Text

Forwards Discussion of Known Deviations from 10CFR50,App R (Generic Ltr 83-33) & Guidance on App R,Except for Control Ctr Complex.Deviations Include Justification Showing Equivalent Level of Fire Protection Provided
	ML20094D250
Person / Time
Site:	Fermi
Issue date:	08/03/1984
From:	Jens W; DETROIT EDISON CO.
To:	Youngblood B; Office of Nuclear Reactor Regulation
References
	EF2-72717, GL-83-33, NUDOCS 8408080305
	Download: ML20094D250 (113)
	v • d • e

_ _ _ _ _ _ _. _ _ _ _ _ _. _. _. _ _ _. _

i t?ayu H. Ana Vice Prevd?M Nuc: ear Creatow j

Detroit

'"*'-2 6400 Norm O Edison ram,xieH-g9way Aueest 3, 1984 E F2-72 717 Director of Nuclear Reactor Regulation Attention:

Mr.

B.

J.

Youngblood, Chief Licensing Branch No. 1 Division of Licensing U.S.

Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Mr. Youngblood:

Reference:

(1)

Fermi 2 NRC Docket No. 50-341 (2)

NRC Generic Letter 83-33, "NRC Positions on Certain Requirements of Appendix R to 10CFR50", October 19, 1983 (3)

IE Information Notice No. 84-09, " Lessons Learned from NRC Inspections of Fire Protection Safe Shutdown Systems (10CFR50, Appendix R)",

February 13, 1984 (4)

Detroit Edison to NRC Le t te r, " Transmittal of Fire Protection Information",

EF2-69218, dated August 4, 1984

Subject:

Submittal of Deviations from Staff Inter-pretations of Fire Protection Features in 10CFR50, Appendix R and Justification References (2) and (3) provided further information con-cerning NRC staff interpretations and positions relative to 10CFR50, Appendix R.

As discussed with your staff in various meetings and workshops, it was recommended that NTOL plants also review their fire protection features against the referenced guidance and submit for staff review information and justifications for any deviations from such guidance.

Accordingly, please find attached the known l

deviations at Fermi 2 from Appendix R and the staff guidance on Appendix R except for the schedular deviation for the control center complex which will be addressed in a separate transmittal.

The deviations include justification to show that an equivalent level of fire protection is provided.

For convenience, the attached deviations are broken down as follows:

8408080305 840803

/

PDR ADOCK 05000341 QQk F

PDR

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^

Mr.

B.

J.

Youngblood:

August 3, 1984 EF2-72717 Page 2 Attachment I -

Deviations due to variances to the automatic suppression criteria or intervening combustible criteria.

Attachment II - Deviation for the 3M one hour protec-tive envelope to show equivalence to a one hour fire rated barrier.*

See reference (4) for more detailed information concerning the test results for the 3M one hour protective envelope.

In addition, Attachment III provides an engineering analysis of fire zones which are not enclosed by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barriers.

This is primarily due to unprotected openings or non-rated doors and hatches.

The analysis is provided to support the equivalence of the zone boundaries defined in FSAR Section 9B (developed in conformance with Appendix A to BTP9.5-1) to the fire areas defined in 10CFR50, Appendix R.

In view of the fact that some of the deviations contain commitments for certain plant modifications, your expedited review is requested.

FSAR changes arising from the attached deviation requests will be included in a forthcoming amendment.

If you have any questions, please contact Mr. Keener Earle at (313) 586-4211.

Sincerely, n

/

us 1

/

t (g tu cc:

Mr.

P.

M.

Byron

Mr.

M.

D. Lynch

Mr.

R.

Eberly*

USNRC, Document Control Desk

Washington, D.

C.

20555

With Attachments l

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DEVIATIONS FROM 10CFR50 APPENDIX R--

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Intervening Combustible Criteria)-

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-NOTES 1)

The type of cable insulation used is primarily ethylene propylene.

Cables have overall fire retardant jackets-of Neoprene or Hypalon.

Cables;have been type-tested in accordance with the flame test of Detroit Edison's Company Specification 3071-80 and are certified to be of fire retardant construction. This is -equivalent to the IEE-383 test.

2)

A third alternative.for shutting down the plant, utilizing an existing emergencyLcore cooling system, is being added to the Appendix R Analysis. For hot shutdown this method consists of manually depressurizing the reactor utilizing safety relief valves to remove steam (B21 System) and the core. spray system (E 21 System) to provide water to the reactor. For cold shutdown, one of two methods may be used. The first (and preferred) method utilizes the RHR shutdown cooling mode as described in the. Fermi 2 FSAR. The second method would utilize the core spray system to provide cooling water from the

- torus to the reactor, the SRVs to return that water to the torus, and the RHR torus cooling mode to remove heat from the torus. This alternative will be utilized in zones where HPCI and RCIC equipment cable locations has caused an interaction problem. The E 21 system equipment has been installed in the Reactor Building completely divisionally. Division I equipment is located on the north side while Division II eo tipment has been located on the south side.

3)~

A fourth alternative for shutting the plant down is to use an alternate shutdown path using the standby feedwater system. This capability will be available by startup af ter the first refueling outage. See DECO letter 72718 for more information on this concept.

4)

Abbreviations:

Appendix R = "R" Non Appendix R = Non "R" Intervening Combustibles = I.C.

5)

Except for sketchs 3.4, 6 and 10, the sketches are portions of the Appendix R drawings which were previously submitted.

6)

For unsealed opening in walls and floors see " Engineering Analysis for Zone Boundaries" which is included with this submittal

( Attachment III).

7) 4 deviation requests were submitted on March 1, 1983 (EF2-61562).

Three of the deviations, Zone.5 Auxiliary Building, Zone 13 Auxiliary Building, and Division II Control Center HVAC Room have been modified and are included in this package. The fourth, relay room stairwell is being withdrawn from consideration.

8)

For doors in the summary sheets, the type of door is given first and the adjacent zone is given second.

"A" means the door has a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months i

fire-resistance.

"B" means the door has a 1 1/2 hour fire resistance.

1 I

100/R264/1.1 080384

..7{

-FIRE ZONE

_1_

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Torus Room Reactor Building

+

Elevation:

540'-0" to 583'-6"

- Combustibles Electrical insulation 270,000,000 BTU

.De,s'ign Basis Fire Fire Loading 19.000 BTU /sq'. ft.

Fire Protection (Available)

Suppression:

Automatic Sprinkler / area wide Detection:

lonization detection (early warning)

Portable Extinguishers: '(4) Dry chemical / Zone 2 (4) CO / Zone 2 2

Hose Stations:

(4) Water / Zone 2 Fire Resistance Rating

()

Required:

.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual Walls minimum 36" thick reinforced concrete-exterior / North, South and West j -

Floor / Ceiling 24" thick reinforced concrete over Steel Beams ceiling i

concrete base mat floor Fixed Openings clear openings / Zone 5 (RB)

Scaled Penetrations 3-hour rated / steam tunnel all penetrations Fire etcp/ cable tray penetrations throu8h unrated l

barriers Unsealed i

Penetrations piping in unrated conduit barriers ventilation j

ducting l

Doors (4) water tight / Zone 2 (RB) 4 0

100/R264/1.2 072284 1

Fire Zone 1 Reactor Building 73 i u j-Appendix'R Drawing No. 6E721-2800-15, 16, 17, 18

SYSTEMS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE

-Div Div I

II B21 Main Steam Isolation Valves; X

X Safety Relief Valves (1) for Depressurizing

. Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

X X

C11 Control Rod Drive (Manual Scram Circuits Only)

Ell RHR; Service Water System, Cooling Towers, X

X Containment Cooling Mode and Shutdown Cooling Mode E41 High Pressure Coolant Injection X

E51 Reactor Core Isolation Cooling X

P44 Emergency Equipment Cooling Water P45-Emergency Equipment Service Water P50 Control Air (Control Center HVAC dampers)

X X

R14 ESF a-c Distribution System for Shutdown Equip R16 ESF a-c Distribution System for Shutdown Equip X

X i

R30 ESF a-c Distribution System for Shutdown Equip R32 ESF d-c System X

Os T41 Control Center HVAC System and ESF Fan Coil, Units for Areas Servicing Shutdown Systems X

X TSO Suppression-Pool Temperature Monitoring Equipment X

X X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System X

X f

I Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

i O

100/R264/1.3 i

073084

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-Fire Zone 1 Reactor Building

^

Appendix R Circuit / Component Protection:

= Statement of Problem Division I and II cables enter the torus room through the east' wall at approximately elevation 578 feet. Division I enters at approximately

~

' column line 12 and angles off to the north area over the centerline of

the torus. -It extends around to the northeast (RCIC) and the northwest. (RHR) corner rooms where appropriate Division I' cables enter the two rooms.

Division II trays enter at approximately column line 11.(approximately 122 feet from Division.I trays) and angle off to the south area over the centerline of the torus.. Division II extends around to the southeast (core spray) and southwest (RHR) corner rooms where

. appropriate cables enter the_ rooms.- Separation of Division I and II at the entry point.(G, 11-13) is greater than 20 feet with no intervening combustibles.

Balance of plant (BOP) cable trays enter and traverse parallel to Divisions I and II cable trays around the torus. On the west side, the BOP trays continue around the torus encircling the drywell and linking Divisions I and II with intervening combustibles.

Therefore, Intervening Combustibles are present between redundant safe shutdown' divisions.

The analysis below demonstrates that even'though this is a deviation from the specific criteria in Section III.G.2 of Appendix R, equivalent protection is provided when taking into account all factors.

Analysis The following provides justification demonstrating an equivalent level of protection to that of Appendix R Section III.G.2.

1.

Jus early warning smoke detection system is installed for assuring early detection and response by the plant fire brigade ensuring early fire extinguishment.

2.

A full zone automatic sprinkler system is installed in the upper level torus room.

3.

There are three 12" BOP cable trays interconnecting Divisions I and II on the west side and are considered Intervening Combust-ibles (I.C.).

The top tray (OP-016) is 20% filled by visual, the middle tray (OC-790) is approximately 5% filled (visual inspec-tion), and the lower tray (0K-097)has a 1% visual fill.

100/R264/1.4 080284'

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q Fire' Zone 1 Reactor Building Cont'd

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t There 'is 50 feet between redundant division cable trays and 40 ft. between divisional conduits on the veat side. The 3 BOP cable trays-pass'approximatelyl,4Lft. east of the' division II con-

'duits which will' provide protection from the small loadings in the trays. Therefore, for a fire to affect both divisions, it will have to trave 1Leore than 50 ft.

3

~

' Thel location of cable trays, 'over the top of' the torus (approxi-mately 35') significantly reduces the possibility of a fire on

.the lower level torus room causing a fire in the cable trays.

The torus room has a very large volume in which. heat from a fire

- can be dissipated. EPRI test at Factory. Mutual Laboratories have shown that cable - fires will.not propagate from short. circuits.

Division I and II' safe shutdown cables, which are located within

~- 10 feet of line 12.0 have been. provided with a 1-hour rated pro-tected envelope. Once in the' majority division areas (north of c line 12 Division I,' south of line 12 Division Ilj, the minority-

~ division has been provided with a 1-hour. rated. protective 1

envelope while in the majority division area. For. ins tances where minority division cables or equipment.is unprotected in the majority division area or a cable / equipment is unprotected in-the 20 ft. space around column line 12, a specific analysis and disposition _ has been completed on the circuits in question.

(See Attachment) 4.

The combustible loading of this zone;is low (19,000 BTU /sq. ft.).

l-The following modification will be installed, per a mutually t

agreed to schedule, upon acceptance of -the deviation:

For trays (2)' 0P-016 and OC-790 a tested fire break will be i

installed in the trays at approximately column line 12 + 3 feet.

l-(See sketch 1)

A break will not be installed in the third I.C. tray (OK-097) because instruments trays have been provided with metc1 covers and solid

bottoms, s

Conclusion

. With the installation of the proposed modifications and in combination l

with the existing fire protection features, an adequate level.of protection'is achieved.

I 100/R264/1.5 080384

(12"OP-01G1576;20% VISUAt 12"OC-790;57# 9';5% VISUA f{< l2'0K 097;573'-6';l%Yl3UAL 5f @

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FIRE BREAK LOCATION h FlRNRE NOTE:0K 097 HA5 METAL TOP 3 AND BOTTOMS I

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I APPENDIX a R" i

5.W. BASEMENT PLAN EL. 562' 0"

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Zone 1 Reactor Building Attachment

\\s' Equipment Analysis E4150F042-HPCI suppression pool suction inboard isolation valve and its associated conduits BB-0401-2P and BB-404-2C The1 valve is located 5 ft. south of column line 12.

The nearest Division I RCIC circuit is bB-021-2K.

This conduit is wrapped to a point 20 ft. north of column line 12.

There is a minimum of 20 f t.

seperation with no I.C.

Additionally the HPCI pump can take suction from the condensate storage tank which is controlled by valve E4150F004. This valve is located in the HPCI Room (Zone 3 R.B.).

Therefore, it is not necessary to provide protection for this valve and associated circuits.

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O<-~s 100/R264/1.58 072284

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. FIRE ZONE 2

' Northeast Corner Room Reactor Building

. Elevations:

'540'-0" and 562'-0" s

Combustibles Electridal Insulation 70,200,000 BTU-

=

Lubricatine. 011--

20,800,000 BTU 91,000,000' BTU:

l-Design Basis Fire Fire Loading 23,000 BTU /sq. ft.-

Fire Protection (Available)

Suppression:

Automatic Sprinkler / elevation 540'-0"

-Detection:

Ionization / sone wide (early warning)

Portable Extinguishers:

(1) Ery chemical j

(1) CO2 Hose Stations:

(2) water Fire Resistance Rating j

Required:

0.30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months j

Actual: Walls -

minimum 36" reinforced concrete Floor / Ceiling 24" reinforced concrete (562' floor) j-concrete base mat floor stairwell / Zone 5 (RB) t Fixed Openings l

metal hatch / Zone 5 (RB)

Sealed Penetrations Fire stops / cable tray penetrations through j

unrated barriers Unsealed-Penetrations 2 ventilation ducting

[

in unrated pressure relief penetrations j

barriers conduits piping j

1.

This represents the total loading for all four cornet rooms.

1

- 2.

Penetrations in the corner rooms are sealed for ventilation and radiation purposes. The seals are not fire-rated.

