire propagation. Typically, there is little threat to the integrity of safe shutdown capability by the presence of such qualified cables. in an " intervening" configuration.

= i An American National Standard i IEEE Standard for Type Test of Class IE Electric Cables, Field Splices, and Connections for Nuclear Power Generating Stations

1. General Provisions containment. That portion of the engineered safety features designed to act as the principal 1.1 Scope barrier, after the reactor system pressure 1.1.1 This standard provides direction for boundary, to prevent the release, even under establishing type tests which may be used in conditions of a reactor accident, of unaccept-t qualifying Class IE electric cables, field able quantities of radioactive material beyond splicts, and other connections for service in a controlled zone.

nucl zr power generating stations. General design basis events. Postulated abnormal guid: lines for qualifications are given in IEEE events used in the design to establish the per-Std 323-1974, Standard for Qualifying Class i formance requirements of the structures, sys-IE Eltetric Equipment for Nuclear Power tems, and components (IEEE Std 323-1974). l Genersting Stations. Categories of cables cov-ared tre those used for power control and in-field splice. A permanent joining and rein-strumsntation services. sulating of conductors in the field to meet the i 1.1.2 Though intended primarily to per-service conditions required. tain to cable for field installation, this guide may also be used for the qualification ofinter-I"*U'd N#.The. terval from m.atallation to m rem val, durmg which the equipment or com-nil wiring of manufactured devices. ponent thereof may be subject to design ser-1.1.3 This guide does not cover cables for vice e nditions and system demands (IEEE service within the reactor vessel. Std 323-1974). 1.2 Definitions 8 NOTE: Equipment may have an installed life of 40 years cable type. A cable type for purposes of quah. with certain components of the equipment changed peri-fication testing shall be representative of edically; thus, the installed life of the components would be 1 s than 40 years. those cables having the same materials, sim-l iltr construction, and service rating, as manu-qualified life. The period of time for which sat-f ctured by a given manufacturer. isfactory performance can be demonstrated i r a specific set of service conditions. (IEEE Class IE. The safety classification of the el' c-e Std 3231974). tric equipment and systems that are essential to smitgency reactor shutdown, containment type tests. Testa made on one or more units to isolation, reactor core cooling and con-verify adequacy of design (IEEE Std 380-t:inment, and reactor heat removal or other-1972). wise are essential in preventing significant re-1.3 Type Tests As Qualification Method. As I se of radioactive material to the environ-described in IEEE Std 323-1974, type tests are the preferred method to demonstrate or assist connection. A cable terminal, splice, or hostile in demonstrating that electric equipment is cnvironment boundary seal at the interface of capable of meeting performance requirements ccble and equipment. under service conditions which include nor-mal and design basis event environments. To 'Other definitions related to this document may be perform type tests for cable, field splices, and found in IFEE Std 100-1972. (ANSI C42.100-1972). Die-connections requires: (1) description (identi-Laon ry of Electrical and Electronics Terms. IEEE Std fication) of cable (2) description of significant 323-1974. and IEEE Std 380 1972. Definitions of Terms U.*d in IEEE Nuclear Power Generating Station. stan, aspects of the environment, and (3) descrip-dards. tion of cable performance required. These, 7

12.t.t. Std 3831974 TYPE TEST OF CLASS IE then, with engineering knowledge and experi-1.3.3.1 A tmosphere. Maximum and aver-ence in insulating materials and systems form age ambient or normal operation condition a basis for designing type tests to demonstrate and design basis event condition or profile for the capabilities. Qualification of one cable the following: may permit extrapolation of results to qualify (1) Gas composition and velocity other cables of the same type, with consid-(2) Moisture content eration being given to cable dimensions and (3) Temperature probable modes-of failure. (4) Pressure A sample field splice or connection or both 1.3.3.2 Radiation. must be type tested with the cable to demon-(1) Normal dose rate and type strate its electrical, mechanical, and chemical (2) Total normalinstalled life dosage compatibility in the environments. (3) Design basis event dose rate. Maximum 1.3.1 Cable Deecription. This description or dose rate and approximate profile specification should melude as a mmimum: (4) Total design basis event dosage 1.3.1.1 Conductor - material identi-(5) Total for the installed life plus design fication, size, strandmg. coating. basis event 1.3.1.2 Insulation - material identi-fication, thickness, method of application. 1.3.3.3 Chemicals 1.3.1.3 Assembly (multiconductor cables (1) Type of chemicals and concentration only) - number and arrangement of con-(2) Spray or immersion rate and time ductors, fillers, binders. (3) Temperature of exposure 1.3.1.4 Shielding - tapes, extrusions, 1.3.3.4 Megam, cal. Normal operating braids, or others. e ndition and design basis event condition for 1.3.1.5 Covering - Jacket or metallic ar-the followmg: mor or both, material identification, thick. (1) Bending or flexing ness, method of application. (2) Vibration 1.3.1.6 Characteristics - voltage and (3) Tension j temperature rating (normal and emergency). (4) Sidewall pressure For instrumentation cables - capacitance, 1.3.3.5 Fire i attenuation, characteristic impedance, micro. 1.3.4 Operating Requirements phonics, insulation resistance, as applicable. 1.3.4.1 Meeting Service Conditions. The 1.3.1.7 Identification - manufacturer's cable, as installed, should be suitable for oper-trade name, catalog number. ation at maximum ambient temperature, 1.3.2 Field Splice or Connection Description radiation. and atmospheric conditions and or Both. This description or specification normal electrical and physical stresses for its should include as a minimum: installed life, as specified. Evidence of this 1.3.2.1 Whether factory or field assem. suitability may be based on compliance with bled to cable. appropriate published industry standards, 1.3.2.2 Conductor connection - type, past documented operating experience, com-materialidentification, and method of assem. ponent tests, or a combination of these. bly. The total station may be subdivided into 1.3.2.3 Items from Sections 1.3.1.2 zones with substantially different ambient through 1.3.1.7. conditions. and if segregation of cables to cer-1.3.3 Description of Significant Environ. tain areas is assured, a cable need only be suit-mental Conditions. Both normal operating able for meeting service conditions in those and design basis event conditions, as well as zones in which it is located. their sequence and duration. are relevant for 1.3.4.2 Design Basis Event Conditions type testing. Separate requirements for post for Qualifying Cables design basis event conditions may be required 1.3.4.2.1 Design Basis Event - Loss-in recognition of momentary or accumulative of Coolant Accident (LOCA) (for cables in changes in material properties due to aging, containment only). The cable, field splices, radiation, heat, and steam exposure. Environ-and connections should throughout their nor-mental factors. the limits of which may be sig-mal lives be capable of operating through nificant to the cable's operation are as follows: postulated environmental conditions re-8 y:-.- 7 m.- --~- p ,c 'l

