ML20141K932

Forwards Request for Exemption from Certain Fire Protection Requirements of 10CRF50,App R,III.G.2 for Sixteen Fire Areas Located in PBAPS Reactor Buildings,Turbine Bldg & Control Structure

ML20141K932
Person / Time
Site:	Peach Bottom
Issue date:	05/22/1997
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9706020152
Download: ML20141K932 (100)

Text

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10 CFR 50.12 PECO NUCLEAR nw%c-965 ChesterbrocA Boulevard A Unit of PECO Energy Wayne, PA 19087 5691 4

May 22,1997 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR 56 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Peach Bottom Atomic Power Station, Units 2 and 3 Request for Exemption from Certain Requirements of 10 CFR 50, Appendix R, Section Ill.G," Fire Protection of Safe Shutdown Capability

• In accordance with 10 CFR 50.12, PECO Energy Company (PECO Energy) hereby requests an exemption from certain provisions of 10 CFR 50, Appendix R, Section Ill.G, " Fire Protection of Safe Shutdown Capability." Specifically, an exemption is requested from the automatic fire suppression requirement stipulated by Section Ill.G.2.c for thirteen (13) fire areas located in the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Turbine Building and Control Structure. In addition, affirmation of a previously granted exemption is requested for one (1) fire area in the Control Structure and two (2) fire areas in the Reactor Buildings. The NRC previously granted this exemption in March 1985 based on the then known fire loading, which has been revised due to the inclusion of combustible fire tnrrier material. All sixteen (16) fire areas are subject to one exemption request from Appendix R, Section Ill.G.2.

j The enclosed exemption request demonstrates that the current configuration of fire protection at PBAPS in the identified fire areas satisfies the underlying purpose of 10 CFR 50, Appendix R.

This exemption will not result in undue risk to the public health and safety because a sufficient ,

level of fire protection of safe shutdown equipment is maintained. Implementing the methods '

required for strict compliance with 10 CFR Part 50, Appendix R, Section Ill.G.2.c would not increase the level of fire protection currently provided at PBAPS, and would result in costs significantly in excess of those considered when the rule was adopted. Thus, the criteria for issuance of this exemption are met in accordance with 10 CFR 50.12.

If you have any questions, please do not hesitate to contact us.

T Very truly yours, Ada.y4 k*( '

G. A. Hunger, Jr.,

Director- Licensing

Enclosure:

Attachnken N0050 llllllllllllllllllilli

* IllljillUllllll cc: H. J. Miller, Administrator, Region I, USNRC W. L. Schmidt, USNRC Senior Resident inspector, PBAPS 9706020152 970522 PDR ADOCK 05000277 P PDR

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Request Page 1 of 44 1.0

SUMMARY

l PECO Energy Company (PECO Energy) requests an exemption from certain fire  ;

protection requirements of 10CFR50, Appendix R, Ill.G.2 for sixteen (16) fire areas in i the Peach Bottom Atomic Power Station (PBAPS) Reactor Buildings, Turbine Building, '

and Control Structure. In accordance with 10CFR50, Appendix R, PECO Energy installed fire-rated, cable wrap material to protect one train of redundant safe shutdown equipment and cables within the fire areas of concern from fire damage. PECO Energy considers that the 1-hour, fire resistance rated, fire barrier systems, v tout fixed automatic suppression, provide an adequate level of fire protection for the lire areas discussed in this exemption request. This consideration is based upon combustible loadings, the design and separation of the safe shutdown equipment and circuits, the  !

presence of automatic fire detection equipment, the manual fire suppression capability, and the fire protection administrative controls that exist for these fire areas. The combination of these features provides defense-in-depth protection that justifies this exemption request. Accordingly, the granting of this exemption will continue to assure a level of fire protection commensurate with the hazards for the subject fire areas and will i not present an undue risk to the public health and safety.

2.0 BACKGROUND

Peach Bottom Atomic Power Station (PBAPS), Unit 2 was licensed to operate in October 1973 (License Number DPR-44), and Unit 3 was licensed to operate in July 1974 (License Number DPR-56). For fire protection, all plants licensed to operate before January 1,1979 are required to comply with 10CFR50.48(b) and 10CFR50, Appendix R, Ill.G. PECO Energy modified PBAPS by adding fire protection features that were necessary to comply with Section Ill.G of Appendix R. Those modifications included the installation of cable / raceway protection utilizing fire rated barriers to meet the requirements of Appendix R, Section Ill.G.2.