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' 100/R264/1.6 072284

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Fire Zone 2 NE Reactor Building

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water Light / Zone 1 (RB)-

Doors unrated (atl)/ Zone 4 (RB)

'A/ Zone 1 (AB) c Appendix'R' Drawing No. 6E721-2800-14, 15

SYSTEMS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE Div Div I

II B21 Main Steam Isolation Valves; X

X Safety Relief Valves (I) for Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

X X

C11 Control Rod Drive (Manaul Scram Circuits Only)

Eli RHR: Service Water System, Coolin6 Towers, X

X Containment Cooling Mode and Shutdown Cooling Mode E41 High Pressure Collant Injection X

3 E51 Reactor Core Isolation Cooling X

E56 RHR Cooling Towers

]

P44 Emergency Equipment Cooling Water P45 Emergency Equipment Service Water (s -)

P50 control Air (Control Center HVAC dampers)

X R14 ESF a-c Distribution System for Shutdown Equip R16 ESF a-c Distribution System for Shutdown Equip X

R30 ESF a-c Distribution System for Shutdown Equp R32 ESF d-c System T41 Control Center HVAC System and ESF Fan Coil, Units for Areas Servicing Shutdown Systems X

X TSO Suppression-Pool Temperature Monitoring i

Equipment X

X X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System X

X i

Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

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i Appendix R Circui*/ Component Protection:

Statement of Problem An area wide suppression system has not been provided for the north east corner room. The analysis below demonstrates that even though this is a deviation from the specific criteria of Appendix R, equiv-alent protection is provided when taking into account all factors.

Analysis The following provides justification demonstrating an equivalent level of protection to that of Appendix R Section III.G.2.c.

1.

An area wide early warning smoke detection system is installed for assuring early detection and response by the plant fire brigade ensuring early fire extinguishment.

2.

An automatic sprinkler system is provided on the 540'-0" eleva-tion for the RCIC pump and turbine room (major combustibles in zone).

3.

Division 11 "R" circuitry is wrapped within this room with a one hour protective envelope. If a Division II circuit / equipment is 7(d unprotected, then a specific analysis and disposition has been done for the circuit in question.

2 4.

The combustible loading in this room is low (23,000 BTU /ft ),

If the combustibles were totally consumed, they would produce a fire which corresponds to a fire severity on the ASTM time temperature curve of approximately 15 minutes.

Conclusion The installation of an automatic suppression system throughout the room would not significantly enhance the fire protection provided by the current configuration.

100/R264/1.8 072284

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FIRE ZONE 2

(

I-Southeast Corner Room Reactor Bui1 ding Elevations:

540'-0" and 562'-0" Combustibles Electrical Insulation 70,200,000 BTU Lubricating 011 20,800,000_

BTU 91,000,0001 BTU Design Basis Fire Fire Loading 23,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

None Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(1) Dry chemical (1) CO2 Hose Stations:

(2) water Fire Resistance Rating Required:

0.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

minimum 36" reinforced concrete Floor / Ceiling reinforced concrete (562' floor) concrete base mat floor Fixed Openings -

stairwell / Zone 5 (RB) metal hatch / Zone 5 (RB)

Sealed Fire stops / cable tray penetrations through unrated Penetrations barriers Unsealed Penetrations 2 ventilation ducting in unrated pressure relief penetrations barriers conduits piping watertight /1RB Doors watertight /3RB 540' nonrated (MN)/3RB 562' (v

100/R264/1.9 073084

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FIRE ZONE 2 Cont'd ut 1.

This loading represents the total for all four cc*ner rooms.

2.

Penetrations in the corner rooms are sealed for ventilation and

-radiation purposes. The seals are not fire-rated.

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IAppendix R Drawing No. 6E721-2800-15, 16

SYL v.MS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE Div Div I

II B21 Main Steam Isolation Valves; X

X Safety Relief Valves (I) for Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure' Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

X X

C11 Contrel Rod Drive (Manual Scram Circuits Only)

Eli RHR: Service Water System, Cooling Towers, X

X Containment Cooling Mode and Shotdown Cooling.

Mode E41 High Pressure Coolant Injection X

E51 Reactor Core Isolation Cooling X

P44 Emergency Equipment Cooling Water P45 Emergency Equipment Service Water P50 Control Air (Control Center HVAC dampers)

X R14 ESF a-c Distribution System for $hutdown Equip R16 ESF a-c Distribution System for Shutdown Equip X

R30 ESF a-c Distribution System for Shutdown Equip R32 ESF d-c System O

T41 Control Center HVAC Syrtem and ESF Fan Coil, Units for Areas Servicing Shutdown Systems X

X T50 Suppression-Pool Temperature Monitoring Equipment X

X X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray Systes X

Required in the case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

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O 100/R264/1.10 073084

p Fire Zone 2 SE Reactor Building

' Q.-

Appendix R Circuit / Component Protection:

Statement of Problem An area wide suppression system has not been provided for the south east corner room..The analysis below demonstrates that even though this is a deviation from the specific criteria of Appendix R, equiv-alent protection is provided when taking into account all factors.

Analysis The following provides justification demonstrating an equivalent level of' protection to that of Appendix R Section III.G.2.

1.

An area wide early warning smoke detection system is installed for assuring early detection and response by the plant fire brigade ensuring early fire extinguishment.

2.

This zone is a major Division II zone, Division I Appendix R circuitry is wrapped within this room with a one hour protective envelope.

If a Division I Appendix R circuit equipment is not protected, then an analysis has been done on the circuit in question.

n(/

2 3.

The combustible loading in this room is low (23,000 BTU /ft ),

If the combustibles were totally consumed, they would produce a fire which' corresponds to a fire severity on the ASTM time temperature curve of approximately 15 minutes.

Conclusion The installation of an automatic suppression system throughout the room would not significantly enhance the fire protection provided by the current configuration.

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100/R264/1.11 072284-

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s Corridor Area Reactor Building Elevations:

562'-0" and 564'-0" Combustibles Electrical-Insulation-120,000,000 BTU Design Basis Fire Fire Loading.

60,000 BTU /sq. ft.

Fire-Protection (Available)

Suppression:

Automatic Sprinkler System /562'-0" corridor Detection:

Photoelectric /564'-0" corridor (early warning)

Ionization /562'0" corridor (early warning)

(2) CO / Zone 2 RB Portable Extinguishers:

2 (2) Dry Chemical / Zone 2 RB 4 -

Hose Stations:

(2) water / Zone 2 RB (NE & SE)

'(1) water / Zone 3 RB Fire Resistance Rating ij' Required:

0.75 hour8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months 3-hour rated / Auxiliary Bldg. (Zone 1) and Turbine Actual: Walls Bldg.

36" reinforced concrete / Zones 1 and 2 Reactor Bldg.

1 j

Floor / Ceiling 3-hour rated Fixed Openings metal pressure relieving hatch / Turbine Bldg.

l l

Sealed 3-hour rated /through rated walls j

Penetrations l

Fire stops / cable trays penetrations through j

unrated barriers i

i Unsealed Penetrations piping in unrated ventilation ducting barriers conduits pressure relief penetrations

[

Doors A/ Turbine Bldg.

non rated (MTL)/ Zone 2 NE Corner Room l

l non rated (MTL)/CRD Pump Room 100/R264/1.12 073084-i

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Fire Zone 4 Reactor Building i

Appendix R Drawing No. 6E721-2800-15, 16

SYSTEMS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE Div Div I

II B21 Main Steam Isolation Valves;-

X Safety Relief Valves (1) for Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

C11 Control Rod Drive (Manual Scram Circuits Only)

Ell RHR; Service Water System, Cooling Towers,

.X X

Containment Cooling Mode and Shutdown Cooling Mode E41 High Pressure Coolant Injection X

E51 Reactor Core Isolation Cooling X

P44 Emergency Equipment Cooling Water P45 Emergency Equipment Service Water P50 Control Air (Control Center HVAC dampers)

X X

R14 ESF a-c Distribution System for Shutdown Equip R16 ESF a-c Distribution System for Shutdown Equip X

R30 ESF a-c Distribution System for Shutdown Equip R32 ESF d-c System X

4

\\

T41 Control Center HVAC System and ESF Fan Coil, x

Units for Areas Servicing Shutdown Systems X

X TSO Suppression-Pool Temperature Monitoring, Equipment X

X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System X

X Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

I i

U 100/R264/1.13 073084

Fire Zone 4 Reactor Building (3

i I

Appendix R Circuit / Component Protection:

Statement of Problem An area wide suppression system is not provided throughout this zone.

In addition, intervening combustibles (cables) are present between Appendix R shutdown divisions. The analysis below demonstrates that even though this is a deviation from the specific criteria of Appendix R, equivalent protection is provided when taking into account all factors.

Analysis The following provides justification demonstrating an equivalent level of protection to that of Appendix R Section III.G.2.

1.

An area wide early warning smoke detection system is installed for assuring early detection and response by the plant fire brigade ensuring early fire extinguishment.

2.

Automatic sprinklers are installed in the north-south corridor, (562') in the area of the cable trays (combustible loading for the room is concentrated in this area). There is no automatic sprinkler system in the east-west corridor (combustible loading

[}

is insignificant in this area). There are no shutdown cables in the area where automatic sprinkler protection has not been v-s provided.

3.

Division I circuitry is concentrated north of column 12 in this zone. Division II circuitry is concentrated south of column 12 in this zone.

4.

Whenever Divison I Appendix R circuitry is within 20 feet of Divison II Appendix R circuitry a 1-hour protective envelope is provided or an analysis is completed justifyin8 that no protec-tion is required.

5.

The intervening combustibles in this zone consist of 2 -12 inch non-Appendix R trays (OP-020 and OC-785) which enter from the Torus Room (Zone 1) south of column line 12, extend east into Zone 4 approximately 7 feet and then are routed north.

Additionally a 12 inch non-Appendix "R" (non "R") instrument tray (OK-034) is located approximately 10 feet south of the 2 -12 inch non "R" trays. Since the instrument tray has a solid metal cover and bottom it is not considered an intervening combustible. An approximate 10 feet clear space exists between Division II "R" tray 2K-007 and the 2 non "R" trays which have fills of 40% and 60% by visual inspection. The 2K-007 tray has a solid metal cover and bottom. Two other Division II "R" trays are located approximately 14 feet to the south of the 2 non "R"

trays.

-s 100/R264/1.14 l

073084 i

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x. s All trays run horizontal which causes a slow burning fire with smaller heat releases. An early warning smoke detector is located directly above the non "R" cable trays near the entry and turning locations. Also, automatic sprinklers are located in this same area.

These non "R" trays represent the only in-situ intervening com-bustible path between Divison I and II cables. For a single fire to affect both Division I and 11 cables, a cable tray fire must burn more than 20 feet and must traverse a clear space of approx-imately 10 feet.

The following modifications will be installed, per a mutually agreed to schedule, upon acceptance of the deviation:

1)

For trays (2) OP-020 and OC-785 a tested fire break will be installed in the trays at approximately column line 12 + 3 feet north.

(See sketch 2) 2)

Additional sprinkler heads will be installed below the pipe obstructions to improve sprinkler coverage of the area.

(See sketch 3) q 3)

One (1) additional head will be provided to improve the Q

coverage over the metal pressure relief hatch.[See (1) on' sketch 4)

Conclusion With the installation of the proposed modifications, and the er.isting fire protection provided, an adequate level of protection is achieved.

)

i 100/R264/1.15 073084

o 4

~

~.

FIRE ZONE 5

x First Floor Peactor Building E12vation:- 583'-6" Combu s t ib.t us, Electrical Insulation 472.000,000 BTU Transient Combustibles- (anticipated) 96,800,000 BTU 368,800,000 BTU Design BLeis Fire Fire Loading

.30,000 BTU /sq. ft.

Fire Protection (Available[

Suppression:

Automatic Spribkler/ column lines (A-B, 9-13)

Detection:

Ionization / zone wide (carly warning)

IIcat/ column lines (A-B, 9-13) (ently warning)

Portsble Extinguishers 4 (3) Dry chemical (3) CO2

(

llose Stations:

(4) water Fire Resistance Pating Required:

.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months 3-hour rated / east Actual:

Walls exterior / north, west, south 1*loor/ Ceiling 24 inches reinforced concrete floor 12 inches reinforced concrete ceiling Fixed Openings (5) open stairwells / Zones 2 (RB) and 6 (RB)

(2) e. lear opening / Zone 6 (RM)

(2) concrete hatches /Zono 1 (RB)

(4) metal hatch / Zone 2 (RB)

(3) pipe chases / Zone 6 (nB)

Scaled 3-hoar rated /through rated walls Penetrations Fire stops /cshle tray penetrations through unrated barriers Unsealed piping Penetratios.e ventilation Jucting in unrated conduits es barriers l

1 blast restatant/stene tunnel

~'

Doors 100/R264/1.16 073084

(.

I

'^'

Fire Zone 5 Reactor Building i

8J Appendix R Drawing No. 6E721-2801-15, 16, 17, 18

SYSTEMS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE Div Div I

II B21 Main Steam Isolation Valves; X

X Safety Relief Valves (I) for Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentaion B31 Recirculation (Inboard Isolation Valves Only)

X X

C11 Control Rod Drive (Manual Scram Circuits Only)

Eli RHR; Service Water System, Cooling Towers, X

X Containment Cooling Mode and Shutdown Cooling Mode E41 Hikh Pressure Coolant Injection X

E51 Reactor Core Isolation Cooling X

P44 Emergency Equipment Cooling Water X

X P45 Emergency Equipment Service Water P50 Control Air (Control Center HVAC dampers)

X X

R14 ESF a-c Distribution System for Shutdown Equip X

X R16 ESF a-c Distribution System for Shutdown Equip X

X R30 ESF s-c Distribution System for Shutdown Equip X

f)

R32 ESF d-c System X

X

\\- '

T41 Control Center NVAC System and ESF Fan Coil, Units for Areas Servicing Shutdown Systems X

X T50 Suppression-Pool Temperature Monitoring Equipment X

X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System X

X Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

i f

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100/R264/1.17 073084

.. ~

~

39

(

+,N Fire Zone 5. Reactor Building W - (n).

'LJ

' Appendix R Circuit / Component Protection:

' Statement of Problem A full area suppression system has not been provided in this zone..

.The analysis below demonstrates that even though this is a deviation

.from the specific criteria of Appendix R, equivalent protection is

.provided when taking in account all factors.

Analysis The following provides justificatici demonstrating an equivalent level of protection to that of Appendix R.III.G.2.c.

1.

An area wide early warning smoke detection system (except for Railroad Bay) is installed for assuring early detection and response by the plant-fire brigade ensuring early fire extinguishment.

2.

An automatic spritikler system is installed in the railroad bay (column AtB,'9f13).

3.

A heat ietection systen is' installed in the railroad bay (column

/]

lines' B, 9-13).