IEEE .ECTRIC CABLES. FIELD SPL1CES, AND CONNECI' IONS Std 383-1974 Iting frcm a LOCA. Conditions of loading environmental extremes which simulate _the id signal levels shall be assumed to be those most severe. postulated conditions of a design ~ ost unf:vorable for cable operation which Isis event and specified conditions of instal-sy be anticipated under such circumstances. lation. Type tests shall demonstrate margin 1.3.4.2.2 Design Basis Event - Fire. } by application of multiple transients. in-ha ecble should not propagate fire under crecsed level, or other justifiable means. Satis-inditions of installation. j factory performance of the cable will be eval-1.3.4.2.3 Other Design Basis Events. usted by electrical and physical measure-hest should also be considered in case they ments appropriate to the type of cable during ' pres 2nt different types or more severe haz-or following the environmental cycle or both. rds to esble operation. The values of pressure, temperature, radi-1.3.5 Type Test Conditions and Sequences ation, chemical concentrations, humidity, 1.3.5.1 General. Type tests are used pri-and time in Section 2 do not represent accept-istily to indicate that the cables, field able limitations for all nuclear power stations. plicts, and connections can perform under The user of this guide should assure that the be conditions of a design basis event. Because values used in the required type tests repre- [ be drsign basis events may oc' cur at any time sent acceptable limits for the service condi-i the station life, the thermal and radiation tions in which the cable or connections will be ging required in type tests to simulate these installed. onditions may at the same time indicate the .bility of cable types to operate under the nor-nil service conditions within the station. 1.4 Documentation 1.3.5.2 Aging. The effect of normal oper-1.4.1 General. Type test data used to dem-iting conditions with time may either add to onstrate the qualification of cables should be -- ir rzduce the ability of cable, field splices, and organized in an auditable form. The docu-nnections to withstand the extreme envi-mentation should include: Inments and loads imposed during and fol. 1.4.1.1 Description or specification of owing a design basis event. Thus, the type cable. .esting for design basis event conditions shall 1.4.1.2 Description or specification of .nvolve both aged and nonaged samples. As-field splice or connection. ng pertains to temperature, radiation, and at-1.4.1.3 Identification of the specific envi-rnospheric effects applied in sequence or si-ronmental features. rnultaneously in an accelerated manner. 1.4.1.4 Identification of the specific per-Tha basis for establishing time and temper-formance requirements to be demonstrated. sture conditions for aging of samples to simu-1.4.1.5 The test program outline. I ts their qualified life may be that of Ar-1.4.1.6 The test results. rhenius plotting (IEEE Std 1-1969 General 1.4.1.7 Approving signature and date. Principles for Temperature Limits in the Rat. 1.4.2 Test Program Outline. For cable and ing of Electric Equipment. IEEE Std 98-1972, connections, this outline shall include: Guide for the Preparation of Test Procedures 1.4.2.1 The physical arrangement of the for the Thermal Evaluation and Estab-cable and test equipment description. lishment of, Temperature Indices of Solid 1.4.2.2 Time program and sequence of all Electrical Insulating Materials, IEEE Std 99-environmental factors. d 1970. Guide for the Preparation of Test Proce-1.4.2.3 The type and location of all envi- [ dures for the Thermal Evaluation of Insula-ronmental and cable monitoring sensors for ti:n Systems for Electric Equipment. and each variable. [ IEEE Std 101 1972. Guide for Statistical 1.4.2.4 The voltages or currents pro-1 i Anclysis of Thermal Life Test Data) or other grammed in conjunction with Section 1.4.2.1 I method of proven validity and applicability above. for the materials in question. 1.4.2.5 The electrical, thermal, or me-1.3.5.3 Test Design Basis Event. Type chanical tests to be performed during environ-tests for design basis event conditions should mental exposure. consist of subjecting nonaged and aged cables, 1.4.2.6 Testing or examinations sub-fiild splices, and connections to a sequence of sequent to environmental cycle. 9 l

IEEE 1 Std 3831974 TYPE TEST OF CLASS IE 1.4.3 Tect R sult:. Test results sh:uld dim- } cnstrate that: lists sizes which have been considered repre-i sentative of these -Hecories. The sample 1.4.3.1 The intended environmental se-quinces were achieved. lengths should be sufficient to permit reliable test readings and evaluation consistent with 1.4.3.2 The cable or field splice (or con-good testing practice. n:ction) or both was capable of performing its int:nded function. 2.3 Testing to Qualify for Normal Operation 1.4.4 Test Evaluation. An evaluation of 2.3.1 Temperature and Moisture Resist. data should be made to demonstrate the ad-once. Evidence of qualification for normal op. squacy of cable performance as outlined in cers@med evidence that the cable ha era n may &m ea bM mg Section 1.4.1.4. 1.5 Modifications. When modification in the manufactured and tested and passed in accor-materials or design of cables or in the condi-dance with the provisions of one or more of the tions ofinstallation or in the postulated envi. following industry standards or criteria. ronments are made, prior type tests shall be ANSI C83.211972 Requirements for Solid tsviewed to determme the effect on the cable Dielectric Transmission Lines qualification. This evaluation shall mdicate ANSI C96.1-1964 (R1969) Temperature Mea-whzther or not new type tests are required. surement Thermocouples Thz analysis of data and evaluation that dem-ANSI C11971 National Electrical Code, enstrates the effect of the modification on the NFPA 70-1971, Sections on Types RHH, squipment performance shall be added to the RHW, and XHHWJ qualification documentation. IPCEA S-19-81 Rubber Insulated Cable IPCEA S-66-524 Cross-Linked Polyethylene-Insulated Cable IPCEA S-68-516 Interim Standards for Eth-

2. Examples of Type Tests ylene-Propylene-Rubber Insulated Wire and Cable. Number 1. Cables Rated 2.1 Introduction. Type tests described in this document are examples of methods which 0-35 000 V. Number 2, Cables Rated 2000 V, Integral Insulation and Jacket.