PECO Energy's response to Generic Letter (GL) 92-08 "Thermo-Lag 330-1 Fire Barriers," which identified inconsistencies with fire ratings of certain cable / raceway 1

protective fire barrier systems, which are used at PBAPS, has resulted in a re-analysis of the Appendix R compliance configuration. Included in this re-analysis was a departure from the practice of exclusively using 3-hour rated (fire resistance) encapsulation systems to achieve compliance. As described in PECO Energy's responses to GL 92-08, and associated Requests for Additional Information (RAl), an integrated analysis program was implemented to resolve the Thermo-Lag fire barrier material operability issue. The goal of this program is to ensure plant safety while resolving the Thermo-Lag regulatory compliance issue cost effectively. To achieve this goal, PECO Energy will reduce its reliance on Thermo-Lag. PECO Energy considered many alternative solutions that maintain plant safety and selected the most cost effective alternative. The integrated analysis program combined a safe shutdown re-analysis with the Individual Plant Examination for External Events (IPEEE) Fire Risk analysis performed in response to GL 88-20, Supplement 4. The fire risk analysis, performed on the revised safe shutdown configuration, was submitted in May 1996.

These analyses were combined to ensure that efforts to reduce safe shutdown cable

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PBAPS Units 2/3 (Docktt Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Rtquest Page 2 of 44 L

protection and requests for exemptions from regulatory requirements do run create new vulnerabilities to fire. PECO Energy does not propose fire risk arguments as justification for exemptions; however, the fire risk analysis is a useful tool to provide supplemental evaluations of relative changes in plant safety with respect to changes in fire protection.

The fire safe shutdown re-analysis for PBAPS, along with cost effective modifications to plant systems and structures, additional operator manual actions, and exemptions from regulatory requirements, where justified, resulted in a reduction of raceway protection required by approximately two-thirds The remaining required raceway encapsulations will be upgraded. The primary plant modifications, which were also determined to improve plant safety with respect to fires, are the creation of five (5) additional fire areas (upgrading existing walls to meet the requirements for 3-hour fire barriers), and the rerouting of off-site power control cables to improve the availability of off-site power for safe shutdown.

The existing safe shutdown configuration conservatively prescribed the exclusive use of 3-hour rated wrap systems to achieve Appendix R compliance. Included in this conservative compliance configuration were fire areas containing fire detection and -

suppression systems, fire areas where exemption from the requirement for fire suppression had been previously granted by the NRC, and fire areas containing combustible loading configurations that could not challenge the cable / raceway protection provided. This conservatism was evaluated during the fire risk analysis by taking no credit for existing raceway protection. If the relative fire risk of the area was deemed acceptable without cable / raceway protection, alternate methods of achieving fire barrier compliance in the area were evaluated. Assurance that the fire barriers cannot be challenged was attained by the safe shutdown raceways being evaluated as targets in the fire risk analyses. Deterministic evaluations of the plant data for the fire areas discussed in this exemption request provided the technical basis for requesting specific exemption from regulatory requirements. Details of the . exemption being requested and the fire protection defense-in-depth evaluations are discussed in the appropriate sections of this document.

3.0 SPECIFIC EXEMPTION REQUESTED 10CFR50, Appendix R, Section Ill.G.2 provides six options for the protection of cables and equipment of redundant safe shutdown trains within the same fire area. Three of these options are designed for fire areas inside of containment, and three are designed for fire areas outside of containment. The applicable options, those for fire areas outside of containment, are as follows:

1. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour (fire resistance] rating. Structural steel forming a part of or supporting such barriers shall be protected to provide fire resistance equivalent to that required of the barrier;

2. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontai distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic suppression 1

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exemption Request Page 3 of 44

)

system shall be installed in the fire area; or

3. Enclosure of cable and equipment and associated non-safety circuits of one l redundant train in a fire barrier having a 1-hour (fire resistance] rating. In addition, fire detection and an automatic suppression system shall be installed in the fire area. l This request proposes to exempt the specific sixteen fire areas of concern located outside of containment from compliance with the automatic suppression provision of option number 3 (above) for protection of redundant trains of safe shutdown equipment and circuits.

In lieu of the options defined in Section Ill.G of Appendix R, PECO Energy proposes a  !

fire protection configuration that takes into account the realistic fire hazards and protection provided in certain areas of the Turbine Building, Reactor Buildings and Control Structure. The proposed fire protection configuration will ensure that one train of equipment necessary to achieve safe shutdown remains free of fire damage. The I proposed fire protection configuration will consist of the following combination:

1. Protection of certain cables supporting redundant safe shutdown equipment / trains in qualified fire barrier systems having a 1-hour fire resistance rating,

2. Use of area automatic fire detection and manual fire suppression capability,

3. General use of IEEE 383 or equivalent rated cables; cables not IEEE 383 or equivalent rated are enclosed within a metal conduit system, and

4. Implementation of strict administrative controls on transient combustibles and fire ignition sources.

For three (3) of the fire areas for which an exemption is being requested, an exemption from 10CFR50, Appendix R requirement for fire suppression was previously granted (3/13/85) by the NRC based on the then known fire loading. Those areas are:

1. Fire Area 25, Fire Zone 25-108A, the Radwaste Building Fan Room

2. Fire Area 6N, Fire Zone 6N-5H, Unit 2 Reactor Building North, CRD Equipment Area

3. Fire Area 13N, Fire Zone 13S-13P Unit 3 Reactor Building, South CRD Equipment Area Affirmation is being requested from the NRC as part of this submittal for the above fire area exemption based on the current fire loading which includes combustible fire barrier material.