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4.

There is greateo than 20 f eet seperation with no intervening combutibles betwee'n Division I and II "R" circuits in the Rail-road Bay-within the zone between column lines A-B; 11-13.

5'. S The notth end of this zone (columns 12-17) is a Division I "R" majority area while'the south end (columns 9-12) is a Division II "R" majority area. The m'inority division will be protected with

.a one hour protective envelope while in the majority area. Both

-divisions are protected if located within 10 ft. either side of column 12 (2d ft.).

For instance.S where a divisional cabit. or equipwnt should hace be, protected but was not, a specific analysis and.dispcaition'has'been completed on the circuits in l

questions.

I 6.

The drywall and rteam tunnel, valle..prdvide fire barriers at least

> 4quivalent-to 3-hour rated barriera.

l 7

The cor.bustible Icading of'the zone is low (30,000 BTU /ft ),

2

_C__onclus ion

'the installation of an adtomttie suppression system throughout the room would not significantly enhance the fire protectioi provided by 7

the current configuration.s 100/R264/1.18.

t 07,2284 N

/

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j 4-.

ft 1-

^

Second Floor Reactor Building Elevation:

613'-6" Combustibles Electrical Insulation 218,000,000 BTU Lubricating 011

___ 760,000 BTU 219,000,000 BTU Design Bas'is Fire Fire Loading 14,000 BTU /sq. ft.

Fire Protection (Available)

. Suppression:

Automatic sprinklers /over cable trays on east' wall between column lines 10-12 Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(3) Dry chemical (3) CO2 Hose Stations:

(5) water Fire Resistance Rating Required:

0.25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

3-hour rated / Auxiliary Building and Steam Tunnel exterior / north, south, west Floor / Ceiling 12" thick reinforced concrete Fixed Openings -

(1) stairwells / Zones 5 (RB) and 7 (RB)

(1) stairwell / Zone 5 (RB)

(1) stairwell /Zune 7 (RB)

(3) pipe chases / Zone 5 (RB) and 7 (RB)

(2) clear openings / Zones 5 (RB) and 7 (RB)

Sealed Penetrations 3-hour rated / Auxiliary Building and Steam Tunnel Fire stops / cable tray penetrations through unrated barriers Unsealed

' piping l

Penetrations l'

Lin unrated

' ventilation ductinu 1

barriers conduits Doors A/ Zone 6 (AB) t-100/R264/1.19 073084

a.,

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Fire Zone 6 Reactor Building

-V-Appendix R Drawing No. 2802-13, 14

SYSTEMS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE Div Div I

II B21 Main Steam Isolation Valves; X

X Safety Relief Valves (I) for Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

X Cll Control Rod Drive (Mar.ual Scram Circuits Only)

Ell RHR; Service Water System, Cooling Towers, X

X Containment Cooling Mode and Shutdown Cooling Mode E41 High Pressure Coolant Injection X

E51 Reactor Core Isolation Cooling X

P44 Emergency Equipmant Cooling Water X

X P45 Emergency Equipment Service Water P50 Control Air (Control Center HVAC dampers)

X R14 ESF a-c Distribution System for Shutdown Equip X

X R16 ESF a-c Distribution System for Shutdown Equip X

X R30 ESF a-c Distribution System for Shutdown Equip X

-(s)

R32 ESF d-c System

~

X

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T41 Control Center HVAC System and ESF Fan Coil, X

X Units for Areas Servicing Shutdown Systems T50 Suppression-Pool Temperature Monitoring Equipment X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System X

X Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

l 1

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100/R264/1.20 073084 L._<

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APPENDIX 'R

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5 W.- SECOND FLODE PLAN s

EL. (ol3'-W

-MAX.13'BETWEENSPRINKLERS

-MAK,10MTWEEN LINES

-M5IGN VOR ALL SPRINKLERS FLDWING 20 PSI END HEAD PRE 55URE

-C/DSED HEAD SPRIMLERS-I(o5'F RATEl

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-s.

Fire Zone 6 Reactor Building Q)

Western side of Reactor Building 1.

An area wide early warning smoke detection system is installed' for assuring early detection and recponse by the plant fire brigade ensuring early fire extinguishment.

2.

Division I circuitry and equipment are concentrated in the northern portion of this floor. Division I conduits also run north-south along the west wall.

3.

There are three non-safe shutdown trays (OP-037, OC-060 and OK-066) which are routed north-south along column line B.

These trays represent the only intervening combustibles which could propogate a fire between Division I and II "R" circuits.

4.

The location of the non-safe shutdown trays near the ceiling (approximately 25' off floor) significantly reduces the possibil-ity of a fire on the second floor of the Reactor Building causing a' fire in the trays above. Because of the fire retardant con-struction of cables, a significant exposure fire is required for cable ignition. EPRI tests at Factory Mutual Laboratories have shown that cable fires will not propagate from short circuits.

5.

Combustible loading for the zone is low (14,000 BTU /ft2),

(

6.

For a single fire to affect both divisions a cable tray fire would have to burn a minimum of 35 feet.

The following modifications will be installed per a mutually agreed to schedule, upon acceptance of the deviation.

1)

East Side Reactor Building - For trays (2) OP-047 and OC-793 a tested fire break will be installed in the trays approximately 3 ft. south of column line 12.

(See sketch 5) 2)

West Side Reactor Building - For trays (2) OP-037 and OC-060 a tested fire break will be installed in the trays at approximately 12 ft south of column line 12.

(See sketch 6)

NOTE:

The two instrument trays OK-069 and OK-066 will not have fire breaks installed because of metal tops and solid bottoms.

3)

Sprinkler protection will be installed on the West Side of the Reactor Building between column line A-C, 12.

(Sketch 7)

Conclusion

)

With the installation of the proposed modifications and the existing fire protection provided, an adequate level of protection is achieved.

100/R264/1.22 073084

[-

. o

+

Zone 6 JReactor Building

EQUIPMENT ~ ANALYSIS s

,hi n

11);

P44N401A/DD039-1K - Division I EECW' inlet temp monitor required for Shutdown Equipment Room Eoolers.-

2);

P4400F602A/CC-021C -: Division I EECW valve required for Shatdown.

Equipment Room Coolers.

This. Division I Equipment ~is. locate'd approximately 5 to 7 ft. south of.

Leolumn.Line'12'which places them in a major Division'II area.

"Approximately 32 ft. separate Division II Equipment from this

, Division I Equipment. Tray OP-037 (Intervening Combustibles).is

' routed approximately 18 ft away from the. equipment. With the proposed sprinkler system and' fire breaks a fire would not' affect both.

Divisions. =The Redundant Division'II EECW equipment is located over 80 ;f t away. : Therefore cable / equipment protection is adequate -as is.

s l-I i.

100/R264/1.23 Attachment l'-

l

' 080284 Page 1 of 1 1

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Third Floor Reactor Building Elevation:

641'-6" Combustibles Electrical Insulation 296,000,000 BTU Lubricating 011 304,000 BTU Transient Combustibles (anticipated) 95,800,000 BTU 392,104,000 BTU Design Basis Fire Fire Loading 29,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

None

. Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(5) Dry chemical (3) CO2 Hose Stations:

(4) water Fire Resistance Rating Required:

0.45 hour5.208333e-4 days 0.0125 hours 7.440476e-5 weeks 1.71225e-5 months Actual: Walls -

exterior / north, west, south 3-hour rated / east Floor / Ceiling 12 inches reinforced concrete floor 12 inches reinforced concrete ceiling Fixed Openings -

(4) stairwells / Zones 6 (RB) and 8 (RB)

(2) clear openings / Zone's 6 (RB) and 8 (RB)

(2) pipe chases / Zones 6 (RB) and 8 (RB)

Sealed Penetrations 3-hour rated /through rated barriers Fire stops / cable trays penetration through unrated barriers 3-hour rated / Zone 8 Auxiliary Building Unsealed Penetrations piping in unrated-conduit barriers ventilation ducting Doors None 100/R264/1.24 072284

F.

Fire Zone 7' Reactor Building (G

).

- Appendix "R" Drawing No. 6E721-2803-10,11

SYSTEMS REQUIRED FOR HOT OR COLD-SHUTDOWN INF FIRE ZONE Div Div I

II B21.

Main Steam Isolation Valves; X

~

Safety Relief. Valves (I) for Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

X X

Cll Control Rod Drive (Manual Scram Circuits Only)

Ell RHR; Service Water System, Cooling Towers, X

Containment Cooling Mode and Shutdown Cooling Mode E41 High Pressure Coolant Injection X

E51 Reactor Core Isolation Cooling X

P44 Emergency Equipment Cooling Water P45 Emergency Equipment Service Water P50 Control Air (Control Center HVAC dampers)

R14 ESF a-c Distribution System for Shutdown Equip R16 ESF a-c Distribution System for Shutdown Equip R30 ESF a-c Distribution System for Shutdown Equip R32 ESF d-c System Os T41 Control Center HVAC System and ESF Fan Coil, Units for Areas Servicing Shutdown Systems T50 Suppression-Pool Temperature Monitoring Equipment X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System X

Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

l 100/R264/1.25 073084

rn

(~'}

Fire Zone 7 Reactor Building

\\d Appendix R Circuit / Component Protection Statement of Troblem An area wide suppression system is not provided for this zone. The analysis below demonstrates that even though this is a deviation from the specific criteria _of Appendix R, equivalent protection is provided when taking into account all factors.

Analysis The following provides justification demonstrating an equivalent level of protection to that of Appendix R,Section III.G.2.

1.

An area wide early warning smoke detection system is installed for assuring early detection and response by the plant fire

~

brigade ensuring early fire extinguishment.

2.

North of column 12 is a major Division I "R" area while south of column line 12 is a major Division II "R" area. The minority division is protected by a one hour protective envelope unless an analysis and disposition has been completed (see Equipment Analysis).

-I )

3.

In-situ intervening combustibles which provide a fire propagation path between redundant divisions are not present.

4.

One passive means (20 ft. of separation) and one active means (ionization detection) is provided for this zone.

2 5.

The combustible loading in this zone is low (29,000 BTU /ft ),

6.

Vertical tray covers will be provided on the vertical tray risers located at approximately F-13 (OP-123, OC-171 and OP-049).

Conclusion The installation of an automatic suppression system throughout the room would not significantly enhance the fire protection provided by the current configuration.

-v 100/R264/1.26

-073084

I s'

)

Fire Zone 7 Reactor Building Equipment Analysis E11 50F023 and associated conduits DD-004-2C and DD-002-2P (Division.II "R" equipment).

This valve is located approximately 20 f t. north of column 12 between columns B and C.

The conduits are routed south back into the major

-Division II area and remain there on this floor. There are no Division I "R" cables on the west side of'the Reactor Building. Any large openings which communicate with second floor Division I "R" are located approximately 50 ft.

away. Therefore, any fire in this area will only affect Divsion II equipment.

i O

100/R264/1.265 073084

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A' pendix LR' Circuit / Component Protection:

p St$tement of Problem.-

s r -

Intervening combustibles are'present'in the.20:ft. clearance between-

~

the shutdown divisions...The analysis below demonstrates that even-Lthough-this?is aHdeviation from the. specific criteria of' Appendix R.

. equivalent' protection is provided when taking'into account all' ifactors~.

'i l Analysis m

An equivalent _ level of protection to Appendix R Section III.G.2 is being provided~ based on the following:

1.

An, area-wide early warning smoke' detection system is installed

for assuring fearly -detection,and = response inr the plant fire brigade ensuring early fire extinguishment'.

2.

Jun automatic sprinkler system is' installed in the zone'at both the 551'_and 562' elevations.

3.-

Division' I and II control air _ equipment is separated inr a dis-tance of 65 feet. Loss of this equipment affects the control center HVAC. Jut alternative method of relay room cooling will be available.

2

. 4.

The combustible loading of the zone is low (80,000 BTU /f t ),

5.

This is a major Division I area. Division II conduits and cable trays are protected with a one hour protective envelope when they are within 20 f t. of Division I circuits.

At the south end of the zone (column G-H, 9-11) intervening combustibles in the form of cables, exist in the 20 f t. separation between divisions (see Drawing 6E-721-2800-16).

Three non-Appendix. R cable trays (OP-005, OC-017 and OC-018) are routed with-three Division II trays (2P-019, 2C-036 and OC-015).

Two of the non "R" trays have approximately 5% visual'and 1%

visual fill. The other non "R" tray (12 inch) (OP-005) is the

. top tray'of the six trays and has'a 30% visual fill of power cables. This group of six trays is routed within approximately 6 a'

ft. of-Division I trays before the Division I trays exit the zone. The Division II trays are wrapped until a 20 f t. ' separation exist between the divisions. Due to the light loading in the-trays, a minimum 6 ft. - clearance, automatic 1

i' sprinklers, a smoke detection system, and partial barriers to maintain a 20.ft.

separation between division wall to wall barriers would not enhance the fire protection in this area.

I' 100/R254/1.29 080284 t

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. Fire Zone 1 Auxiliary Building O.

The-other location where intervening combustibles exist is.at column lines G-H, 11-12, (see Drawing 6E7221-2800-16). Division II "R" trays and conduits are protected with a one hour protec-tive envelope when within 20 ft. of Division I circuits.

LApproximately 10 ft. of clear space exist between the two divisions with only tray OP-002 (40% visual fill; 12 inch), being routed thru this clear. space.

. Three non "R" trays run parallel' to the unprotected portion of the Division II "R" trays (20-026, 2C-035, 2K-011) in the area.

The first, a solid bottom, _ metal' cover instrument cray (OK-001)

(10% visual fill) is located adjacent to a Division II solid bottom metal covered instrument tray (2K-011). The other two non-R" trays (OP-005, OP-002) are located approximately 9 f t.

and.10 f t.

north of the instrument trays and are 12 inch power trays with visual fills of 40% and 25% respectively. The remainder of the I.C.

trays run perpendicular to the ' unprotected portions of the Division II trays and are approximately 10 ft. sway.. Tray. loading in the area is light with only one intervening trays exceeding 25% visual loading (40%).

Division II conduits BB040-2C is unprotected in this area and is located more than 20 f t.

from Division I circuits. The conduit is located approximately 14 ft. below the three non "R" trays in O

the area.

Due to the light loading, the high ceilings (unprotected portion of Division II trays 26 ft. of flocr), automatic suppression and smoke detection system wall to wall bariers would not enhance the fire protection features in the area.

The following modifications will be installed, per a mutually agreed to schedule, upon acceptance of the deviation.

For trays (3) OP-005, OC-017, and 0C-018 a tested fire break will be installed in the trays at approximately column line(s) 9 + 4 feet north, 11 + 24 feet west.