may be used to qualify electrical cables, field AEIC 5 71 Specifications for Polyethylene splicts and connections for use in nuclear and Cross-Linked Polyethylene-Insulated, powar generating stations. Tests of the cable Shielded Power Cables rated 5000-35 000 V cr connection assembly, as applicable, should AEIC 6 73 Specifications for Ethylene-Propy-th n supplement the cable tests in order to lene-Rubber Insulated Shielded Power qurlify the connections and other aspects Cables Rated 5-46 kV unique to planned usage. 2.3.2 Long Term Physical Aging Proper-The values of pressure, temperature, radi. ties. Aging data should be submitted to estab-ction, chemical concentrations, humidity, lish long term performance of the insulation. End time used do not represent acceptable Data may be evaluated using the Arrhenius limits for all nuclear power generating sta. technique. A minimum of 3 data points, in-tions. The user of this guide should assure cluding 136

• C and two or more others at least thtt the values used in the required type tests 10*C apart in temperature, should be used.

rsprssent acceptable limits for the service con. 2.3.3 Thermal and Radiation Exposure. ditians in which the cable or connections, or The following test sequence may be used to both will be installed. demonstrate that the cable will be operational R:sults of prior tests that are being used as after exposure to simulated thermal and radi-the bises for the present tests should be refer-ati n aging. snced in the documentation. 2.2 Type Test Samples. The samples tested should contain the conductor, insulation, fill-

• Cable type. RHH. RHW, and XHHW, as specified ars, Jteket, binder tape, overall jacket, shield.

in the National Electrical Code should meet the re-ing, and field splices which are representative cf tha cable category being qualified. Table 1 N," j,,7 N j o [ ioc,$othe bte s t iz a,enci. 10 v- '-. ~ }**

l IEEE lLECIltlC CABLES, FIELD SPLICES, AND CONNECTIONS Std 3831974 i Table 1 Represensentative Cables for Type Tests Type Test Section size Jp to 2000 V multiconductor temperature and moisture 2.3.1 1/C-14 or 12 AWG entr:1 cabla or resistance i ihi11ded multiconductor I Jgnal esbla (see list below for thermal and radiation 2.3.3 1/C or M/C-ndividu:] component) or exposure 14 or 12 AWG $ingla conductor power cable design basis event 2.4 1/C or M/C - simulation 14 or 12 AWG 1/C - 6,4 or 2 AWG ' vertical flame test 2.5.6 1/C-14 or 12 AWG 3 singles from cable j assembly ivertical tray flame test 2.5.4 7/C-16,14 or 12 AWG j Sillded pairs, triple or temperature and moisture 2.3.1 1 pair shielded hund from multiconductor resistance 16 AWG or actual cable hnal cable thermal and radiation 2.3.3 exposure design basis event 2.4 simulation vertical flame test 2.5.6 ?oaxisl. triaxial or temperature and moisture 2.3.1 actual size lpecial instrument cable resistance thermal and radiation 2.3.3 exposure design basis event 2.4 simulation vertical flame test 2.5.6 singles from cable assembly Bingla piir thermocouple temperature and moisture 2.3.1 2/C-20 AWG or actual OtInsion esble resistance size if smaller thermal and radiation 2.3.3 exposure design basis event 2.4 simulation i vertical tray flame test 2.5.4 vertical flame test singles 2.5.6 from cable assembly 2001-15 000 V power cable vertical tray flame test 2.5.4 6 AWG (2 5kV) )/C triplsxtd and multiconductor 2/O or 4/O or 4 /O (215kV) 2.3.3:1 Form suitable lengths of insu-jected in air to gamma radiation from a source I sted c:nductor which conform to the appli-such as "Co to a dosage of 5 x 102 rd at a rate cbl2 stEndards into test coils so that the ef-not greater than 1 x 106 rd per hour. Ktiva section of each coil under test will be 2.3.3.4 After the radiation exposure of 'ot less then 10 ft. Section 2.3.3.3 the specimen should be 2.3.3.2 Subject the coils to circulating air straightened and recoiled with an inside ven cging at a temperature and time devel-diameter of approximately 20 times the cable ped by plotting data using the Arrhenius overall diameter and immersed in tap water at Khniqu2 er other method of proven validity room temperature. While still immersed, a simulated installed life. these specimens should pass.a voltage with-2.3.3.3 The specimens with conditioning stand test for 5 minutes at a potential of 80 s covered in Section 2.3.3.2 should be sub-V/ mil ac or 240 V/ mil dc. l 1 11 l I .n