The enclosed detailed analyses illustrate, for the specific circumstances in the fire areas discussed, the adequacy of the proposed fire protection configurations to protect the public health and safety without undue risk.

4.0 SATISFACTION OF EXEMPTION CRITERIA Exemptions from NRC requirements are authorized by 10CFR, Section 50.12. An exemption will be granted if it is authorized by law; will not present an undue risk to the public health and safety; is consistent with the common defense and security; and is supported by one or more of the special circumstances in 10CFR50.12(a)(2). Special A

PBAPS Units 2/3 (Dock:t Nos. 50-277/278) 10CFR50, Appendix R Exemption Request Page 4 of 44 circumstance 10CFR50.12(a)(2)(ii) allows for an exemption if application of the i regulation would not serve the underlying purpose of the rule or is not necessary to l achieve the underlying purpose of the rule. Special circumstance 10CFR50.12(a)(2)(iii) allows for an exemption if compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted. ,

All of these criteria are satisfied with this request. l The exemption is authorized by law because the underlying requirement is established by an NRC rule for which an exemption may be granted under 10CFR50.12. The following evaluation of safety significance shows that the exemption will not result in undue risk to the public health and safety because a sufficient level of fire protection is maintained. Common defense and security are not atfected. Therefore, the criteria of l 10CFR Section 50.12(a)(1) are met.

Two of the special circumstances recognized by the NRC are applicable. The level of i fire protection required by strict application of the rule would not improve protection of I safe shutdown equipment from damage due to a realistically expected fire. This

exemption request demonstrates that the configuration of fire protection features satisfies the underlying purpose of 10CFR50 Appendix R, by providing adequate fire protection of safe shutdown equipment. In addition, the costs associated with implementing the fire protection methods required for strict compliance with the rule would be significantly in excess of those contemplated when the rule was adopted. In the determination for costs associated with implementation of the rule, consideration must be given to those costs incurred to attain the current compliance configuration.

For the reasons discussed, the NRC's criteria for issuance of this exemption are satisfied and the exemption should be granted.

5.0 GENERAL INFORMATION ON FIRE PROTECTION AT PBAPS Fire protection is provided at PBAPS using the " defense-in-depth" philosophy. The objectives of this philosophy are:

1. Prevent fire from starting;

2. Rapidly detect and suppress fires that do occur, thereby limiting their damage; and

3. Design plant systems such that essential clant functions will not be damaged from the effects of fire.

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PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exemption Request Page 5 of 44 5.0.1 Fire Protection Administrative Controls To meet objective (1) of the defense-in-depth philosophy, the prevention of fires at PBAPS is accomplished by the implementation of, and adherence to comprehensive fire protection administrative controls. PECO Energy maintains a strong program of administrative controls for fire protection activities. Particular strengths include effective housekeeping, control and inspection of fire barriers and penetrations, and control of:

hot work processes, transient combustible materials, chemicals and combustible liquids. Transient ignition sources within the plant are controlled by administrative procedures. Work that could introduce an ignition source is controlled and compensatory actions are required to preclude and/or mitigate the ignition of combustibles within the work area.

5.0.2 Fire Detection and Fire Suppression To meet objective (2) of the defense-in-depth philosophy, fires can be rapidly detected and suppressed at PBAPS by utilizlng diverse fire detection and fire suppression capabilities.

1. Fire Detection System The fire detection system is provided with both heat and smoke detection capability.

Detection arrangement is implemented following the guidance of NFPA 72E,1984.

The system is a Class B installation using a two-wire system with a resistor between the wires at the end of the circuit. Each system is electronically supervised to detect ground faults, circuit breaks, or control power failure. Audible fire alarms are distinct from other operational alarms. Heat and smoke detection is accomplished by the appropriate detector installed in plant areas where fire potential exists and in most areas containing safety related equipment. Actuation of a detector causes alarm and annunciation in the main control room and, as required, actuates automatic suppression systems.

2. Fire Suppression System Fire extinguishing capability is provided to numerous areas and equipment at PBAPS by using automatic and manual water systems, automatic and manual I carbon dioxide systems, hose stations, fire hydrants, and portable fire extinguishers.