(See sketch 8)

Conclusion i

With the installation of the proposed modifications and the existing fire protection provided an adequate level of protection is achieved.

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- 100/R264/1.30 073084 l

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.v_

Mezzanine and Cable Tray Area Auxiliary Building Elevations:

583'-6" and 603'-6" Combustibles Electrical Insulation 424,000,000 BTU.

Design Basis Fire Fire Loading 71,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

Automatic Sprinklers / zone wide Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(2) Dry chemical Hose Stations:

(1) Water (2) Water / Turbine Building

()

Fire Resistance Rating Required:

1.0 hour0 days 0 hours 0 weeks 0 months Actual: Walls -

3-hour rated / north, south, east and west exterior / north and south Floor / Ceiling -

3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated ceiling Fixed Openings -

Concrete hatch / Zone 3 (Reactor Building)

Sealed Penetrations 3-hour rated Unsealed Penetrations none i

A/ Zone 3 (AB)

Doors (2) A/TB NR/Outside d

Appendix "R" Drawing No. 6E721-2801-15, 16 i

l l

' O 100/R264/1.31 073084 l

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Fire Zone 2 Auxiliary. Building Appendix R Circuit / Component Protection:

. Statement-of Problem Intervening combustibles are present between the shutdown divisions.

The analysis below demonstrates that even though this is a deviation from the specific criteria of Appendix R, equivalent protection is

.provided when taking into account all factors.

Analysis The following provides justification' demonstrating an equivalent level-of protection to that of Appendix R Section III.G.2.

1.

An area wide early warning smoke detection system is installed for assuring early detection and response by the plant fire brigade ensuring early fire extinguishment.

2.

Suppression in the form of an automatic sprinkler system is pro-vided throughout the zone both at the ceiling and into the trays near the floor (routed along the east wall).

2 3.

The combustible loading of this zone is low (71,000 BTU /ft ),

4.

Division I cabling required for safe shutdown is concentrated in the northwest corner of this zone.

5.

Division II cabling required for safe shutdown is concentrated in the southern end of this zone.

6.

Where Division II "R" cabling is routed in the northern end of this zone, within 20 feet of Division I "R" circuitry, it is wrapped. Divisional cable or equipment has been protected or a special analysis and disposition has been completed on the circuits in question.

7.

When Division I "R" cabling is routed in the southern end of this zone, within 20 feet of Division II "R" circuitry, it is wrapped.

Divisional cable or equipment has been protected or a special j

analysis and disposition has been completed on the circuits in question.

8.

In order for a single fire to affect both divisions it must burn a minimum of 20-feet. This fire would be a cable insulation fire since this is the only type of in-situ combustibles in this zone.

9.

There is approximately 90 feet (between column lines 10 and 15) where there is no opposite division interaction of Appendix R circuits.

100/R264/1.33

[

080284 t1

U T Fire Zone 2 Auxiliary Building th' The following modifications will be installed, per a' mutually

. agreed to schedule, upon acceptance of the deviation. A tested fire break will be installed in the trays at;approximately column line(s).

_ See-sketch 9).

(

.For trays:

' Tray ID#

FBL OC-617 Break installed approx. 4 feet west of column at. Gg.

OC-618 Break installed approx. 4 feet west of column at Gg.

OC-611 Break installed approx. 4 feet west of column at Gg.

-0C-614 Break installed approx.- 4 ' feet west of column at Gg.

0C-582 Break installed on east side'of column-at Gg.

OC-585 Break installed on east side of column at Gg..

OC-640 Break installed approx. 3 feet west of Gg.

OC-636 Break installed approx. 3 feet south of cable chase edge.

OC-914 Break installed approx. 3 feet south of cable chase edge.

OC-570 Break installed approx. 3 feet south of cable chase edge.

f-OC-645 Break installed approx. 3 feet south l

of cable chase edge.

j OC-592 Break installed approx. at column Line 15.

Conclusion-j '

With the installation of the proposed modifications and the existing fire protection provided, an adequate level of protection is

~

s achieved.

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Ventilation Equipment Area Auxiliary Building Elevation:

659'-6" Combustibles Electrical insulation 9,400,000 BTU Design Basis Fire rire Loading Northeast corner 14,000*

BTU /sq. ft.

Total Zone Loading 1,190 BTU /sq. ft.

Fire Protection (Available)

Suppression:

None Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(1) Dry chemical-north stairwell Hose Stations:

(2) Water Fire Resistance Rating Ak,,)

Required:

0.25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

3-hour rated / east, north, and west 3-hour rated / northwest stairwell exterior / south concrete block enclosure, 3-hour dampered pipe chase Floor / Ceiling -

50 inches reinforced concrete floor 12 inches reinforced concrete ceiling Fixed Openings -

Metal hatch / Zone 11 AB and 15 AB Sealed Penetrations 3-hour rated /through rated walls

[

in unrated Fire stops / cable tray penetrations through unrated barriers barriers i

Unsealed l

Penetrations piping conduit A/ northwest stairwell Doors A/ Turbine Building

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Calculated for deviation request 100/R264/1.42 073084

g-Fire Zone 13 Auxiliary Building

(

)

R /.

Appendix "R" Drawing No.

6E721-2804-10, 11

SYSTEMS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE Div Div I

II B21 Main Steam Isolation Valves; X

X Safety Relief Valves (I) for Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

X X

C11 Control Rod Drive (Manual Scram Circuits Only)

E11 RHR; Service Water System, Cooling Towers, X

X Containment Cooling Mode and Shutdown Cooling Mode E41 High Pressure Coolant Injection X

E51 Reactor Core Inolation Cooling X

P44 Emergency Equipment Cooling Water P45 Emergency Equipment Service Water P50 Control Air (Control Center HVAC dampers)

R14 ESF a-c Distribution System for Shutdown Equip X

R16 ESF a-c Distribution System for Shutdown Equip X

R30 ESF a-c Distribution System for Shutdown Equip g

)

R32 ESF d-c System 5

T41 Control Center HVAC System and ESF Fan Coil, Units for Areas Servicing Shutdown Systems X

X T50 Suppression-Pool Temperature Monitoring Equipment X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System X

X Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

100/R264/1.43 073084

r Fire Zone 13 Auxiliary Building

t I

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Appendix R Circuit / Component Protection:

Statement of Problem:

An area wide suppression system is not provided for this zone. The analysis below demonstrates that even though this is a deviation from the specific criteria of Appendix R, equivalent protection is provided when taking into account all factors.

' Analysis I

An equivalent level of protection to Appendix R Section III.G.2, is being provided in this zone based on the following:

1.

An area wide early warning smoke detection system is installed for assuring early detection and response by th'e plant fire brigade ensuring early fire extinguishment.

2.

Division II cables are provided with a 1-hour rated protective envelope. If a Division II circuit / equipment is not protected in the zone, then a specific analysis and disposition is completed.

2 3.

The fire loading of this zone is very low (1,190 BTU /ft ),

4.

The Testability / Trip Cabinets (see equipment analysis - next page) are located 30 FT.

apart with no intervening combustibles a minimum of 40 FT.

separates the panels from the fixed combustibles in the zone (cable trays). The following modification will be installed per a mutually agreed to schedule, upon acceptance of the deviation:

Erection of a one Hour fire partition routed in front of the Division II Cabinet to function as a radiant energy shield. As the fixed loading is low and large spatial seperation exists the partition will protect the Division II panel from an exposure fire which might affect its redundant counterpart.

(See Sketch 10)

Conclusion With the installation of the proposed modifications, and the existing fire protection provided, an adequate level of protection is achieved.

l O

100/R264/1.44 073084 i

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,e'~j Fire Zone 13 Auxiliary Building

~t Equipment Analysis Division 'I Trip / Testability cabinets H21-P080 and H21-P082 1)

Loss of RCIC 2)

Loss of HPIC 3)

No Initiation of ADS Logic A, Low Pressure Core injection (LPCI) Logic A and Core Spray Logic A 4)

Loss of Reactor vessel Level indication Division I Division II Trip / Testability Cabinets H21-P081 and H21-P083 1)

Loss of RCIC 2)

Loss of HPIC 3)

No Initiation of ADS Logic B, LPCI Logic B and Core Spray 4)

Loss of Reactor Vessel Level indication Division II O

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FIRE ZONE 15

~

Ventilation Equipment Area Auxiliary Building Elevation:

677'-6"

' Combustibles.

Charcoal filter material 4,880,000 BTU Open Cable Trays Electrical Insulation 10,100,000 BTU 14,980,000 BTU Design Basis Fire

-Fire Loading 2200 BTU /sq. f t.

Fire Protection (Available)

Suppression:

manually actuated spray system / charcoal filters l

De*3ction:

ionization / zone wide (early warning)

Portable Extinguishers:

(1) Dry chemical Hose Stations:

(2) water j

%d Fire Resistance Rating Required:

0.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

3-hour rated / east, west exterior / south minimum 24" reinforced concrete / north Floor / Ceiling -

12 inches reinforced concrete exterior ceiling i

Fixed Openings -

metal hatch / zone 13 Sealed 3-hour rated /through rated barriers l

Penetrations Fire stops / cable trays penetrations through unrated barriers j-Unsealed Penetrations piping in unrated conduit ventilation ducting barriers A/ west stairwell Doors unrated (MTL)/ Zone 14 (AB) i l

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I j'"s Fire Zone 15 ' Auxiliary Building i'"'h Appendix "R" Drawing No. 6E721-2805-10

SYSTEMS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE Div Div I

II B21 Main Steam Isolation Valves; Safety Relief Valves (I) for Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

Cll Control Rod Drive (Manual Scram Circuits Only)

.Eli RHR; Service Water System, Cooling Towers, Containment Cooling Mode and Shutdown Cooling Mode E41 High Pressure Coolant Injection E51 Reactor Core Isolation Cooling P44 Emergency Equipment Cooling Water P45 Emergency Equipment Service Water P50 Control Air (Control Center HVAC dampers)

R14 ESF a-c Distribution System for Shutdown Equip R16 ESF a-c Distribution System for Shutdown Equip X

R30 ESF a-c Distribution System for Shutdown Equip R32 ESF d-c System h)

T41 Control Center HVAC System and ESF Fan Coil,

\\d Units for Areas Servicing Shutdown Systems X

X TSO Suppression-Pool Temperature Monitoring Equipment X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

4 i

! O 100/R264/1.46 073084

. ~..

s 4

1 T

FireNcme15 Auxiliary Building

, -'3

\\j Appendix R Circuit /Componcut Protection:

S_tatement of' Problem t

An arda* wide suppress!on system is not provided for this zone. The analysis below demonstrates that even,though this is a deviation from the ipecific criteria of Appendix R, equivalent protection is provided when'taking into account all factors.

- Analysis An equivalent level of protection to Appendix R Section III.G.2, is being provided in this pone based on the following:

1.

An area wide early warnich smoke detection system is installed for assuring early deteEtion and, response by the plant fire brigade ensuring early fire extinguishment.

y 2.

This is a major. Division I_ zone. Dihision II shutdown cables are provided with a 1-hour rated fire barrier. For instances where a divisional cable or equipment should have been protected but was not, a specific analysis and disposition has been completed on the circuits in question.

.N s

3.1 'The fire loading of this zone is very low.

s--

Conclusion i

Based on the low combustible loading, the 1-hour rated protective

.cnve ope, and area ylde smoke detection the installation of auto-l matic suppression in this zone would not enhance, to a signifi-cant degree, the fire protection provided by the current configuration.

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Steam Tunnel Turbine Building O(,)T Elevation: 583' Combustibles.

No fixed combustibles (Stesn' valves contain less than 1-gallon of oil per valve. Therefore, the oil is not considered'in the FHA (see section 9B3.2-2)

Design Basis Fire J

Fire Loading 0 BTU /sq. ft.

Fire Protection (Available)

Suppression:

None Detection:

None f

. Portable Extinguishers:

CO, dry chemical, available in area 2

)

Hose Stations:

available from RB & TB Fire Resistance Rating

, ()

Required:

N/A Actual: Walls -

east - metal plates separate tunnel from TB south - 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated between RB & tunnel north west - drywell 4

i Floor / Ceiling 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated between RB & tunnel I

ceiling 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated between AB & tunnel Fixed Openings -

tunnel connection to turbine bldg. at 628' elev.

Sealed Penetrations 3-hour rated /through rated barriers j

Unsealed I

Penetrations N/A blast resistant door between tunnel and RB 1

Doors l

A/ Zone 6 l'

i i

100/R264/1.48 072284 t

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Appendix'R Drawing No.'6E721-2801-15, 16-7

SYSTEMS REQUIRED FOR HOT OR COLD' SHlTTDOWN IN FIRE ' ZONE JIiv-Div s

I II

,'B21 Main Steam Isolation Valves; X

. Safety Relief Valves (I) for Depressarizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentaion 531 Recirculation (Inboard -Inolation Valves Only)

~b C11 ' r Control Rod Drive (Manual SEram Circuits Only)

Ell, RER;_ Service Water System, Cooling Towers, Containment Cooling Mode and Shutdown Cooling

/

Mode El'1 HighPressureCoblant. Injection X

ESI Reactor Core Isolation Cooling X

P44 Eme gency Equipment Co.oling hater f

P45 Emergency Equipment Service Water v~ ~

P50 Control A1_r (Control Center HVAC dampers)

R14 ESF a-c'Distributiod System f or S? utdown Equip -

f R16 ESF a-c Distributio'n System for Sputdotan Equip R30 ESF a-c Distribution System for Shutdown Equip

/~'N R32 ESF d-c System

(,)

TIl Ccntrol Center HVAC System and ESF PantCoil, y

Units for Areas Sarviciat Shutdown Systems

~

TSO Suppression-Pool Temperature Honitoring s

Equipment X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System Division I/ cable's enter tunne_l'from north' wall of tunnal Division 11 cables enter' tunnel fron south' wall of tunnel Required In -this case means some subset of the se a listed in I

required for, hot.cr,. cold shutdown, not nll of (b-ny ten.

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100/R264/1.49' 073084-=

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Fire Zone S' team' Tunnel' t.ppind ix ' R ' Circuit / Component Pro tec t ion :

u c

Statement of Problem

J r

~

lA' smoke' detection system, an automatic-sprinkler system, and fire barriers -have not7been provided for the' steam tunnel (583' elevation

~

lat column G12). The' analysis;below demonstrates that even though this

' is; a deviation f rom ' the specific' critbria of ~ Appendix R, equivalent

protection is(provided when all? factors are taken into account.