IEEE Std 383-1974 TYPE TEST OF CLASS IE 2.4 Tastirs f;r Operctiss During Design around a metal mandrel with a diameter of B: sis Event approximately 40 times the overall cable 2.4.1 eneral. This section is predicated diameter and immersed in tap water at room upon a loss of coolant accident (LOCA) but temperature. While still immersed, these spec-not necessarily limited thereto. i imens should again pass the same voltage Prepare two sets of specimens in accordance withstand test performed under Section with the following. 2.3.3.4. 2.4.1.1 One set to be unaged. 2.4.1.2 The other set to be heat aged NOTE: The poet LOCA simulation test demonstrates an specimens in accordance with Sections 2.3.3.1 adequate marrin of safety by requiring mechanical dura. bility (mandrei bend) following the environmental simu-cnd 2.3.3.2-I8ti n and i8 m te severe than exposure to two cycles of the environment. NOTE: The requirements of Sections 2.3.3.3 and 2.3.3.4 m2y be omitted if Section 2.4 is followed as a ruide since tha requirements of Section 2.4 exceed those of Sections 2.5 FlameTests 2.3.3.3 and 2.3.3.4. 2.5.1 General This section describes the t method for type testing of grouped cables via 2.4.2 Radiation Exposure - Total. Ex-the vertical tray flame test to determine their '1 posure specimens to the maximum total cum-relative ability to resist fire. ulative radiation dosage expected over the in. 2.5.2 Criteria stalled life (see Section 2.3.3.3) plus one 2.5.2.1 The fire test should demonstrate l LOCA exposure to radiation for the particular that the cable does not propagate fire even if installation involved as covered in IEEE Std 323 1974 Appendix A or B. The rate of ex-its outer covering and insulation have been pc:ure shall not be greater than 1 x 10* rd per destroyed in the area of flame impingement. 5 2.5.2.2 The fire test should approximate hour. This restriction is removed when simu-installed conditions and should provide con-1 tion of the LOCA profile requires a greater sistent results. dosi rate. 2.5.3 Test Specimens 2.4.3 LOCA Simulation. Test irradiated 2.5.3.1 The tests proposed are for power. l sp;cimens in a pressure vessel so constructed control, and instrumentation cables. thxt the specimens can be operated under 2.5.3.2 Sizes recommended for type tests rcted voltage and load while simultaneously may be as listed in Table 1 but not necessarily l cxposed to the pressure, temperature. humid-limited thereto, ity cnd chemical spray of a LOCA event. Chxmber designs should have provisions for 2.5.4 Fire Test Facility and Procedure 2.5.4.1 Test should be conducted in a monitoring and varying temperature and naturally ventilated room or enclosure free steam pressure, for recycling chemical spray, I Knd for electrically loading the specimens as from excessive drafts and spurious air cur-rents. specified herein. l 2.4.3.1 After conditioned specimens are 2.5.4.2 The vertical tray configuration is recommended as the best arrangement to es-l instelled inside the pressure vessel they tablish whether or not a cable could propagate should be energized at rated voltage and a fire. The tray should be a vertical, metal, 1:4ded with rated service current while under ladder type. 3 in deep,12 in wide, and 8 ft l th cverage normal operating condition. The long. The tray may be bolted at the bottom to l snzrgized specimens should be exposed to one a length of horizontal tray for support. cycla of the environmental extremes accord-ing to the schedule postulated for the particu-2.5.4.3 Test sample arrangement - mul-l lir installation, see IEEE Std 323-1974. tiple lengths of cable should be arranged in a 2.4.3.2 The cable should function elec-single layer filling at least the center six inch portion of the tray with a separation of ap-tricclly throughout its exposure to the envi-proximately 1/2 the cable diameter between renmIntal extremes within the specified elec-each cable. The test should be conducted 3 triccl parameters. times to demonstrate reproducibility using 2.4.4 Poal LOCA Simulation Test. Upon different samples of cable. c:mplition of the LOCA simulation, the spec-2.5.4.4 Flame source, when specified, the im:ns should be straightened and recoiled procedure detailed below shall be followed: 12 - - - " )EEE*

65Enlerim IEEE ELECTRIC CABLES. FIELD SPLICES. AND CONNECTIONS Rd 3831974 14in wide.11-55 Drilling l Rshbon Burner Madifed Zero-Pressure Governor l Optional for Gas Pressure Control Netural p

• Air 4es Miner or Propene Gas Source Ll Water l

Menometers Supply Sede A Water Compressed air A r in tB U (oil free and dryl Air replator and valve. NOTE: All pressures measured under dynamic conditions. A Schematic Drawing \\ \\ out e N A m.nor Ports N controsvdo.4 I $3S" Stud"*d A A s-32 Nut Sold. red / to Cover Plate } /4 spring (Appros l 9 inch Dimensions) oo.200 lach l 3 Free Length.1 inch Wire Seze.018 Inch 12 Turns Cover Plate Last Tum Formed j to a Poent B Detail Drawing of Zero Preneure Governor Modification Fig 1 . Flame Source 2.5.4.4.1 The ribbon gas burner shall in behind and approximately 2 ft above the 8 be mounted horizontally such that the flame bottom of the vertical tray. Because ofits uni-irnpinges on the specimen midway between form heat content natural grade propane is the tray rungs, and so that the burner face is 3 preferred to commercial gas. 2.5.4.4.2 The flame temperature 'An American Gas Furnace Co 10in.11-55 drilling. rib-should be approximately 1500*F when mea-b.n type. catalog no 10X 1155 with an air sas Venturi sured by a thermocouple located in the flame miser. catalog no 14-18 (2 lbf/in' man gauge pressure) se tho only presently available model that has been found close to but not touching the surface of the setsfactory for purposes of these tests. test specimens (about 1/8 in spacing). 13 o

IEEE 1 Std 3831974 TYPE TEST OF CLASS IE as ,...; ; y. ; a' .U Vi' N'. : :' f.4'g ~,$)f i$ ~ l l ?W y~ ' a)ii. (EG@@$?f.$ u i f,p JM3 .say.g Poto'c'de'$es a vo cawrie l3 l 7 ". g, is i 3 $7tp 3 STtF 4 POLD Costetes D"W et TO CtmTte l Na M N 6 sTfP s 'IEc"o*7Es <*oian4 to est 7.n.T v NOTE: All dimensions are in inches. es Fig 2 Burlap Folding Sequence I 2.5.4.4.3 For the schematic arrange- - m:nt see Fig 1. Under dynamic conditions,if 2.5.4.5.1 Use a 24 in square piece of 9 prcpane gas is used the pressure shall be or per square yard burlap, folded as shown in } -2.6*0.3 cm of water at the supply side A to Fig 2 into a bundle 4 in x 4 in x 6 in. Wrap j the Venturi mixer. If commercial gas is used with fine copper wire as shown, to retain the j th2 pressure shall be -0.9*0.1 cm of water shape of the bundle. Immerse in a container of whzn measured at the suppl oil' for 5 minutes. Remove, hang free in air, l turi mixer. For propane gas,y side of the Ven-allow to drain for approximately 15 minutes. the airpressure j sh:uld be 4.3*0.5 cm of water. For commer-The burlap ignitor is weighed before im-l ciIl gas it shall be 5.6*0.5 cm of water, men-mersion and after draining, and the fuel pick-sured at the air inlet B to the mixer. In prac-up should be 160*5 g. The repeatability of tice the flame length will be approximately 15 this test is derived from constant fuel pickup in when measured along its path. in ignitors of constant size and weight. Tem-perature should be monitored at point of max-2.5.4.4.4 Gas. burner procedure - ig-imum flame impingement upon the test ca-nita the burner and allow it to burn for 20 bles. minutes. Record temperatures at point ofim- . ping: ment throughout the duration of the 2.5.4.5.2 After draining, the ignitor test, length of time flame continues to burn af-should be placed in front of and approximate-ter g:s burner is shut off, jacket char distance, ly !' ft above the bottom of the tray with the cnd distance insulation is damaged. 4 in x 6in face of the ignitor held in place 2.5.4.5 Alternative flame source, oil or against the cables by a suitable metal wire or band. burl:p - when specified, the procedure de-tr.iled below shall be followed. such as Mobilect 33. 14 .. m., -..-. - =. - = r =- ~ - - '~ ^