These systems and components have been selected, designed, and installed based l on the magnitude of the hazard in the area and the characteristics of the equipment  !

they protect. l The source of water for the fire protection distribution system is the Conowingo Pond which, for fire protection purposes, has an unlimited capacity. Two vertical-shaft, turbine fire pumps, each capable of supplying 100% of the required cystem ,

demand, take suction from the pond, To assure availability, one pump is electric-motor driven, and the other is diesel-engine driven. The pumps are located in the l circulating water pump structure which is separated from other plant buildings and structures. The yard fire main loop encircles the power block with cross-connects through the Unit 2 and Unit 3 Turbine Building.

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex:mption R: quest Page 6 of 44

3. Manual Fire Fighting I Manual fire fighting at PBAPS is performed by the Shift Fire Brigade. The Brigade is cornprised of a Fire Brigade Leader and a minimum of four Fire Brigade members.

Fire Brigade members are qualified by the completion of classroom training, passing a physical examination, certification with respiratory protection devices, and completion of Fire Brigade initial live fire-ground training. Annual requalification is required for all Brigade members. This requalification includes additional classroom and live fire-ground training at the PECO Energy Fire Academy. The PECO Energy Fire Academy is EMACS (Emergency Management Accreditation and Certification System) certified (1994).

The Fire Brigade Leader (Incident Commander) and brigade members do not 4

include those individuals who have operational responsibility for the safe shutdown of the plant during a fire emergency. The leader must be qualified as a Fire Brigade member and receives additional advanced training on fire incident command.

The Fire Brigade is knowledgeable of the physical arrangement of the site. To aid the Fire Brigade Leader and Brigade members, PECO Energy maintains detailed pre-fire strategy plans (PF procedures) which provide detailed primary and secondary access routes to each plant fire zone and a detailed map of each zone.

l Access routes that involve locked doors are specifically identified in the strategies, I with appropriate precautions and methods for access identified. The PF maps also 4

include the location of fire fighting equipment, fire and safety hazards, and important plant equipment. Written descriptions accompany each map which list information )

important to successfully combat a fire such as hazards, tactics, ventilation, construction information, and suppression equipment available. A Class ll standpipe system is installed throughout the plant, and portable fire extinguishers are available to assist the Brigade in fire fighting activities.

Upon being alerted to a fire at PBAPS, Control Room personnel, via Off Normal (ON) procedures enter into pre-fire strategy plans. These procedures are designed to provide fire fighting guidance to plant personnel in the event of a fire. Operations personnel are provided guidance on the decision to initiate safe shutdown. If reactor shutdown is required, fire area specific Fire Guide (T-300 series, TRIP) procedures are entered. The Fire Guides are used in conjunction with plant operating procedures to achieve safe shutdown. The specific safe shutdown methodologies, including instructions for manual actions and repairs are detailed in the Fire Guide procedures. The fire fighting pre-fire strategy plans, Fire Guides and operating procedures, when used in combination, provide the Control Room and Fire Brigade

. personnel with a comprehensive plan and methodology for mitigating the consequences of a fire in the plant.

During the IPEEE Fire Risk Analysis, an evaluation of Fire Brigade response times to plant areas was performed. The results of the evaluation showed that the Fire Brigade is routinely able to respond to a fire in any plant area and initiate fire suppression activities within 10 minutes of notification. Fire extinguishment was determined to occur within 30 minutes of fire notification.

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exemption Request Page 7 of 44 Historically, NRC Inspection Reports have recognized the effectiveness of the PBAPS Fire Brigade in controlling and extinguishing fires and the PBAPS pre-fire strategy plans in providing fire crea data. The history of fire protection inspections and audits at PBAPS shows that PECO Energy's responsiveness and overall control and performance of the PBAPS Fire Protection Program has been very good. This trend of continued good performance is reflected in the consistently excellent evaluations during NRC Systematic Assessment of Licensee Performance (SALP) evaluations.

5.0.3 Design of Plant Systems To meet objective (3) of the defense-in-depth philosophy, plant systems at PBAPS are designed such that essential plant functions will not be damaged from the effects of fire. At PBAPS, fire protection was an original design objective, and has evolved appropriately in concert with changes in the state of the art for fire protection for nuclear power plants. PBAPS conforms with the intent of General Design Criteria for Nuclear Power Plants, as specified in 10CFR50, Appendix A. Specifically, for fire protection, PBAPS conforms with General Design Criteria 3. Structures, systems and components important to safety are designed and located to minimize the probability and consequences of fires. Noncombustible and heat resistant materials are used wherever practical throughout the plant, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability are provided, as discussed in the previous sections.