Analysis

-The:following provides justification demonstrating an equivalent level of protection to that of Appendix R,Section II, G2.

1.

Valves E41 F003 and E41^F600 are' separated from valve E51 F008

-(RCIC) by approximately 7 f t.' LThese valves control the steam supply to their respective pumps / turbines. Valve E41 F003 (HPCI)'

is, separated from valve E51 F0013 (RCIC) by approximately 14 ft.;

' These-valves'are isolation valves for their respective pump /

turbines. 1 Figure 1 depicts the locations of.these 4 valves 2.

Manual suppression equipment -is available for the tunnel area.

3.

There are no fixed combustibles in the tunnel.

2 4. - - Due to the tunnel being a Radioactive Level X area (highest),

access to'this area will be controlled.- Additionally, this is not the normal pathway between the Reactor and Turbine Building.

This area will be posted for no storage.

5.

All electrical circuits for. controlling these valves are located in conduits. Division I circuits (RCIC) enter'the tunnel from the north while Division II circuits (HPCI) enter the tunnel from the south.

o 6.

The high ceiling area, approximately 57 ft., make the: install-ation of an automatic sprinkler system smoke detection system impractical.'

7.

Steam tunnel temperatures are monitored by ambient tunnel temperature and HVAC differential temperature.

(supply air vs.

exhaust air temperature.)

Conclusion The postulated fire for this arca would involve less than 1 gallon of oil in each steam valve and the 7 ft. separation and conduit routing of circuits provide sufficient. protection. The installation of smoke detection, automatic suppression, and barriers would not enhance the present fire protection features in the tunnel.

- 100/R264/1.51 LO802Ti'

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FIGURE I

'LOGM/DN6F VALVES E41-FD0G,E4t-F003.

E51-F008fE51-Fol3 IN THE STEAM TUNNE L a

4 Fire Zone 14

/~~%

}

v AUXILIARY BUILDING - DIVISION II CONTROL ROOM VENTILATION EQUIPMENT ROOM, ELEVATION 677'-6" Statement of Problem and Intended Change Detroit Edison committed to install a three hour fire rated barrier around Division I cable and conduit in the room. Edison wishes to install its standard 3M one hour design in this area. The analysis below demonstrates that even though this is a deviation from the specific criteria of Section III.G.2 of Appendix R, it is equivalant protection when taking into account other factors.

Analysis A.

The room which houses the Division II equipment in the control room ventilation equipment room is described in the_ write-up for Zone 14 of Section 9B.4.2.15 of the Enrico Fermi Unit 2 (EF-2)

FSAR.

The wall's surrounding this room are constructed of reinforced concrete and concrete block. A one hour rated fire barrier with f-g Class A firs doors separates Division I and II air conditioning

'()

equipment. A one hour rated fire barrier separates Division I and II cables. Penetrations through rated walls are sealed to provide a fire resistance equivalent to the walls in which they are located. The floor is constructed of reinforced concrete and provides a three hour fire rated barrier. Electrical and piping penetrations in the floor are sealed. Ducts are encased by three hour rated fire barriers. The ceiling is constructed of reinforced concrete over unprotected steel.

The ceiling height is 15 ft.

The volume of the room in the control room ventilation equipment room where both Division I and Division II cables are present is 26,250 cu. ft.

Ventilation for this zone is provided by the control center air conditioning system. Conditioned air is supplied through ducts to the control room air conditioning equipment room. Exhaust air from the control room air conditioning equipment room is drawn through an exhaust duct opening to the control center air conditioning units located in the room. Additionally, local cooling and recirculation units in the control room air conditioning equipment room maintain suitable room ambient temperature when the control center air conditioning system is operating in the emergency recirculation mode.

During operation in the emergency recirculation mode, the supply i

/T and return air flows to and from the control center air k -)

conditioning equipment room are stopped. There are 1.2 air s

changes per hour.

l l

100/R264/1.52 073084 l

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17 l

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8 This' area is easily accessible for manual fire. fighting.

s.

.B..

SafelShutdown Equipment This room containslthe following shutdown' equipment:

1.-

Division II control' center air' conditioning equipment.

2.

' Division,I and II control and power cables for T41 system control center HVAC.

'~

Either one of the two Divisions of cables is sufficient for hot shutdown.

C.-

Fire Hazard Analysis Installed combustibles within this room consist of cable ~

insulating and jacketing materials and lubricating oil in the ventilation equipment. The type of cable insulation used is primarily ethylene propylene. Cables have overall' fire retardant jackets of Neoprene or Hypalon. For purposes of the fire hazards analysic, all cable insulation and jacketing was assumed to be combustible and to have a heat content of 10,000 Btu /lb. Cables have been type-tested in accordance with the flame test of.

Detroit' Edison's Company Specification 3071-80 and are certified to be of fire retardant construction. This is equivalent to the IEEE-383 test.. Transient combustibles are assumed'to be a l'

container of heptane.

l:

The total quantity of combustible is 1,942 pounds of cable insulation and jacketing material, and approx. five gallons of i

lubricating oil. The total Btu content is 20,300,000. A one hour fire barrier will be installed on all Division I cable tray and conduit, resulting in a net reduction of 7,000,000 Btu; l

leaving 13,300,000 Btu. This results in a 7,600 Btu /sq. ft.

i fire loading for this room. Because of the fire retardant construction of the cables, a significant exposure fire is required for cable ignition. EPRI tests at Factory Mutual Laboratories have shown that cable fires will not propagate from i

short circuits.

The Btu release of 7,600 Btu /sq. ft. would have an equivalent fire severity of less than 10 minutes in accordance with the NFPA Handbook.

D.

Fire Protection Existing or Committed Fire detection equipment located within this zone consists of an area ionization detection system. Fire suppression equipment located in this zone consists of manual hose and portable fire extinguishers.

100/R264/1.53 080284 l-

,,.... _. ~ - ~. _ _. - _. _ _ _ -,.. _ ~, _. -,,.. - - - -. -

O Conclusions

' i Equivalent protection to Section III.G.2 of Appendix R is provided based on the following:

1.

This room contains a low concentration of combustibles, with a resultant fire severity of _less than 10 minutes; also a one hour 4

fire barrier is provided for the Division I cables.

2.

An ionization detection system is provided in the room to give an early warning of a fire. This room is easily accessible for manual fire fighting.

Therefore, in the unlikely event a fire would occure, the installation with the proposed deviation meets the intent of the requirements of Appendix R.

i O

100/R264/1.54 073084

~. _ _, _

ZONE 5 AUXILIARY BUILDING - CABLE TUNNEL, ELEVATION 613'-6"

O Statement of Problem Intended Change Detroit. Edison committed to install one hour fire rated barriers around Division I and II cables. Since an automatic fire suppression syrten was also included, ' this.aet the requirements of Section III.b.2

'of' Appendix R.

Due to physical construction problems involving tray

. wrap, Fdison wished instead to erect a three hour fire. rated wall to separate the two divisions and change the fire suppression system to be manually actuated. This is equivalent protection as defined in Section III.b.2.

t Analysis A.

Area Description This zone is described in Section 9B.4.2.6 of the Enrico Fermi Unit 2 (EF-2) FSAR.

This zone serves as a cable routing area for Division I, Division II and balance of plant cable. The Division I cables are located.

along the east side of the tunnel while the division II cables are located along the west wall. One hour protective envelopes will be provided on conduits which have been routed in the opposite division area.

The walls, floor, and ceiling separating this zone from other areas are constructed of reinforced concrete having a fire resistance rating of three hours. Penetrations through rated walls,' floor, and ceiling are sealed to provide a three hour fire resistance rating. The door openings leading from the cable tunnel are protected by Class A fire doors.

The tunnel is divided in two by a three hour fire rated gypsum wall.

Ceiling height is 8 feet at the center of the cable tunnel and 17 feet at each end. Room volume is 8,000 cu. ft.

Ventilation for this zone is provided by the reactor / auxiliary building ventilation system. Air is ducted directly to the cable tunnel and. exhausted Girough ducts to the auxiliary building main exhaust system. Relief air flows unducted from the cable tunnel

~

to the corridor leading to the turbine building. Air flow l

entering the corridor is controlled by a backdraft damper. There are three air changes per hour, This zone is easily accessible for manual fire fighting.

O 1.

100/R264/1.55 073084 l

l

29.

~

- B;- -Safe Shutdnun'Equipatnt i* SYSTEMS' REQUIRED POR HOT OR COLD SHUTDOWN IN FIRE ZONE Div

~ Div s

1-II B21 Main Steam Isolation Valves; X.

X

, Safety' Relief Valves (I)1for Depressurizing

. Reactor Pressure. Vessel;- Reactor Vessel-Pressure Instrumentation B31 Recirculation (Inboard Isolation Valves Only)

C11

-Control Rod Drive (Manual Screa Circuits only)

X X

Ell-RRR; Service Watar System, Cooling Towers, X

X Containment Cooling Mode and Shutdown Cooling Mode'

. E41 High Pressure Coolant-Injection X

E51-

' Reactor Core Isolation Cooling.

X P44 Emergency-Equipment Cooling Water X

X P45-Emergency Equipment Service Water P50 Control Air' (Control Center HVAC dampers)

X X

R14 ESF a-c Distribution System for Shutdown Equip X

X R16 ESF a-c Distribution System-for Shutdown Equip X

'R30 ESF a-c Distribution System for Shutdown Equip X

X R32 ESF d-c System.

X X

T41 Control Center HVAC System and ESF Fan Coil,

' Units for Areas Servicing Shutdown Systems X

X

.T50 Suppression-Pool Temperature Monitoring Equipment X41 EDG and EDG Switchgear Room HVAC System X

E21. Core Spray System X

X

~

Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

C.

Fire Hazard Analysis Installed combustibles within this zone consist of' cable insulating and jacketing materials. The type of cable insulation used is primarily ethylene propylene. Cables have overall fire retardant jackets of Neoprene or Hypalon._ For purposes of the fire hazards analysis, all cable insulation and jacketing was assumed to be combustible and to have a heat content of 10,000 Btu /lb. Cables have been type-tested in accordance with the flame test of Detroit Edison's Company Specification 3071-80 and are certified to be of fire retardant construction. This is equivalent to the IEEE-383 test. Transient combustibles are assumed to be a container of heptane.

The total quantity of combustibles on the west side of the wall

.(Division II) is 36,860,000 BTU's due to cable insulation while the east side contains 59,260,000 BTU's due to pounds of cable insulation. The resultant fire loading for the west side of the tunnel is 78,400 Btu /sq. f t.

the east side fire loading is L190,000 Btu /sq.

ft.

100/R264/1.56 080284:

I The fire ' severity for the west side of the tunnel'in accordance -

lwith the NFPA handbook is less than one hour and less than-2.5

. hours for the-east side. --Because of the fire retardant-Lconstruction:of the cables, a significant' exposure fire is required for cable-ignition. EPFI tests at Factory Mutual

-Laboratories have shown that cable -fires will not propagate _ f rom short circuits.

The Btu releases of 78,400 Btu /sq. ft.-and 190,000 Btu /sq. ft.

would have an equivalent fire severity of approx. three hours in

~accordance with the NFPA Handbook.

The inadvertent operation of the carbon dioxide suppression system will have no adverse affect on the cables.

D.

Fire Protection Existing or Committed Fire detection equipment in this zone consists of an ionization detection system. Fire suppression equipment consists of a.

manually actuated carbon dioxide system, hose stations, portable fire extinguishers and a CO2 hose reel.

Conclusions Equivalent protection to Section III.G.2 of Appendix R is provided based on the following:

Smoke Detection is provided to the Control Room and manual actuation is provided outside the tunnel for easy operation. As the tunnel is connected to the Control Center Complex Response time will be satisfactory. The CO2 system has been designed for extended discharge (concentration hold time is 20 minutes). Therefore, automatic actuation does not significantly enhance the existing fire protection design.

l l

100/R264/1.57 080284 l

s

.. FIRE AREA / ZONE 11

. Miscellaneous Rooms Auxiliary Building Elevation:

643'-6"

-Combustibles 1Electrica1' insulation 76,200,000- BTU l

Design Basis Fire Fire Loading 37,000 BTU /sq. ft.

Fire Protection (Available)

CO / Zone wide--

Suppression:

2 Detection:

(2) ionization detection systems / zone widef(one actuates Halon system) 1I-Portable Extinguishers:

(2) Dry chemical (1 in' corridor)

(1) CO2 i

Hose Stations:

(1) water - corridor:

(1).CO2 i

Fire Resistance Rating Required:

0.50 hour5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months 4

1 i

Actual: Walls -

3-hour rated / north, east, west, south l

Floor / Ceiling 3-hour rated i

}

Fixed Openings -

metal hatch / Zone 13 i

sealed 3-hour rated Penetrations Unsealed f

Penetrations None f

(2) A/12 AB Doors (2) A/ Zone 10 (AB) l A/ Turbine Building q-

}

Safe Shutdown Equipment Division I and II battery charges and associated cables.

i Division I and II cables.

100/R264/1.59 4

073084 4;

_ _.,. _. ~ _....

1 Zone 11 A.B.

~

{v'y Statement of Problem-f Division I and Division II battery chargers and associated equipment in this-zone are separated by a 4 inch solid concrete brick wall with a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months firedoor. The wall has a minimum rating of 1 1/2 hours. The carbon dioxide system protects the area where the Division I equipment is located but suppression is not provided in the Division II cubicle.

The analysis below demonstrates.that even though this is a deviation from the specific criteria of Appendix B, equivalent protection is provided when taking into account all factors.

Analysis An equivalent level of protection to Appendix R,Section III, G.2 is being provided based on the following:

1)

The Division II battery charger cubicle contains a minor amount of fixed combustibles in the form of cables. Nu trays are located in this cubicle. The loading is less than 1000 BTU /sq.

ft.

2)

A carbon dioxide system is provided in the Division I battery charger area. The loading in this area is 37,000 BTU /sq. ft.

3)

An automatic smoke detection system is provided in both the Division II cubicle and Division I area.

t Conclusion The installation of an automatic suppression systeu in the Division II cubicle would not significantly enhance the fire protector provided by the current contiguration.