-) a marrysm .) I i IEEE F LECTRIC CABLES, FIELD SPLICES, AND CONNECTIONS Std 3831974 2.5.4.5.3 Ignite the oil soaked burlap. perature Limits in the Rating of Electric I Th2 cpplied flame should be allowed to burn Equipment i its:lf out naturally. IEEE Std 98-1972, Guide for the Preparation j 2.5.5 Evaluation. Cables which propagate 3h2 firma and burn the total height of the tray } of -Test Procedures for_ the Thermal Eval-y untion, and Establishment of Temperature cbov2 the flarne source fail the test. Cables i Indices of Solid Electrical Insulating Materi- ? chich s:lf-extinguish when the flame source is ' als R xmoved or burn out pass the test. Cables IEEE Std 99-1970, Guide for the Preparation !8 chich continue to burn after the flame source ; of Test Procedures for the Thermal Eval-d b shut off or burns out should be allowed to untion of Insulation Systems for Electric Surn in order to determine the extent. Equipment [ 2.5.6 Instrument Cable and Single Con. IEEE Std 100-1972 (ANSI C42.100-1972), i ducters from Multiconductor Assembly. A Dictionary of Electrical and Electronics i Cpecimin of each type ofinstrument cable or Terms i Gh2 individually insulated or insulated and IEEE Std 101-1972, Guide for the Statistical f. fjceketsd conductors removed from each mul-Analysis of Thermal Life Test Data Ciconductor control cable which is type tested IEEE Std 2791971 (ANSI N42.7-1972), Cri-chould prss a flame resistance test in accor-teria for Protection Systems for Nuclear Pow-dcnce with ASTM D2220-68 Vinyl Chloride er Generating Stations 1 &lzstic Insulation for Wire and Cable, Section IEEE Std 308-1974, IEEE Standard Criteria 1 0 (IPCEA Standard S-19 81, Section 6.19.6), for Class IE Power Systems for Nuclear Power ] cxcept the weight may be omitted if the speci-Generating Stations men is sicurely clamped. IEEE Std 317-1971 Electrical Penetration-8.6 Documentation of Type Testing. Follow-Assemblies in Containment Structures for clear wer neraMg Mahons eng th2 procedures outlined in this guide, pro-IEEE Std 323-1974, Standard for Qualifying ade dzta necessary to document satisfactory c:mpliznce. Certification of prior test results Class IE Electric Equipment for Nuclear i cill be provided when required. Power Generating Stations IEEE Std 334-1971. Type Tests of Continuous Sectirn Duty Class I Motors Installed Inside the Con-8.3.1 Tcmperature and Moisture tainment of Nuclear Power Generating Sta- '8.3.2 Long-Term Physical Aging Properties tions 8.3.3 Tharmal and Radiation Exposure IEEE Std 336-1972 (ANSI N45.2.4-1972), In-8.4 Tcsting for Operation During Design stallation, Inspection, and Testing Require-Brsis Event (LOCA) ments for Instrumentation and Electric t 8.5.1 Firme Test on Grouped Cables in Verti. Equipment During the Construction of Nu-8 cal Tray clear Power Generating Stations 8.5.6 Flime Test on Single Conductor IEEE Std 380-1972, Definitions of Terms Used in IEEE Nuclear Power Generating Sta-

3. References tions Standards ASTM D2220-68, Vinyl Chloride Plastic Insula-lEEE Std 1 1969, General Principles for Tem-tion for Wire and Cable L

f I 15 ll i-

i l FLAMEMASTIC - AS AN EFFECI A n. mu. MARDAiG Fltmesastic is compose'd of a polyvinyl acetate binder, flame retardant cdditives and inorganic fillers and fibers. The polyvinyl acetate binder forms a tough, weather-resistant, permanent coating which encapsulates the cable. The. fire retardant additives include antimony oxide, chlorinated hydrocarb,ons and a phosphate plasticizer. These materials function synergistically to inhibit the flammability of the binder and all flammable substrates to which the coating is applied. Wh:n exposed to a fire, the coating functions to provide fire retardant properties through a combination of the following series of actions: 1. An ablative process, consisting of dehydration and other endothermic chemical reactions coupled with the formation of a carbonaceous char, which reduces the heat transmission to the protected object. 2. Radiation of a significant amount of heat away from the protected object emanating from the carbonaceous char and the inorganic components of the coating which form a surface of high heat emmissivity. 3. A heat insulation effect provided by the coating of high temperatures to reduce the heat transferred to the protected object. Although the coating has been designed to offer limited insulation at room temperature in order to minimize ampacity derating effects on cables, it functions as an effective heat insulator. 4. The fire retardant additives form products in the fire which inhibit the combustion process and minimize the flammability of materials in the vicinity of the fire. 5. The coating itself and the inorganic fibrous residue that remains after the organic binder has been pyrolized form a barrier that effectively prevents the access of oxygen to the flammable materials that are being protected. Basically, Flamemastic protection involves the encapsulation of cabling with a coating that will not propagate flame, that is, it will not burn l I in the ordinary sense of the term. Flamemastic prevents the process that allows 'non-burning' cables to support each others combustion when grouped in trays or bundles. In many independent tests, both in this country and abroad, it has been shown that a fire source that will cause unprotected grouped cables to ignite, burn completely and propagate fire, will cause little or no damage to Flamemastic protected grouped cables. In a situation where a large heat source impinges directly on Flamemastic coated cables, the cables will ultimately be destroyed at the point of ficae impingement but the coating will completely prevent propagation of fleae away from the point. Sore fire tests have shown that a 1/16 inch coating of Flamemastic on rendomly grouped cables in a cable tray will not cause the cables to heat excessively when operated in accordance with the current limitations specified by the National Electric Code for such conditions.