5.0.4 Combustible Loading Classification The classification of the fire loading in an area is based on the methodology discussed in the NFPA Fire Protection Handbook,17* Edition, Section 6, Chapter 6. The results of the studies show that the loading in an area can be classified as low, moderate, or high, defined by the fire loading (BTU /Ft2 ) of the area. For application at PBAPS, these classifications have been lowered from the classifications discussed in the referenced handbook to provide conservatism between the classification of combustibles within an area, and the fire resistance rating of the surrounding fire barriers. The classifications are defined as follows:

Low: The combustible loading of an area is classified as " Low"if it does not exceed an average of 60,000 BTU /Ft' of floor area. This loading corresponds to a fire severity of 45 minutes using the standard time-temperature curve, ASTM E-119. Classification of the combustible loading in an area as " Low" identifies the area as having a fire severity be!ow that which could be expected to be contained within a 1-hour fire resistance rated enclosure.

Moderate: The combustible loading of an area is classified as " Moderate" if it exceeds an average of 60,000 BTU /Ft' but does not exceed an average of 140,000 BTU /Ft2 of floor area. This loading corresponds to a fire severity of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, 45 minutes using the standard time-temperature curve, ASTM E-119. Classification of the combustible loading in an area as " Moderate" identifies the area as having a fire severity below that which could be expected to be contained within a

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex;mption Requ:st Page 8 of 44 2-hour fire resistance rated enclosure.

High: The combustible loading of an area is classified as "High" if it exceeds an average of 140,000 BTU /Ft 2 of floor area. This loading corresponds to a fire severity in excess of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />,45 minutes using the standard time-temperature curve, ASTM E-119. Classification of the combustible loading in an area as "High" identifies the area as having a fire severity below that which could be expected to be contained within a 3-hour fire resistance rated enclosure, provided that the defense-in-depth concept has been provided for high hazard

, concentrations of combustibles.

5.0.5 Cable / Raceway Fire Barrier Construction in addition to general design of plant systems, cable / raceway protection by fire barriers is used to protect redundant trains of safety systems. At PBAPS, the original design and construction of the fire barriers was performed using the safety related modification process which invoked strict quality requirements. The barriers were originally designed and constructed to provide a 3-hour fire resistance rating. Invoking the safety related quality requirements resulted in barriers that have very consistent, high quality construction parameters. Barrier quality was confirmed by detailed walkdowns and subsequent evaluations performed to evaluate the barrier for a fire resistance rating.

These same barriers with proposed minor upgrades have been conservatively evaluated to meet the requirements for a 1-hour fire resistance rated barrier. The 1-hour fire resistance ratings are based on full scale Thermo-Lag 330-1 barrier  ;

configuration tests performed by the Nuclear Energy Institute (NEI), utility industry, and l PECO Energy in accordance with Generic Letter 86-10, Supplement 1. '

The proposed minor upgrades were derived from NEl and industry test results and confirmed by PECO Energy testing. Specifically, PECO Energy testing consisted of ,

barrier configurations constructed from the same drawing details that were used to  !

construct the barriers installed in the plant, with minor upgrades to resolve potential weaknesses. The weaknesses were derived from reviews of failure modes of similar i industry tested configurations. The PECO Energy tests demonstrated that PBAPS fire barrier designs, with upgrades, can provide a 1-hour fire resistance rating with approximately 25% margin. This margin evaluation is conservative for most assemblies in that the test was concluded upon the failure of the first assembly of five on the test deck. A member of the USNRC Fire Protection Branch observed the test being conducted.

Samples of installed PBAPS Thermo-Lag 330-1 were used to determine, via a pyrolysis gas chromatography analysis, the applicability of NEl and industry Thermo-Lag 330-1 ,

testing. The industry testing, coordinated by NEl, was conducted by Nucon International, Inc. (Nucon). To assure applicability of the PECO Energy specific test program, Nucon performed the same analysis on material used to construct the test deck. The test results compared favorably to the results of the NEl test program.

l PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Request Page 9 of 44 6.0 CABLES AND EQUIPMENT FOR WHICH AN EXEMPTION IS REQUESTED The fire areas for which an exemotion is sought are located in the Reactor Building, Turbine Building, and the Control Structure. The specific fire areas are analyzed in detail below, included in each individual analysis are fire area description, fire loading information, fire detection / suppression capability, and safety train information.

6.1 CONTROL STRUCTURE 6.1.1 Fire Area 102 - 4kV Switchgear Corridor U2 U3

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7d 102l l

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Fire Area 102 4 kV Switchgear Corridor Elevaton 135'-0" l

Fire Area Description This area, room 262 (fire zone 2-147), was previously included in Fire Area 2 as described in the PBAPS Fire Protection Program (FPP). During the Thermo-Lag l Reduction and IPEEE Fire Risk Analyses, the barriers (walls) within Fire Area 2 were i evaluated. The evaluation concluded that by qualifying the wall which separates the Radwaste Corridor from the Radwaste Building as a 3-hour rated barrier, the corridor would become a separate fire area. This subdivision resulted in an increase in plant safety with respect to fires and a reduced need for raceway encapsulation. A new fire area designation will be determined upon the completion of the modifications required to establish the fire rating of the walls. For the purposes of this request, the area will be i referred to as Fire Area 102.