I i

l 1

O 100/R264/1.60 073084

,.,__---.-..y.,

.-,m

..,--.,--,,..,,-w_._,,m._,-._..,m._.,...-

,,,,,...,_,._,__.m..,,.,__,.y., _, -,, _, -,... _,.., _.,,,,,

-_,,,-.,m,,e

FIRE ZONE 9

.r~"g kJ Control Room Auxiliary Building Elevation:

643'-6" to 655'-6" Combustibles Control Room:

Electrical insulation 134,000,000 BTU Paper 95,000,000 BTU r

Transients (in computer room)

'102,000,000 BTU Peripheral Rooms:

Paper, wood, plastic 222,000,000 BTU Fire Protection (Available)

Suppression:

None Detection:

Smoke detection (early warning) above drop ceiling and in Control Room panels Portable Extinguishers:

(2) CO2

'(3) Halon

. (

Hose Stations:

(2) Water / Turbine Building j

Fire Resistance Rating i

Reinforced concrete Actual: Walls i

Floor / Ceiling

- Reinforced concrete Fixed Openings - None-Sealed Penetrations sealed consistant with fire rating of Penetrations walls, floor and ceiling Unsealed Penetrations in barriers

- Ventilation ducting 2 bulletproof doors to Turbine Building (A)

Doors 1 bulletproof door to northeast stair tower O

i U

100/R264/1.61 072784

rt ps

(

j-Fire Zone 9 Auxiliary Building v-Appendix R Drawing No. 6E721-2803-8 SYSTEMS REQUIRED FOR HOT OR COLD SHUTDOWN IN FIRE ZONE Div Div I

II-B21 Main Steam Isolation Valves; X

X Safety Relief Valves (1) f or Depressurizing Reactor Pressure Vessel; Reactor Vessel Pressure Instrumentstion B31 Recirculation (Inboard Isolation Valves Only)

X X

C11 Control Rod Drive (Manual Scram Circuits Only)

X X

E11 RHR; Service Water System, Cooling Towers, X

X Containment Cooling Mode and Shutdown Cooling Mode E41 High Pressure Coolant Injection X

E51 Reactor Core Isolation Cooling X

P44 Emergency Equipment Cooling Water X

X P45 Emergency Equipment Service Water X

X P50 Control Air (Control Center HVAC dampers)

X X

R14 ESF a-c Distribution System for Shutdown Equip X

X R16 ESF a-c Distribution System for Shutdown Equip X

X R30 ESF a-c Distribution System for Shutdown Equip X

X O,

'R32 ESF d-c System X

X T41 Control Center HVAC System and ESF Fan Coil, Units for Areas Servicing Shutdown Systems X

X TSO Suppression-Pool Temperature Monitoring Equipment X

X X41 EDG and EDG Switchgear Room HVAC System E21. Core Spray System X

X Required in this case means some subset of the system listed is required for hot or cold shutdown, not all of the system.

h 1

V 100/R264/1.62 073084

Fire' Zone 9 Auxiliary Building Appendix R Circuit / Component Protection:

Statement of Problem An alternate shutdown system independent of the control complex is being designed and is scheduled to be in operation after the first refueling outage. An area wide suppression and detection system is not provided for the control room as required by Appendix R Section III.G.3.

The analysis below demonstrates that even though this is a deviation from the specific criteria of Appendix R, equivalent pro-tection is provided when taking into cccount all factors.

Analysis The following provides justification demonstrating an equivalent icvel of protection to that of Appendix R Section III.G.3.

1.

The control room is bounded by walls, floor and ceiling con-structed of reinforced concrete having a fire resistance rating of three hours.

2.

Supply and return control room IIVAC ducts are provided with fire dampers where they penetrate three hour boundaries. Supply and return IIVAC ducts for the cable spreading room and relay room pass through the control room and are not provided wf *h fire dampers.

3.

The northeast stair tower is constructed to a tw. hour fire rating and is provided with a Class B fire door. Two Class A fire doors communicate with the Turbine Building.

4.

The control room is constantly manned, ensuring that potential fires are quickly detected and suppressed.

5.

Portable fire extinguishers are located throughout the control room and adjacent fire zones. Water hose reels are also located in adjacent fire zones with the capability to reach the control room.

6.

An area wide smoke detectJon system is provided above the control room drop ceiling.

7.

Each control room operating panel is provided with smoke detection.

8.

Control room operating panels each consist of a low combustible load and contain only low energy cables such as for control, indication and low power circuitry for control room instrumentation.

100/R264/1.63 080284

4 t

w s

4

- Fire Zone 9 ' Auxiliary Building Cont'd

-~

Yi

~

a 9;

The surface burning characteristics of the glazed block walls, duct insulation and ceiling panels are rated 25 or less in'

.accordance with ASTM-E-84 test method.

~

[

~

10.

Smoke and fuel contribution of the walls, duct insulation and k*

" ceiling panels are rated as 50 'or less in accordance 'with '

4

. ASTM-E-84' test method.

11. -Control cabinets are mounted!on a 4 inch high concrete pad.

12. -Ventilation louvers at.the bottom of the control cabinets have been closed over by fixing a 1 inch thick marinite board over them.

13. -An automatic Halon suppression system is.provided for the computer room and underneath the raised floor.

14. Small fitup gaps around the marinite barriers will be blocked on 4

safe shutdown panels 601, 602, 808, 809, 810 and 817. Adjacent l

. panel bulkheads will have openings or gaps between them sealed

.vith a fire retardant sealant or barrier.'

j

15. An alternate shutdown system and temporary fire protection:

measures proposed until the alternate shutdown system is opera-tional is. addressed 'in Detroit Edison's letter EF2-72,718 to. the t

NRC.

Conclusion The installation of an area wide automatic suppression and detection system j

in the control room would not significantly enhance the fire' protection provided by the current configuration.

i I

i-i 1

i l

1

\\:

l

(

l 100/R264/1.64 080384

. Attachment II C

Deviation.for the 3M one hour protective envelope to show equivalence to a one hour fire rate'l barrier.-

i

-n 4

Deviation - The 3M Brand Fire. Barrier materials _ and design configuration applied for protection of cables cat-Fermi 2 do not_ meet the acceptance for

-transmission-of heat outlined in NFPA Standard 251, Standard Methods'of Fire Tests' of Building Construction and Materials. Specifically, paragraph 7-2.C limits the temperature 1 increase on the unexposed surface to no more than 250*F (121*C) above ambient.

Design-Objective -- The design ' objective at Fermi 2 for cable protection is to ensure that one train of cables required for safe hot shutdown remain functional. during and af ter a fire exposure so as.not to preclude safe shutdown. -An acceptable method to the USNRC for accomplishing this

~

objective is outlined in 10CFR50 Appendix R paragraph itII.C.2.c,

" Enclosure of cables and equipment...in a fire barrier

-having a 1-hour rating.

In addition, fire detectors and automatic. fire ' suppression shall be installed in the fire area."

Fermi 2 meets this design objective with' the 3M Brand Fire Barriers as installed for cable trays containing EPR/Hypalon cables.

Justification - The justification of this deviation request is outlined below in four major' parts.

1.

Independent Testing and Approval of Design - The design configurations were tested at Underwriters Laboratories using PE/PVC cables of various sizes 'in trays. The configurations were exposed to the standard time-temperature curve of NFPA 251 (ASTM E-119). After one hour of exposure to this standard fire, the barriers were exposed to a hose ' stream test to evaluate the effect of thermal shock representative of manual fire suppression activities. The acceptance criteria was'that the circuit integrity was maintained during and af ter the fire exposure and after the hose stream test. The system passed UL's acceptance criteria with the PE/PVC cables.

Cables temperatures monitored during these UL tests yielded the following range of values:

Cable Size Temperature Range Low High Ave 300 MCM 203*F 397*F 373*F 7/C - #12 247*F 436*F 402*F 2/C - #16 286*F 521*F 440*F 100/R319/5.1 073084

n, r-- _

v

, ~

. Quality of Fermi 2. EPR/Hypalon~ Cables -:The EPR/Hypa' on cables '

,2.

l

installed'st Fermi 2 are significantly better'from both a damastability and ignitability standpoint -than the PE/PVC used in the UL ' tests. ? Tests. (EPRI-NP.1767 ' dt'd' 3/81) conducted by FMRC

.sponscred.by EPRI'showed that no EPR/Hypalon cables experienced

.ay offgassing prior to 567*F t(297*C) and 'did not allow piloted

. ignition'below 900*F (482*C). These-tests establish the effectiveness of the hypalon. jacket' on retarding ignition and damage to theLEPR: insulated conductors..

. Tests run'specifically:for Detroit Edison, by 3M on Fermi II EPR/Hypalon cables measured ' cable insulation ' failure 'by ' exposed weighted ~ cables to a heated ~ oven. Cables were weighted to 10

~

' times'the load expected on rungs of ladder type = trays. The oven was preheated to 90*C to represent the peak load working.

temperature of;the cables. The temperature was increased to 475'F in 45 minutes..After holding this' temperature'for 30 minutes the - oven was then heated up at a, rate of 5'F/ minute to failure. Failure occurred in a4 range;from'610*F to 875'F.,

Tests reported on at the Winter meeting'of the IEEE January.1971, (IP33-PWR, IEEE Transactions, July-August 1971, Vol PAS 90 No.1

40) verified the' quality of EPR cable ' insulation to withstand high temperatures from cable overload withe it failure and without -

permanent changes in electrical properties. Test exposures to cables of 446*F (230*C) to 572*F (300*C) for. periods of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months were conducted. The EPR insulation continued to ' function as an insulator.. and -upon cooling back to ambient temperatures,

experience no permanent change in electrical properties.

These three sets of tests verify the quality of both the Hypalon jacket to retard the onset of damage and ignition and the EPR insulation to maintain its electrical properties during and after thermal exposure. Comparing the cable temperatures recorded in the UL test configuration using PE/PVC, to the performance of EPR/Hypalon described above, it can be concluded that the EPR/Hypalon cables protected by the 3M Fire Barrier system would remain free of fire damage for at least one hour..

3.

Actual Fire Exposure from In-site Combustibles - The areas where the 3M Fire Barrier System is installed are areas of relatively low fire hazard. The actual fire exposure potential to these cables is significantly less severe than the standard fire exposure used in the UL Tests (NFPA 251 or ASTM E-119).

4.

Fire Detection and Automatic Fire Suppression Systems - Most areas where the 3M Fire Barrier system is installed contain. fire detection and automatic fire suppression systems designed to detect and suppress exposure fires.

100/R319/5.2 073084

Conclusion - Based on the' justifications presented above, this deviation request should be granted because<the. cable protection system installed at Fermi 11 provides an equivalent' level of protection to the specific requirements outlined in 10CFR50 Appendix R paragraph III.G.2.c.

100/R319/5.3 073084' L.

.t Attachment III 5

t, i

).

I i

i ENGINEERING ANALYSIS FIRE ZOf E BOUNDARIES i

100/R264A/1.53 072884

._. are the fire zones which are not enclosed by 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire barrier boundaries. These barriers were reviewed by the NRC in 1981 and found to provide an adequate level of protection (Supplement 2 to Fermi 2 Safety Evaluation Report).

It is Detroit Edison's position that these zone boundaries are adequate for the Appendix R analysis for the following reasons:

1.

Combustible loading in these zones consists of electrical insulation and lubricating oil. The corresponding fire severity on the ASTM time temperature curve for these zones is never greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (see individual zone summary sheets).

2.

Early warning smoke detection in each zone provides assurance of early fire awareness and response by the Fire Brigade.

3.

Zones with concentrated fire loading are provided with an automatic suppression system (see individual zone summary sheets).

4.

All cable tray penetrations are fire stopped at floors, ceilings and walls, therefore eliminating cable trays as a means of propagating fire between zones.

5.

Fire zones may communicate by one of the following means: (see indi-vidual zone summary sheets) a.

Unprotected hatches b.

Open stairwells c.

Non-rated covered hatches d.

Piping, conduit and ventilation duct penetrations These openings will not affect the ability of Fermi 2 to shutdown.

Further information is provided on these floor and wall penetrations on the following pages (parts A & B).

6.

The major oil hazard is the Motor Generator Sets and their oil coolers. These are located on the fourth floor of the Reactor Building. Curbing of sufficient height to contain the oil is provided along with Automatic Sprinkler Protection. No shutdown cables are present in the area.

7.

Heat and products of combustion from a fire in any zone of the Reactor Building would rise and dissipate to the Reactor Building volume. is a listing of where Detroit Edison utilized 12 inch concrete block walls as 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barriers.

100/R264A/1.54 080284

o c'

I, e <

j_

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w Lh A

FkoorFenetrations'

'A

,x

.'At your request ffor more information on unsealed floor penetrations,in.the

~

fl'

' Reactor' Building ftre-sones, DECO has performed an analysis to evaluata the

~

-consequences of a postulated fire in.a given fire sone.

In depth consider -

'ation was given :to the affect on redundant division safe shutdown

~ capability and equipment.

u.

+

Fermi'2.has several ' features lwhich' preclude a postulated fire from spread-ing vertically and preventing its safe-shutdown.

First and foremost is

~

FERMI 2's design separating Divisions I and II cables'and equipment from each other.

. Fermi 2 Reactor Building. was ~ designed ~ with Division I cables and equipment north of column line 12 and with Division II cables and equipment to the south of column line'12.in the Reactor Building.

~ For the Appendix R analysis ("R"), the same philosophy was utilised. The area north of column line 12 was ' designated a Division I "R" area and required Division II "R" circuitry are being, protected by a one hour pro-tactive envelope. Divisional' cable or equipment has been protected or a specific analysis and disposition has been completed on the circuits :in question. The area south of column line 12 was designated a Division II "R" area and required Division I "R" circuitry are being protected.

Divisional cable or equipment has been pcotected or a specific analysis and disposition has been completed on the circuits in question. The area 10 ft. north and south of column line 12 has been analysed and Appendix R circuitry have been protected to maintain the necessary 20 f t. separation.

Additionally intervening combustibles which might connect the 2 Divisional Areas have been addressed in individual deviations for the zone in question. Therefore Fermi has affectively subdivided the Reactor Building into two sub areas.a north area-and a south area.

Only heat and hot gases will traverse to the floors above, because there are no combustible materials in the stairwell or open penetrations to propsgate a fire. Additionally the large ceiling heights between floors (approx 30 f t. high) and a large building volume will aske fire propagation virtually impossible.

The hot gases could have a localise af fect around the openings, nearest the fire but the divisional separation and large building volume will protect both divisions of equipment are not af fected. As indicated in the zone summary sheets (attsched), these fire zones have low combustible loadings (less than one hour).-. In areas where there are specific hazards, i.e.

4th floor - M/G sets, First Floor Railroad Bay, and HPCI pump room, automatic sprinkler ' protection has been provided. Smoke detection has been provided-throughout all Reactor Building zones.