I s... Other fire tests have shown that a self spreading fire will not occur in esbles installed in either horizontal or vertical cable trays which are coated with Flamemastic and exposed to a fire of moderate intensity. Flcmemastic complies with Factory Mutual requirements and it is approved for the protection of grouped combustible insulated cables against a self-spreading fire originating within the cables or from exposure to an external ignition source of moderate intensity. The United States Testing Company performed standard flame spread, smoke l drasity and fuel contributed tests on a 1/4 inch Johns Manville Flex-board coated with a 1/16 inch (dry) film thickness of Flamemastic fire barrier coating in accordance with ASTM Designation E-84, " Standard Mathod of Test for Surface Burning Characteristics of Building Materials". The results showed that Flamemastic has a flame spread rating of 10, a fuel contribution of 0 and a smoke density classification of 30. (See copy of Test Report No. LA12396). Attached are copies of two certified test reports for tests conducted at the Kerite Company fire test facility in 1977. The objective of the tests was to demonstrate that the cables and raceways, as tested, would not propagate a fire, even if the outer covering and insulation of the cables had been destroyed in the area of flame impingement, when exposed to an IEEE Standard 383 (1974) flame source. The cables used were 7/C and 4/C #10, 1,000 V, polyethylene insulated conductors and PVC jacketed cables which are representative, in every respect, of the type of cable originally installed at the Haddam Neck Plant. The tray arragement used for the tests was also typical of those errangements found at the Plant. Two layers of ten feet lengths of test cable were mounted in the tray with no cable spacings in between. Each layer consisted of fifteen cables, half from each conductor make-up placed in alternating sequence, for a total of thirty cables. The tray arrangement was tested with (test Reference No. 3) and without (test Reference No. 8) the application of Flamemastic. Six cables were chosen at rendom for each test, three from each layer, for energizing with a 240V power source which was also used to monitor the electrical integrity of the cables during the tests. The only difference between the standard test procedure (IEEE 383) and the Kerite tests, was the cable spacing in the tray which is more representative of conditions at the Plant. However, approximations to installed conditions are permitted by the standard. It is NNECO's conclusion that the Flamemastic material provides exceptional protection for cables subjected to a direct flame. Also that the Flamemastic caterial effectively prevents fire from spreading in the horizontal direction. Finally that the protective system offers an excellent warning system both visually (white smoke) and by odor.

I l l l United States Testing Company, Inc. California Division 8654 TELEGRAPH ROAD, LOS ANGELES, CALtPORNIA 90040 TELEPHONE: LOS ANGELES-2133237181 ) s a tese FROed SAN FRANCISG)-41E/03458 REPORT OF TEST The Flamemaster Corporation ~ 11120 Sherman Way Sun valley, California 91352 FIAME SPREAD CIASSIFICATION SMOKE AND FUEL CONTRIBUTION Flamemastic 77 Coating November 16, 1981 TEST REPORT NO. IA 12396 SIGNED FOR THE COMPANY $C.Y Ar4 ia J I y4-SY Pat McCullen mes H. He9 wood Test Technician Test Engineer 25 1r Richland Reading Memphis a

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Og, UNITED STATES TESTING COMPANY, INC. La 12396 1 REFERENCE Client's Purchase Order No. 7948 per Mr'. Samuel L. Engel, Sr. REQUIREMENT Perform standard flame spread, smoke density and fuel contributed classification tests on the panel supplied by the Client in accordance with ASTM Designation E-84, " Standard Method of Test for Surface Burning Characteri-otics of Building Materials". SAMPLE IDENTIFICATION The sample tested was submitted and identified by the Client as: Flamemastic 77, a water based, fire l' barrier coating applied to 1/4" Johns Manville Flex-board at a rate of 1/8" wet film thickness. (k 2)RY Page 2.

UNITED STATES TESTING COMPANY, !!'O. ~ IA 12396 PREPARATION AND CONDITIONING ~.. ~ The panels provided were self supporting and pre-cut to meet the tunnel dimensions. The sample panels were. placed in the conditioning room (maintained at a dry-bulb temperature of 73.415'F. and a relative humidity of 50 1 5%) and allowed to come to equilibrium. TEST PROCEDURE The sample was tested following calibration and pre-heating. The evaluation was performed in conformance with the specifications set forth in ASTM Designation E-84, " Standard Method of Test for Surface Burning Characteristics of Building Materials", both as to equipment and test procedure. The foregoing test procedure is comparable to UL 723, NFPA No. 255, and UBS No. 42-1. e 3. ~ _,

- ~ ~ ' ""*'e u n s s cu o n e. ".2

,,j,

LA 12396 J SUMPRRY OF TEST RESULTS Occause of the possible variations in reproducibility, the results are adjusted to the nearest figure divisible by 5. Fuel Smoke Sample Identification Flame Spread contribution _ Density Flcmemastic 77 10 e , 30 In order 'to obtain the Flame Spread Classification, the. above results should be ' compared to the following table: NFPA CLASS ~ UBC CLASS _ IIAME SPREAD I. O.through 25 A B I,I 26 through 75 C III 76 through 200 201 through 500 D Over'500 E BUILDING CODES $ITED N, tional Fire Protection Association, NFPA No.101, 1. a " Life Safety Code". Uniform Building Code, 1979 edition, Part VIII, " Fire 2. Resistive Standard for Fire Protection", Chapter 42-4201-4203. Interior Wall and ceiling Finish, Sections Pg. 4

g UNITED STATES TESTING COMPANY, INC. IA 12396 ASTM E-84 TEST DATA SHEET CLIENT: The Flamemaster Corp. DATE: November 16, 1981 SAMPLE: Flamemastic 77 Coating THICKNESS: 1/8" Wet film FLAME SPREAD: Ignition 58 Seconds 1 Minute Flame Front 2 1/2 ft. max. Time to Max. Spread 57 Seconds cciculatilon 21.67 x.515 = 11.'16 Test Duration 10 Minutes l

SUMMARY

( FLAME SPREAD BY: ASTM E-84-80 10 FUEL CONTRIBUTION: 9 SMOKE DENSITY 30 ' OBSERVATIONS Considerable bubbling of the coating surface preceded a cample ignition time of 58 seconds. A maximum flame front advance of 2 was observed about 1 minute after ignition. Total delamination of the coating in the flame but impingement area occurred shortly af ter 2 minutes, did not enhance the flame front. No afterburning noted at test conclusion. Page 5

~ dita ecmpany REPORT ON FLAME TEST CONDUCTED ON CABLE AND RACEWAY SYSTEM October,19,1977 TEST NO. 77 VG-48-C Ref. No. 3

1. OBJECTIVE Jhe objective of this flame test is to demonstrate that the cable and raceway, o t:sted, will not propagat e a fire when exposed to an IEEE 383-74 flame Jource.