1. Construction Fire Area 102 is the corridor between the 4 kV switchgear and safeguard battery rooms and the Radwaste Building located on the 135' elevation of the Units 2 and 3  ;

Control Structure. The layout, including the arrangement of primary equipment, is  ;

shown in Appendix B, Figure 1.

The room is approximately 500 ft.2 in area and approximately 7500 ft.' in volume.

The area is bounded by 3-hour fire rated barriers to the north, west, south, floor and

, ceiling. The barrier to the east (adjacent to the switchgear and battery rooms) is i

I l

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exzmption Rrquest Page 10 of 44 f rated for a 2-hour fire resistance'. Penetrations in the area have been sealed to provide a 3-hour fire resistance rating except for HVAC and bus duct penetrations2.

2. Ventilation / Availability of Oxygen '

Fire Area 102 communicates to adjacent fire areas through openings (fire rated doors) that are electronically supervised and/or administratively controlled to be kept in a closed and latched position. Due to the lack of ventilation openings into  ;

the corridor, any fire that could occur would be limited in size due to ventilation

restrictions.

l 3. Use of Area j Fire Area 102 is the corridor between the Radwaste Building and the 4 kV ,

switchgear and safeguard battery rooms in the Control Structure. This corridor is the primary ingress / egress path between these areas; therefore, occupancy would be j

, transient. >

Fire Loadina Information

1. In-Situ Fire Hazards

! Fire loading in Fire Area 102 is classified as " Moderate", with an associated fire i duration of less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />,45 minutes. The actual calculated fire severity of the l area is approximately 45 minutes which is below that required for 1-hour fire i resistance rated barriers. Fixed combustibles in the room consist of combustible j fire barrier material and electrical cable insulation, with the fire barrier material i accounting for approximately 50% of the total fixed combustible loading. Since the  :

area is a corridor, the fixed combustibles are located at or near the ceiling. Without i including the combustible loading associated with the fire barrier material, the  !

combustible loading in the corridor would be classified as " Low".

2. Transient Combustibles Fire Area 102 is designated as a transient combustible free zone. No use or storage of combustible material is permitted without strict compensatory measures. The use 1 of combustibles within this area and the compensatory measures required are controlled by plant administrative procedures with guidance provided by site fire protection personnel.

3. Fire Initiators No ignition sources exist within the corridor. Ignition sources that could be introduced by hot work are controlled by administrative procedures. Any hot work performed in the area requires the use of fire watches and other compensatory measures as required by the work being performed.

' This configuration was approved in the SER issued on 10/3/91. i 2

These configurations were approved in SERs dated 3/13/85 and 10/3/91, respectively.

l l

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Requ:st Page 11 of 44

4. Challenge to Fire Barrier The fixed combustibles in the area are exposed electrical cable insulation which is IEEE 383 or equivalent rated and combustible fire barrier material. The area is a corridor with the combustible material located at or near the ceiling. No ignition sources exist in the corridor, which is designated as a transient combustible free zone. Therefore, no fire is postulated for this area that could challenge the 1-hour fire rated barrier assemblies.

Fire Detection and Suporession Capability

1. Automatic Fire Detection Capability Fire Area 102 has area fire detection with audible and visual alarms in the control room. Three (3) smoke detectors are arranged in the corridor in accordance with the requirements of NFPA 72E,1984.

2. Manual Fire Fighting Capability Upon receipt of an alarm in the main control room, the Fire Brigade will be dispatched to extinguish the fire. Area, specific pre-fire strategy plans are to be used by the Fire Brigade. There are no obstructions to access Fire Area 102. Hose l stations for manual fire fighting are available through the doors at the north and south ends of the corridor. Each hose station is provided with 100 feet of 1-1/2" j hose, which is capable of covering the entire area. CO2 and dry chemical i extinguishers are available from the same areas and the adjacent switchgear rooms.

Safety Train Information

1. Layout and Configuration of Safety Trains The layout of Fire Area 102 is shown in Appendix B, Figure 1. There is no major safe shutdown equipment located in this fire area. The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following functions:

. 4.16kV AC Train 2A Power Distribution to Emergency Load Center

. 4.16kV AC Train 3A Power Distribution to Emergency Load Center

. 4.16kV AC Train 3B Power Distribution to Emergency Load Center

• Control of Breakers on E12 and E22 Emergency Switchgear

. 480V AC Train 2A Power Distribution to Emergency Motor Control Centers e 480V AC Train 3B Power Distribution to Emergency Motor Control Centers

. Control of E1 Diesel Generator (OAG12) and Protective Relaying

. Control of E2 Diesel Generator (OBG12) and Protective Relaying

. Control of Unit 2 Main Steam Line Safety Relief Valves RV2-02-071 A, B, & C

. Control of Unit 3 Main Steam Line Safety Relief Valves RV3-02-071 A & B Appendix A, Table 1 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 2 depicts the protected safe shutdown circuit routings.