The unsealed penetrations, pipe and duct chases, hatches and open stair-wells are indicated'on drawings 6A721-2246 thru 4A721-2265. These drawings were previously submitted. The color coded drawings indicate the location i

and limited number of unsealed penetrations in the Reactor Building fire sones 100/R264A/1.84 080384

F r

I containing safe _ shutdown equipment. The unsealed penetrations consist of -

[

pipe and conduit penetrations, ventilation duct chases, pipe chases, an open equipment hatch, open stairwells and steel or concrete covered hatch-ways. The large openings (stairwells and refueling hatch) are located well into either the north or south subzones (The refueling hatch is 25 ft.

south of column 12; the stairwells are 50 f t. north or south of column 12).

As discussed previously the localized' hot gases could af fect only one division.

Thg pipe penetrations and ventilation duct chases present no fire hazard to L

safe shutdown capablity due to their limited number, small clearance around L

the pipes, and penetration locations. The covered hatches present no hazard to safe shutdown capability because the cover will prevent passage of hot gases.

I It is Edison's position that although unsealed penetrations exist in the l

Reactor Building that a fire in the Reactor Building will not affect both l

divisions of safe shutdown cables and equipment. This is based on the design criteria for the plant separation of Divisions I and 11 equipment, installation of automatic sprinklers, and smoke detection, and provision of 1-hour protect ive envelope.

B.

Wall Penetrations Detroit Edison Cocpany (DECO) has performed an analysis of all unrt.;ed walls. The analysis included the unrated walls between zones 1 and 2, zones 2 and 3, and zone 1 and 4 of the Reactor Building and zones 14 and 15 of the Auxiliary Building.

Reactor Building All unrated walls, excluding exterior boundary walls, 'were analyzed for unsealed penetrations in Reactor Building fire zones 1 (IRB), 2 (2RB), ~and 3 (3RB) and 4 (4RB). These fire zones are adjacent to each other as indi-cated on FSAR figures 9B-2 and 9B-3.

The walls are a minimum thickness of 36 inch reinforced concrete. Combustible loading in all the zones is low as indicated on the summary sheets.

The interior walls of the four corner rooms connect zones 1RB and 2RB. All penetrations in these walls are sealed for one of the following purposes:

3-hour fire rated cable trays, radiation shielding, metal covered pene-trations for pressure relief of the Torus Room during a steam break, air tightness, or ventilation flow control (back flow damper).

As discussed in the previous floor penetration analysis, the Reactor l

Building is divided at column 12 for the Appendix R analysis. Therefore the two north corner rooms (2RB) and the north end of 1RB area are Division I aress, while the south corner rooms (2RB) and the southend of 1RB are l

Division II "R" areas. Additionally the HPCI/ Control Rod Drive Zone (3RB) is also a Division II "R" area and shares a commonwall with the southeast corner room 2RB (Div II) and the southend of 4RB (Div II). The last unrated wall is between zone IRB and 4RB. Zone 4RB (north / south corridor) i also utilizes the north-south concept at column 12. Therefore the walls in 100/R264A/1.85 1

073084

4 Jguestion are not separating different divisional areas. and need not be a-s rated barrier. In fact-the walls are not utilized in the Appendix R:

analysis : as : fire barriers. They will. however', effectively prevent fire

. propagation.

Auxiliary Building-The other unrated wall lis located on the fif th floor of the Auxiliary

-Building and separates fire Zones 14 and 15 (14AB and 15AB respectively).

Both fire zones are.provided with early warning smoke detectors.

The wall was examined and' determined..to have no open penetrations as indi-cated on schedules.6A721-2369 Rev.-H and 6A721-2370 Rev. G and confirmed by walkdown inspections. However, _the wall does have five _ penetrations with air-_ tight seals (A.T) which are not 3-hour rated. They are located approx-instely five feet from the ceiling in the southeast corner of Zone 14 (northeast corner of Zone 15). As the combustible loading is both of these LZones are minimal (less than a 10 minute fire), these air seals will pre-ventethe propagation of fire.

Based on the wall analysis, a postulated fire will not affect both Appendix R shutdown divisions because of any unrated walls.

100/R264A/1.86 080384

m:

,.: y

,5 ATTACHMENT 1 ZONE

SUMMARY

SHEETS For doors in the Summary Sheets..The-type of door

' NOTr.S s >

1) is given first and the adjacent zone is given second.

"A" means the door has a three hour fire resistance.

"B" means the door has a 1 1/2 hour resistance.

100/R264A/1.92 073084 i

~

FIRE ZONE 1

1 i

Torus Room Reactor Building Elevation:

540'-0" to 583'-6" Combustibles Electrical insulation 270,000,000 BTU DekignBasisFire Fire Loading 19,000 BTU / sq. f t.

Fire Protection (Available)

Suppression:

Automatic Sprinkler / area wide Detection:

Ionization detection (early warning)

Portable Extinguishers:

(4) Dry chemical / Zone 2 (4) 00 / Zone 2 2

Hose Stations:

(4) Water / Zone 2 Fire Resistance Rating Required:

.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months minimum 36" thick reinforced concrete-Actual: Walls exterior / North, South and West Floor / Ceiling 24" thick reinforced concrete over Stect Beams ceiling concrete base mat floor clear openings / Zone 5 (RB)

Fixed Openings Sealed 3-hour rated / steam tunnel all penetrations Penetrations Fire stop/ cable tray penetrations tlirough unrated barriers Unsealed piping Penetrations conduit in unrated vent ilation barriers duct ing (4) water tight / Zone 2 (RB)

Doors 100/R264A/1.55 072884

W

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3 -

-9

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FIRE AREA / ZONE' I_

'wl

.x 2('.s-.

t ;. ; K g

Northwest Corner Roca Reactor Building 3

'V Elevations: ' 540 '-0" and 562 '-0" s.

' ~

~

3 t

Combustibles Electrical Insulation

-(

70,200,000 BTU 20,800,000 BTU Lubricating.011 4

91,000,000' _ BTU C

f y

Design Basis Fires 23,000

. BTU /sq. ft.

fire Loading l.

Fire Protection-(Available)

Suppres sion:

None 3

Detection nization/ sone wide (early warning)

Portable Extinguishees:

(1)' Dry chemical (1)7 C02 i

s Hose Stations:

(2) water Fire Resistance Rating Required:

0.30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months Actuait. Walls -

36" reinforced concrete F1 or/ Ceiling '-

2" reinforced concrete (562' floor)

Concrete base mat floor

,h J'

Fixed, Openings -

stairwell / Zone 5 (RB) s metal hatch / Zone 5 (RB)

Sealed Penetratifons Fire stops / cable tray penetrations through unrated barriets s

(,

Unsealed g

ventilation ducts Penetr ations in unrated barrie.s pressure relief penetrations f

piping conduit water, tight / Zone 1 (RB)

Doors s4 1.

.This '1oacitng represents the total for all four corner rooms.

c s

\\',,

+

s 100/R264A/1.57 072884

FIRE ZONE 2 Northeast Corner Room Reactor Building Elevations:

540'-0" and 562 '-0" Combustibles Electrical Insulation 70,200,000 BTU Lubricating Oil 20,800,000 BTU 91,000,000 BTU Design Basis Fire l

Fire Loading 23,000 BTU /sq. ft.

Fire Protection (Available)

Suppression: Automatic Sprinkler / elevation 540'-0" Detect ion:

Ionization / zone wide (early warning)

Portable Extinguishers:

(1) Dry chemical (1) CO2 Hose Stations:

(2) water l

l Fire Resistance Rating Required:

0.30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months Actual Walls Minimum 36" reinforced concrete Floor /Ceilling 24" reinforced concrete (562' floor) concrete base mat floor stairwell / Zone 5 (RB)

Fixed Openings metal hatch / Zone 5 (RB)

Scaled Fire stops / cable tray penetrations through Penetrations unrated barriers l

l Unsealed Penetrations 2 ventilation ducting in unrated pressure relief penetrations l

barriers conduits piping l

1.

This represents the total loading for all four corner rooms.

l 2.

Penetrations in the corner rooms are sealed for ventilation and radiation purposes. The seals are not fire-rated.

100/R264A/1.59 072884 L-

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water tight / Zone 1 Doors unrated (mtl)/ Zone 4 (RB)

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Southwest Corner Room Reactor Building Elevations:

540'-0" and 562'-0" Combustibles-Electrical. Insulation-70,200,000 BTU Lubricating 011 20,800,000_

BTU 91,000,000' BTU Design Basis Fire

. Fire Loading 23,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

None Detect ion:

Ionization / zone wide (early warning)

I Portable Extinguishers:

(1) Dry chemical (1) CO2 Hose Stations:

(2) water Fire Resistance Rating Required:

0.30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months Actual: Walls -

minimum 36" reinforced concrete Floor / Ceiling -

reinforced concrete (562' floor) concrete base mat floor Fixed Openings -

stairwell / Zone 5 (RB) l metal hatch / Zone 5 (RB)

Sealed Penetrations 2 Fire stops / cable tray penetrations through unrated barriers Unsealed Penetrations ventilation ducting in unrated pressure relief penetrations barriers conduits piping 1.

This loading represents the total for all four corner rooms.

2.

Penetrations in the corner rooms are sealed for ventilation and radiation purposes. The seals are not fire rated.

. water tight / Zone 1 (RB)

Doors 100/R264A/1.61 073084

FIRE ZONE 2

Southeast Corner Room Reactor Building Elevations:

540'-0" and 562'-0" Conbustibles Electrical Insulation' 70,200,000 RTU Lubricating Oil 20,800,000_

BTU 91,000,000L BTU

-Design Basis Fire Fire Loading 23,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

None Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(1) Dry chemical (1) 002 Hose Stations:

(2) water Fire Resistance Rating Required:

0.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

minimum 36" reinforced concrete Floor / Ceiling reinforced concrete (562' floor) concrete base mat floor Fixed Openings -

stairwell / Zone 5 (RB) metal hatch / Zone 5 (RB)

Sealed Fire stops / cable tray penetrations through unrated Penetrations barriers Unsealed Penetrations 2 -

ventilation ducting in unrated pressure relief penetrations barriers conduits piping water tight /lRB Doors water tight /3RB 540' non rated (MTL)/3RB 562' l.

This loading represents the total for all four corner rooms.

2.-

Penetrations in the corner rooms are sealed for ventilation and radiation purposes. The seals are not fire-rated.

s 100/R264A/1.63 073084 j

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I

FIRE AREA / ZONE 3

HPCI Pump cnd Turbine and Control Rod Drive Pump Rooms Reactor Building Elevation:

540'-0 and 562 '-0 Combustibles 16,300,000 BTU Electrical insulation 29,600,000 BTU Lubricating Oil 45,900,000 BTU Design Basis rire-Fire Loading 19,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

Automatic Sprinkler /HPCI Turbine and pump room Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(2) Dry chenical (2) CO2 Hose Stations:

(1) Water Fire Resistance Rating Required:

0.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated / south, east, north 36" reinforced concrete / west Floor / Ceiling -

concrete base mat floor reinforced concrete Fixed Openings -

unprotected hatch way Scaled Penetrations 3-hour rated / south, east, and north walls 3-hour rated / portion of 562' ceiling fire stops / cable tray penetrations through unrated barriers Unsealed Penetrations piping in unrated conduit barriers ventilation ducting Doors water tight / Zone 2 (RB 540')

unrated (mtl) Zone 4 (RB)

A/ Zone 1 (AB) unrated (mtl)/ Zone 2 (RB 562')

100/R264A/1.65 072884

FIRE ZONE' 4

Corridor Area Reactor Building Elevations:

562'-0" and 564'-0" Comb 6stibles Electrical Insulation 120,000,000 BTU Design Basis Fire Fire Loading 60,000 BTU /sq. ft.

Fire -Protection ( Available)

Suppression:

Automatic Sprinkler System /562'-0" corridor Detect ion:

Photoelectric /564'-0" corridor (early warning)

Ionization /562'0" corridor (early warning)

(2) CO / Zone 2RB Portable Extinguishers:

2 (2) Dry Chemical / Zone 2RB Hose Stations:

(2) water / Zone 2RB (1) water / Zone 3RB Fire Resistance Rating Required:

0.75 hour8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months 3-hour rated / Auxiliary Bldg. (Zone 1) and Turbine Actual: Walls Bldg.

36" reinforced concrete / Zones 1 and 2 Reactor Bldg.

Floor / Ceiling 3-hour rated metal pressure relieving hatch / Turbine Eldg.

Fixed Openings Sealed Penetrations 3-hour rated /through rated walls Fire stops / cable trays penetrations through unrated barriers Unsealed Penetrations piping in unrated ventilation ducting barriers conduits pressure relief penetrations A/ Turbine Bldg.

Doors non rated (MTL)/ Zone 2 NE Corner Room non rated (MTL)/CRD Pump Room 100/R264A/1.67 073084 l

Change from 1981 Zone Boundaries Previously EF2 FSAR identified the ceiling of Zone 4 as a 3-hour rated -

-fire barrier. ' However, at the north end of the north-south corridor there is a metal pressure relieving hatch in the ceiling. The hatch is designed for pipe break outside containment ~ steam venting.

Because of the light fireloading'on each side of the hatch,-the automatic

-sprinkler system in this zone, and the availability of manual suppres-sion equipment, the retal hatch provides the necessary fire resistance for the zone.

100/R264A/1.68 072884

FIRE ZONE 5

First Floor Reactor Building Elevation:

583'-6" Combustibles Electrical Insulation 472,000,000 BTU Transient Combustibles (anticipated) 96,800,000 BTU 568,800,000 BTU.

Design Basis Fire Fire Loading 30,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

Automatic Sprinkler / column lines ( A-B, 9-13)

Detect ion:

Ionization / zone wide (early warning)

Heat / column lines (A-B. 9-13) (early warning)

Portable Extinguishers: (3) Dry chemical (3) CO2 Hose Stations:

(4) Water Fire Rettistance Rating Required:

.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Actual: Walls -

3-hour rated / east exterior / north, west and south Floor / Ceiling 24 inches reinforced concrete floor 12 inches reinforced concrete floor Fixed Openings -

(5) open stairwells / Zones 2. (RBV) and 6 (RB)

(2) clear opening / Zone 6 (RB)

(2) concrete hatches / Zone 1 (RB)

(4) metal hatch / Zone 2 (RB)

(3) pipe chases / Zone 6 (RB)

Sealed 3-hour rated /through rated walls Penetrations Fire stop/ cable tray penetrations through unrated barriers Unsealed Penetrat ions piping in unrated ventilation ducting barriers conduits ducting Doors blast resistant / steam tunnel 100/R264A/1.69 073084

Fire Zone 5 Reactor-Building Deviation -from FSAR change in 1981 zone beundary definition Previously EF2 identified the door between the Reactor Building and

.. Steam Tunnel as a Class A door. However, the door -opening between this zone and - the steam tunnel is protected by a heavy pressure-resistant door.. The pressure-resistant door in combination with the labyrinth access passage-and. light. fire !oading will prevent the

~

spread of a fire from the steam tunnel. area to this zone.