?). CABLE AND RACEWAY TESTED 9/c (12 and 4/c (10,1 KV, polyethylene insulation, PVC jacketed cable hstalled in a steel vent tray with a steel rib cover (to simulate vent rib ) ray). The cables, tray, and cover were coated with Flamemastic. B. TEST FACILITY Jho t:st was conducted on September 6,1977 at The Kerite Company Fire Test Facility. An American Gas Furnace Company ten-inch wide ribbon burner was used to provide the flame source. A direct readout Omega pyrometer was used in conjunction with a thermocouple to monitor flame lemperature throughout the test. A laboratory timer was used to measure Bo duration of the test. The test specimen was installed in the 12-inch wide, 3-inch deep,11-foot high tray. A 240 volt power source was used to monitor he electrical integrity during the test. D. TEST PROCEDURE Two layers of 10 foot lengths of test cable were mounted in the tray with no bble spacings. Each layer consisted of 15 cables, half from each make-up, 21accd in an alternating sequence, for a total of 30 cables. Six cables were Mosen at random, three from each layer, and energized with the 240 volt mwcr cource. Pho flame source was adjusted so that the temperature was approximately 1500* F Lnd approximately 15 inches in length. Under dynamic conditions, the following nanometer readings were recorded for both air and fuelin centimeters of water: Air Fuel 4.7 2.8 1

LEPORT ON FLAME TEST 2. TEST NO. 77 VG-48-C lONDUCTED ON CABLE ~ sND RACEWAY SYSTEM October 19,1977 hess press'ures were measured for both air and fuel at the inlet of the mixer. Fhe flame source was placed on the front side of the tray at a three-inch $ctanco from the cables and allowed to burn for twenty minutes. At the nd of twenty minutes, the flame source was shut off and the cables 110wed to burn until they self-extinguished or were totally consumed. Lll partinent data was recorded. The temperatures indicated in the next <ction were measured by a thermocouple located 2-7/8" from the burner - ce. l

2. TEST DATA Time for specimen to ignite:

Within the first three minutes 1 Time specimen continued to burn after removal of flame cource: 5 minutes 1 Maximum length of sample damage: 48 inches J. Time for electrical breakdown: 9 minutes, 33 seconds (line one to ground) Heat input 61,300 BTU /hr. 0

(rita ocmpcny REPORT ON FLAME TEST 3. _ TEST NO. 77 VG-48-C CONDUCTED ON CABLE AND RACEWAY SYSTEM October 19, 1977 , (E - Test Data - Continued) 6. Minutes Flame Impingement Temperature (* F) Start 1400 1 1450 2 1350 3 1300 1 l 4 1250 5 1250 6 1250 I 7 1250 8 1250 9 1250 10 1250 11 1250 12 1250 l 13 1250 14 1250 15 1250 16 1250 17 1250 18 1250 l 19 1250 20 1250

F. ATTESTATION The above test was personally witnessed by the undersigned and the data presented Dbove is accurate and complete to the best of my knowledge and belief.

CAUnW~ JVO:me [/ John V. Osborn, Technician 7 D, // h [ f V APPROVED ~ Paul D. Basconi, Mechanical Eng. Bubscribed and sworn to before me this o75 day of O d d(u 1977. On w.A4Yf, // Notary Public My Commiction Expires March 31,1979

~ rita c mptny REPORT ON FLAME TEST CONDUCTED ON CABLE AND itACEWAr 6tbTEM October 19,1977 Test No. 77 VG 58-C Ref. No. 8

A. OBJECTIVE The objective of this flame test is to demonstrate that the cable and race-way, as tested, will not propagate a fire when exposed to an IEEE 383-74.

flame source. / ' B. CABLE AND RACEWAY TESTED Ssven conductor No.12 and four conductor No.10,1 KV, polyethylene in-sulation, PVC jacketed cable, installed in a steel vent tray with a vent rib cover (to simulate steel vent rib tray). C. TEST FACILITY The test was conducted on September 9,1977 at The Kerite Company Fire Test Facility. An American Gas Furnace Company 10-inch wide ribbon bumer was used to provide the flame source. A direct readout Omega pyrometer was ussd in conjunction with a thermocouple to monitor flame temperature through-out the test. A laboratory timer was used to measure the duration of the test. The test specimen was installed in a 12-inch wide, 3-inch deep,11-foot high f tray. A 240 volt power source was used to monitor the electrical integrity during the test. D. TEST PROCEDURE Two layers of 10 foot lengths of test cable were mounted in the tray with no cable spacings. Each layer consisted of fifteen cables, half from each , makeup, placed in an alternating sequence, for a total of thirty cables. Six cables were chosen at random, three from each layer, and energized with the 240 volt power source. - - - - - i

,3, Test No. 77 VG 58-C Ref. No. 8 The flame source was adjusted so that the temperature was approximately 0 p500 F and approximately 15 inches in length. Under dynamic conditions, the <ollowing manometer readings were recorded for both air and fuel in centi-meters of water: Air Fuel

4. 5

2. 9 These pressures were measured for both air and fuel at the inlet of the (mixer.

The flame source was placed on the front side of the tray at a 3-inch dis-

tance from the cables and allowed to burn for twenty minutes. At the end of itwenty minutes, the flame source was shut off and the cables allowed to burn juntil they self-extinguished or were totally consumed. All pertinent data was

' recorded. The temperatures indicated in the next section were measured by 7 a thermocouple located 2 /8" from the burner face. l lE. TEST DATA *

1. Time for specimen to ignite:

Within the first three minutes.

2. Time specimen continued to burn after removal of flame

) source: Was not recorded. 3. Maximum length of sample damage: Cable samples totally consumed.