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PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Eximption Request i Page 12 of 44

2. Safe Shutdown Capability Fire Area 102 contains cables associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The protected ,

I safe shutdown methods for this fire area are Unit 2 Method C and Unit 3 Method C.

No equipment associated with safe shutdown is located in this area. Cables associated with the protected safe shutdown methods which do not have either a functionally redundant component located outside the fire area or a manual operator  ;

action to recover the potentially lost function are encapsulated by a 1-hour rated fire barrier.

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6.1.2 Fire Area 25, Fire Zone 108A - Radwaste Building Fan Room

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l F ~1 Fire Area 25 Radweste Fan Room Elevations 150'# to 165'M l

Backaround .

An exemption from the10CFR 50, Appendix R requirement for fire suppression in Fire Area 25, Fire Zone 25-108A, the Radwaste Building fan room was previously granted l (3/13/85) based on the then known fire loading. Affirmation of the exemption based on the existing fire loading is requested.

Fire Area Description

1. Construction Fire Area 25 consists of the cable spreading, computer, control and fan rooms on the 150' and 165' elevations of the Units 2 and 3 Control Structure and Radwaste Building. The specific fire zone within Fire Area 25 for which this exemption request is applicable is Fire Zone 25-108A, the Radwaste Building fan room on the 165' elevation.

Fire Zone 25-108A is approximately 6000 ft.' in area and approximately 78,000 ft.'

in volume. The room is surrounded by 3-hour fire rated barriers to the north, east, south, and west. The ceiling is the roof of the Radwaste Building and is not rated due to lack of exposures. Penetrations in the room have been sealed to provide a 3-

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exemption Request Page 13 of 44 l

hour fire resistance rating except for the area at the top of the block wall to Fire l Area 2, and HVAC penetrations *.  !

2. Ventilation / Availability of Oxygen l Fire Area 25, Fire Zone 25-108A communicates to adjacent fire areas / zones through four fire rated doors and a ventilation opening that measures approximately 55 ft . The doors are administratively controlled to be in a closed and latched {

position, however there is sufficient air available through the ventilation opening to ~  !

provide for a fuel controlled fire within the zone.

3. Use of Area l

Fire Area 25, Fire Zone 25-108A, is the Radwaste Building fan room. The room contains the fans and fan motors for the Radwaste and Control Building ventilation systems. Also contained within the room are the two GDC 19 remote / emergency shutdown panels.

Fire Loadino information

1. In-Situ Fire Hazards Fire loading in Fire Area 25, Fire Zone 25-108, is classified as " Low", with an associated fire duration of less than 45 minutes. Fixed combustibles within the zone consist of exposed IEEE or equivalent cable insulation and combustible fire barrier material. Along the east wall of the room is a cable chase. The cable chase extends down to the 150 ft. elevation where the cables pass through the east wall into the cable spreading room. The fire barrier material in the area accounts for approximately 20% of the total combustible loading within the zone.

2. Transient Combustibles The use, storage and types of combustible materials permitted within Fire Area 25 are- controlled by plant administrative procedures, if required, compensatory measures are implemented as directed by administrative procedures and site fire protection personnel.

3. Fire Initiators There are several possible ignition sources in Fire Zone 25-108. The room contains fans and fan motors for the following radwaste and control room area ventilation systems: Cable Spreading Room, Rad Chemistry Lab Fume Hood, Control Room, Emergency Switchgear Rooms, Battery Rooms, Health Chemistry and Lab. The room also contains the Unit 2 and Unit 3 emergency shutdown panels, and two motor control center panels.

The ignition sources in this area have a low potential for igniting the combustible materials located in the room due to the fact that all fans and fan motors are enclosed within heavy gage steel enclosures which provide structural support and air flow intake and distribution. If a fire were initiated in one of the fan motors, it

' These configurations were accepted in SERs dated 10/3/91,3/13/85 and 12/31/86.

1 PBAPS Units 2/3 (Docket N:s. 50-277/278) 10CFR50, Appendix R Ex .mption Request Page 14 of 44 would be contained within the enclosure and would not present an exposure to the  ;

combustibles within the room. The emergency shutdown and motor control center I panels contain internal cables which could allow fire propagation within the panels.

The panels are enclosed with the exception of ventilation openings as required to facilitate cooling of the intemals. Cables entering or exiting the panels are required  ;

by design to be sealed at the panel interface to preclude flame propagation past the seal. '

4. Challenge to Fire Barrier Possible fire scenarios in Fire Zone 25-108 include local fires in the exposed electrical cable insulation, electrical panel internals, and within the small fan motors.