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.. -.. -. - -. ~

FIRE ZONE 6

Second Floor Reactor Building Elevation:

613'-6" Combustibles

' Electrical Insulation 218,000,000 BTU Lubricating 011 760,000 BTU 219,000,000 BTU Design Basis Fire Fire Loading 14,000 BTU / sq. f t.

Fire Protection (Available)

Suppression:

Automatic sprinklers /over cable trays on east wall between column lines 10-12 Detection:

. Ionization / zone wide (early warning)

Portable Extinguishers:

(3) Dry chemical (3) CO2 Hose Stations:

(5) water Fire Resistance Rating Required:

0.25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

3-hour rated / Auxiliary Building and Steam Tunnel exterior / north, south, west Floor / Ceiling 12" thick reinforced concrete Fixed Openings -

(1) stairwells / Zones 5 (RB) and 7 (RB)

(1) stairwell / Zone 5 (RB)

(1) stairwell / Zone 7 (RB)

(3) pipe chases / Zone 5 (RB) and 7 (RB)

(2) clear openings / Zones 5 (RB) and 7 (RB)

Sealed 3-hour rated / Auxiliary Bui1. ding and Steam Tunnel Penetrations Fire stops / cable tray pe. etrations through unrated barriers Unsealed Penetrations piping ventilation ducting in unrated conduits barriers A/ Zone 6 (AB) j Doors 100/R264A/1.71 073084

FIRE ZONE 7

Third Floor Reactor Building Elevation:

641'-6" Combustibles Electrical Insulation 296,000,000 BTU Lubricating 011 304,000

-BTU Transient Combustibles (anticipated) 95,800,000 BTU 392,104,000 BTU Design Basis Fire Fire Loading 29,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

None Detect ion:

Ionization / zone wide (early warning)

Portable Extinguishers:

(5) Dry chemical (3) CO2

-Hose Stations:

(4) water Fire Resistance Rating Required:

0.45 hour5.208333e-4 days 0.0125 hours 7.440476e-5 weeks 1.71225e-5 months Actual: Walls -

exterior / north, west, south 3-hour rated / east Floor / Ceiling 12 inches reinforced concrete floor 12 inches reinforced concrete cciling Fixed Openings. -

(4) stairwells / Zones 6 (RB) and 8 (RB)

(2) clear openings / Zones 6 (RB) and 8 (RB)

(2) pipe chases / Zones 6 (RB) and 8 (RB)

Sealed Penetrations 3-hour rated /through rated barriers Fire stops / cable trays penetration through unrated barriers 3-hour rated / Zone 8 Auxiliary Building Unsealed Penetrations piping in unrated conduit 1

barriers ventilation ducting Doors-None i

100/R264A/1.73 072884 i

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FIRE ZONE 8

Fourth Floor Reactor Building

~

Elevation:

659'-6" Combdstibles 1 Lubricating 011' 167,000,000 BTU-Electrical Insulation 142,000,000 BTU 309,000,000 BTU Design Basis Fire Fire Loading 37,000 BTU /sq. ft.

Fire Protection (Available)

Suppression:

Automatic sprinkler (MG sets and oil coolers)

Detect ion:

Ionization (early warning) heat (actuation)

- Portable Extinguishers:

(3) Dry chemical (4) CO2 llose Stations:

(4) water Fire Resistance Rating Required:

0.50 hour5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months 3-hour rated / east Actual: Walls exterior / north, south, and west Floor / Ceiling 12" reinforced concrete floor a

12" reinforced concrete ceiling Fixed Openings -

(3) stairwells / Zones 7 (RB) and 9 (RB)

(2) stairwell / Zone 7 (RB)

(2) clear openings / Zones 7 (RB) and 9 (RB)

Sealed Penetrations 3-hour through rated walls Fire stops / cable trays penetration through unrated barriers Unsealed Penetrations piping in unrated conduit ventilation ducting barriers Doors None 100/R264A/1.75 072884

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'w FIRE AREA / ZONE 9'

Fifth Floor Reactor Building Elevation:

684'-6" Combustibles Lubricating 011 12,000,000 BTU

. De%ign Basis Fire Fire Loading 600 BTU /sq. ft.

Fire Protection (Available)

Suppression:

None

' Detect ion:

Ionization / zone wide (early warning)

~

E Portable Extinguishers:

(4) 002 (2) Dry chemical (4) water Hose Stations:

(4) water I

Fire Resistance Rating Required:

0.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months 1

Actual: Walls -

exterior / north, west, south, east (partial) 3-hour rated / east to 701'-0" Floor / Ceiling 12" reinforced concrete floor exterior ceiling Fixed.0penings -

(6) concrete hatches / Zone 8 i

(2) metal hatches / Zone 8 Sealed Penetrations 3-hour rated /through rated walls Fire stops / cable tray penetrations through unrated barriers Unsealed Penetrations piping in unrated conduits barriers ventilation ducting i

Doors A/ Zone 15 (AB)

-(3) B/ Zone 8 (RB)

A/ Zone 13 (AB) 100/R264A/1.77 073084 1

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FIRE ZONE 2

Mezzanine and Cable Tray Area Auxiliary Building Elevations:

583'-6" and 603'-6" Comb 0stibles' Electrical Insulation 424,000,000 BTU Design Basis Fire Fire Loading 71,000 BTU /sq. ft.

Fire Protection ( Available)

. Suppres sion:

Automatic Sprinklers / zone wide Detect ion:

Ionization / zone wide (early warning)

Portable Extinguishers:

(2) Dry chemical Hose Stations:

(1) Water (2) Water / Turbine Building Fire Resistance Rating Required:

1.0 hour0 days 0 hours 0 weeks 0 months Actual: Walls -

3-hour rated / north, south, east and west exterior / north and south -

Floor / Ceiling -

3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated ceiling Fixed Openings -

Concrete hatch / Zone 3 (Reactor Building)

Sealed Penetrations 3-hour rated Unsealed Penetrations none A/ Zone 3 AB Doors TB Appendix "R" Drawing No. 6E721-2801-15,16 100/R264A/1.88 073084 wwwo-e-~

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FIRE ZONE 2 AUXILIARY BUILDING At the south end of Zone 2 is a cable vault area where cable enters from outside. This vault _is separated from the remainder of Zone 2 (vault's north ' wall) by a 24 inch concrete wall. Penetrations in the wall are 3

hour fire. rated.- The door is a 1 inch thick steel water tight door. It is Detroit Edison's opinion the door will prevent a fire from propagating thru

.th'e opening. The loading on either side of the door consists of cables and ar,,e less'than one hour.

Within this entry area, Division I Appendix R ("R") cables are located on the east side while Division II "R" cables are located on the west side.

An eight inch hollow. concrete block wall with a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire door separates the two sides. Penetrations in this wall are 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated seals.

Additionally each side contains 2 smoke detectors. Though an eight inch HCB wall _ does not provide a rated 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barrier, the barrier will provide adequate resistance for a postulated fire in the. cable vault area.

(see sketch 1) 100/R264A/1.89 073084

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'R' ZONE (AUTOMATIC SPRINKLER) 25' (5MOKE DETECTION) yy EE EE EE I

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FIRE AREA / ZONE 11 Miscellaneous Rooms Auxiliary Building Elevation:

643'-6" Comb 6stibles Electrical Insulation

-76,200,000 BTU DefsignBasisFire.

Fire Loading 37,000 BTU /sq. ft.

Fire Protection (Available)

CO / Zone wide Suppression:

2 Detect ion:

(2) ionization detection systems / zone wide (one

~

actuates Halon system) chemical (1 in corridor)

Portable Extinguishers:

(2) Dry /

(1) 002 corridor Hose Stations:

(1) water - corridor (1) CO2 Fire Resistance Rating Required:

0.50 hour5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months Actual: Walls -

3-hour rated / north, east, west, south Floor / Ceiling -

3-hour rated Fixed Openings -

metal hatch / Zone 13 Sealed Penet ratio ns 3-hour rated Unsealed Penetrations None Doors (2) A/ Zone 12A (2) A/ Zone 10 (AB)

A/TB Safe Shutdown Equipment Division I and II battery chargers Division I and II Cables 100/R264A/1.78 073084

f Change in.1981' Zone Boundary Definitions EF2 FSAR Section 9B.4.2.12, " Miscellaneous Rooms, Zone 11", Paragraph 3

.under " Description" states in part that

"...the. ceiling also has-a metal hatch cover 'that is protected with a 3-hour - rated coating...". Detroit Edison committed to this in Ammendment 152 based on our interpretation of

. Apendix R.

Upon further analysis of Fermi 2's fire protection, we have determined that coating the' metal hatch covers with a 3-hour rated coating is unneces sary.

Our conclusion was based on:

(1)'The low fuel loading, 37,000 BTU /ft.2, in ~ this zone;.(2) having two independent early warning smoke detection systems; (3) the room being provided with an automatic / manually actuated CO2 flooding system; and (4) the metal hatch cover design is 1/4" x 24 x 11". steel, reinforced with 1/4" x'4" steel welded to the unde rs ide.

t' 1

100/R264A/1.83 072884

e-i FIRE ZONE 13 Ventilation Equipment Area Auxiliary. Building Elevation:

659 '-6" l

Combustibles Electrical insulation -

9,400,000 BTU Detign Basis Fire Fire Loading Northeast corner 14,000*

BTU /sq. ft.

Total Zone Loading 1,190 ETU/sq. ft.

Fire Protection (Available)

Suppression:

None Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(1) Dry chemical-:. orth stairwell Hose Stations:

(2) Water Fire Resistance Rating Required:

0.25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

3-hour rated / east, north, and west 3-hour rated / north iest stairwell exterior / south concrete block enclosure, 3-hour dampered pipe chase Floor / Ceiling -

50 inches reinforced concrete floor 12 inches reinforced concrete ceiling Fixed Openings -

Metal hatch / Zone 11 AB and 15 AB Sealed 3-hour rated /through rated walls Penetrations in unrated Fire stops / cable tray penetrations through unrated barriers barriers Unsealed Penetrat io ns piping conduit Doors A/ northwest stairwell A/ Turbine Building

Calculated for deviation request 100/R264A/1.79 073084

FIRE AREA / ZONE '14 Control Room Ventilation Equipment and Standby Gas Treatment System Rooms Auxiliary Building Elevation:

677'-6" Combs 3stibles Lubricating' oil 725,000 BTU Charcoal Filter 40,000,000 BTU Electrical Insulation 19,420,000 BTU 60,145,000 BTU Design Basis Fire Fire Loading 7,600 BTU /sq. ft.

Fire Protection (Available) 00 /SGTS charcoal filters Suppression:

2 Detection:

Ionization / zone wide (early warning)

Portable Extinguishers:

(1) CO2 (1) Dry Chemical Hose Stations:

(1) water Fire Resistance Rating Required:

0.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

3-hour rated / east and west minimum 24" reinforced concrete / south exterior / north Floor / Ceiling -

3-hour rated / exterior ceiling Fixed Openings -

none Sealed Penetrations 3-hour rated /through rated walls Fire stop/ cable tray renetrations through unrated barriers Unsealed Penetratio ns conduit in unrated piping barriers ventilation ducting A/Between Division I and 11 rooms Doors non rated (MTL)/ Zone 15 100/R264A/1.81 073084

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Zone 14 consists of 3 rooms, Division I Control Center. HVAC, Division II Control Center HVAC and a duct chase room which is a part of zone 9AB control room. These rooms are divided by 8 inch concrete block walls, with 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire doors, fire seals, and fire dampers..Even though the 8 inch HCB wall does not provide a _ rated 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire barrier, with the low

- fire loading in the area (800 BTU /sq. ft.) and smoke detection, the wall will prevent a postulated fire from propagating to another room.

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677'-6" Combustibles Charcoal filter. material &

14,980,000 BTU electric installation Design Basis Fire Fire Loading 2,200-BTU /sq. ft.

Fire Protection ( Available)

Suppression:

manually actuated spray system / charcoal filters Detection:

ionization / zone wide (early warning)

Portaole Extinguishers:

(1) Dry chemical Hose Stations:

(1) water Fire Resistance Rating Required:

0.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months Actual: Walls -

3-hour rated / east, west exterior / south minimum 24" reinforced concrete / north Floor / Ceiling -

12 inches reinforced concrete exterior ceiling Fixed Openings -

metal hatch / zone 13 Sealed Penetratio ns 3-hour rated /through rated barriers Fire stops / cable trays penetrations through unrated barriers Unsealed Penetrations piping in unrated conduit barriers ventilation ducting Doors A/ west stairwell unrated / Zone 14 (AB) 100/R264A/1.82 073084

Twelve Inch Concrete Block Walls-In the'Lfollowing auxiliary building areas, 12 inch concrete block walls

.were erected:

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Zone 4~

.Switchgear Room 2nd. Floor'(Sketch 1) 2)

Zone 6' - 2nd. Floor Miscellaneous Rooms (Sketch 1) 3)

Zone 7

- Cables Spreading Room (Sketch 2).

Cable Tray Area (Sketch 3 and 3A) 4).

Zone 8 5)

Zone 11 - 3rd. Floor Miscellaneous ' Room _ (Sketch 4) 6)

. Zone:12 - Switchgear Room 3rd. Floor (Sketch 5) 7)

Zone 13 -' Ventilation Equipment Room 4th. Floor (Sketch 6)

8).

Ventilation Equipment Room Sth. Floor (Sketch 7)

Zone 15 -

Sketches have been-provided depicting where these walls are located.

I- -

Detroit Edison has ta' ken credit for 12 inch concrete blocks being a three hour rated wall-in the Fire Hazard Analysis (Chapter 9B FSAR). Even though a specific design test i:s not available for this' rating it is Edison's

' position that the 12 inch block will prevent any postulated fire from spreading and is equivalent to a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months wall. The largest fire loading in the previously referenced zones is 86,000 BTU /ft2 (Zone 4 Switchgear.

Room). - In conclusion, Edison does not propose to change the FSAR to reflect where the 12 inch concrete block walls are located in the plant but will consider them equivalent to 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated walls.

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ML20094D250

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Dear Mr. Youngblood:

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ML20094D250

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Dear Mr. Youngblood:

Reference:

Subject:

SUMMARY

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