4. Time for electrical breakdown:

4 minutes, 45 seconds (Line two to ground) 5 minutes, I second (Line one) i

5. Heat input 63,000 BTU /hr.

CBacause of the severity of the smoke and fire, the test was halted at 15 minutes. 'T

its ccmpcny - Test No. 77 VG 58-C Ref. No. 8 l Test Data cont'd) 6. Minutes Flame Impingement Temperature ( F) Start 1450 1 1150 2 1150 3 1225 4 1250 5 1250 6 1225 ~ 7 1225 8 1275 9 1275 10 1225 11 1225 12 1300 13 1350 14 1400 15 1450 T1. ATTESTATION The above test was personally witnessed by the undersigned and the data pras:nted above is accurate and complete to the best of my knowledge and balici. I f M JVO/dm nn V. Osbofn, Technician r APPROVED L V, 4(A4&w Paul D. Basconi, Mechanical Engineer Bubscribed and sworn to before me this ofS day of o f. f,. /,, j ,1977. 03&LK. Y ffs // Notary Public t.1y Cc::..n:: don Expires thrch 31,1979 T

APPENDIXC C0tPLIANCE STATUS DOCKETNO. 50-2145 JULY,1982

~. FIRE CURRENT WILL EXEMPTION ZONE COMPLIANCE COMPLY REQUESTED PROPOSED HODIFICATIONS R-1 / None R-2A

• Enclose DC control power feed from MCC-DC-llAl to MCC-2-3 with a 1 hr j

fire barrier. Install fire stops in intervening cable trays. R-2B / Enclose DC ' control power feed from MCC-DC-llA-1 to MCC-2-3 and from DC-1A to MCC 11A-1 with a 1 hr fire barrier. R-2C / Enclose DC power feed from DC-11A to MCC-DC-11A-1 with a 1 hr fire barrier. R-2D Enclose DC power feed from DC-1A to MCC-DC-11A-1 with a 1 hr fire rated barrier. y R-5 / None R-6 / None R-7 / None R-8 / None R-9 / None R-12 / None i l R-14 / None R-17 wr None l R-19 / None { T-5A / None i i T-5B / Reroute 4KV Bus #6 tie to 489V #2A. Provide a 1-hour fire barrier around diesel generator power and control cables.

wesurmuuan.m wavauwe wuuas vanrwavuu m FIRE CURRENT WILL EXEMPTION ZONE COMPLIANCE COMPLY REQUESTED PROPOSED MODIFICATIONS T-5C v Enclose AC power feed from 480V #2A to MCC-22A-1 with a 1 hour fire barrier. Install fire stops in intervening cable tray. T-6 / None T-7 / None T-9 y Provide shielding to Gas Turbine Cables J Stock spare parts (connectors-cabling) required to support T-10 post fire repairs to cold shutdown equipment. l Repair procedures will be implemented to assure that l cables needed for cold shutdown will be repaired promptly. T-15B J None T-16 J Install an automatic fire suppression system. . Customized administrative controls will be implemented to minimize introduction of flammable liquids in the cable unit. T-17 J Provide a one hour fire barrier around S-2 power train control cables and normal (S-2) DC feed to Distribution Panel DC-IIA-2 (ADS Valves). J Enclose train S-2 cable tray with I hour rated fire T-19A barrier from fire zone T-19B to a point twenty feet past the S-1 switchgear. A water curtain spray system will be installed to provide separation between redundant 4kV and 480V SWCR. Install fire stops in intervening cable trays.

~ ' LUTITI,1 AITLr ' JI AIU3 Wiln Arrr.NUIA R FIRE CURRENT WILL EXEMPTION ZONE COMPLIANCE COMPLY REQUESTED PROPOSED MODIFICATIONS T-19A A curb / dike will be installed to assure that a flammable liquid spill would not effect redundant 4kV and 480V SWCR. Enclose the AC feeder from 480V #2 to MCC 2-5 with a one hour rated 1-19B y fire barrier from fire zone T-19A to fire zone T-19C. A water curtain spray system will be installed to provide separation between fire zone T-19B from T-19A and T-19C. Curbs / dikes will be installed to separate fire zone T-19B from T-19A and T-19C. T-19C Enclose the cables listed below in a 1 hr fire barrier. a) DC-1 feed to dist. pnl. DC-llA-2 (ADS Valves) b) DC-1 feed to MCC-DC-11A-2 (Iso. Cond. 1-IC-3 Valve) c) DC Control Power feeds to 4kV Emer. Bus #6 and 480V load center

1. 2A (S2 safe-shutdown options) d) 480 VAC load center #2A feed to MCC-2A-4 (S2 DC Power) e) 480 VAC feed from MCC-2A-4 to Battery Charger #1 (S2 DC Power for S2 safe-shutdown options) f) Emergency Service Water Pumps A&C and Service Water Pump D power cables from 4kV switchgear #6 (S2)

Install fire stops in intervening cable trays. Install a water curtain spray system to separate Fire Zone T-19C from T-19B. Install a curb / dike to separate Fire Zone T-19C from T-19B. T-19D / Enclose the cables listed below in a 1 hr fire barrier. a) DC-1 feed to dist. pnl. DC-11A-2 (ADS Valves) b) DC-1 feed to MCC-11A-2 (Iso. Cond.1-IC-3 Valve)

COMPLIANCE STATUS WITH APPENDIX R FIRE CURRENT WILL EXEMPTION ZONE COMPLIANCE COMPLY REQUESTED PROPOSED MODIFICATIONS T-19D c) DC Control Power feeds to 4kV Emer. Bus #6 and 480V load center

1. 2A (S2 safe-shutdown options) d) 480 VAC load center #2A feed to MCC-2A-4 (S2 DC Power) e) 480 VAC feed from MCC-2A-4 to Battery Charger #1 (S2 DC Power for S2 safe-shutdown options)

T-19E / Reroute (S-2) cables and run in a common protected conduit as proposed in fire zone T-19C discussion. The conduit shall be run in such a manner as to provide a minimum of twenty feet separation for 4kV Bus #7 (S-1) and its bus duct tie to Bus 4kV #3. I Provide a rated fire barrier around the power feed from MCC 2A-4 to Battery Charger #1 as shown in Drawing 34014. T-21 Customized administrative controls will be developed to assure that no flammable liquids are allowed inthe control room. Fire rated dampers or equivalent will be installed on louvered openings of the main control board and its auxiliary cabinets. All openings between the cabinets and the floor that would allow a spilled flammable liquid to enter the cabinets will be sealed. Ramps (1/8"/ foot) will be installed to divert spilled flammable liquid away from required auxiliary cabinets. T-22 / None T-23 / None T-24 y None l GT / None SH / None MODIFICATIONS RESULTING FROM ASSOCIATED CIRCUITS REVIEW-NONE}}