The design of the electrical panels minimizes the possibility of a fire initiated within l the panel traveling beyond the cabinet. Panels are constructed of heavy gage metal .

and are sealed except for the required ventilation louvers. Cables exiting and I entering the panels are sealed at the panel to prevent the passage of flame past the cabinet / seal interface. Due to the arrangement and configuration of the combustibles within the room, it is not expected that a fire could develop which could challenge the 1-hour fire rated barrier assemblies.

Fire Detection and Suppression Capability

1. Automatic Fire Detection Capability Fire Zone 25-108A is provided with area detection which provides audible and visual alarms in the main control room. Four (4) smoke detectors are arranged in the zone in accordance with the requirements of NFPA 72E,1984. Additionally, safety related cable trays in the cableway area are provided with line type heat detection which provides local and main control room alarm and annunciation.

2. Manual Fire Fighting Capability Upon receipt of an alarm in the main control room, the Fire Brigade will be dispatched to extinguish the fire. The fire area specific pre-fire strategy plans will provide the necessary guidance for the Fire Brigade. Access to the area is through the Reactor Building stairwells with no obstructions. A hose station for manual fire fighting is available within the area. Two (2) additional hose stations are available in the Unit 2 and Unit 3 Reactor Buildings, with a hose cart in the Unit 3 Reactor Building. Each hose station is provided with 100 feet of 1-1/2" hose, which is capable of covering the entire area. Dry chemical and CO2 extinguishers are located in the room to assist in manual fire fighting operations.

Safety Train Information Layout and Configuration of Safety Trains

1. The Radwaste Building Fan Room layout, including the arrangement of primary equipment, is shown in Appendix B, Figure 3. The major safe shutdown equipment located in this fire area is:

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exemption Request Page 15 of 44

. Drywell Pressure Indicator Pl-2508

. Drywell Pressure Indicator PI-2508X  !

. Drywell Pressure. Indicator PI-3508

. Drywell Pressure Indicator PI-3508X The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shutdown functions:

. 4.16kV AC Train 2B Power Distribution to Emergency Load Center

. 4.16kV AC Train 2D Power Distribution to Emergency Load Center  !

. 4.16kV AC Train 3B Power Distribution to Emergency Load Center

. 480V AC Train 2D Power Distribution to Emergency Motor Control Centers

. 480V AC Train 3B Power Distribution to Emergency Motor Control Centers e 480V AC Train 3D Power Distribution to Emergency Motor Control Centers Appendix A, Table 2 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 4 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 25 contains cables associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in tne PBAPS FPP. The safe shutdown methods protected for this area are Unit 2 Alternative Shutdown Method D and Unit 3 Alternative Shutdown Method D. Cables associated with the protected safe shutdown methods whose function cannot be transferred to an alternative shutdown panel and for which manual operator recovery actions are not practical, are encapsulated by a 1-hour rated fire barrier.

6.1.3 Safeguard Battery Rooms U2 U3

-f + +

l 40 h d 31 I l 41 i l

F ~1 Fire Areas 31.40 and 41 Ele on1

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exemption Rrquest Page 16 of 44 The following three (3) fire area discussions are for Fire Areas 31,40 and 41 which are safeguard battery rooms. The rooms are similar in function, size, and equipment content. The information applicable to all three fire areas is summarized here, while fire area specific information is provided in subsequent sections.

Fire Area Description

1. Ventilation / Availability of Oxygen Each battery room communicates to adjacent plant fire areas through two fire rated doors, one each in the east and west walls. HVAC openings into the battery rooms are provided with fire rated dampers which will close during a fire thereby eliminating mechanical ventilation to the room. The doors are administratively controlled and electronically supervised to be kept in a closed and latched position.

Because the doors provide the only ventilation paths to the room, a fire in the room would be expected to be ventilation controlled.

2. Use of Area These fire areas are station battery rooms containing 125/250 Volt de safety related l batteries. I Fire Loadina information l

1. In-Situ Fire Hazards Fire loading in the battery rooms is classified as " Low", with an associated fire l duration of less than 45 minutes. Fixed combustibles within the fire areas consist of l combustible fire barrier material. Exposed cable insulation is limited because there l are no cable trays located in the battery rooms.

The battery cases, as discussed in the PBAPS FPP, are not considered within the combustible loading analysis of the areas for the following reasons: 1) the battery cases are filled with an aqueous solution, 2) the case material exhibits superior '

ignition resistance, and 3) the case material exhibits very low heat release during a fire.

2. Transient Combustibles The use or storage of combustible material is not permitted without strict compensatory measures. The use of combustibles within these areas and the compensatory measures required are controlled by plant administrative procedures with guidance provided by site fire protection personnel.

3. Fire initiators Ignition sources in the battery rooms consist of the station batteries and associated electrical equipment. The battery cases are manufactured from a polycarbonate plastic which demonstrates superior ignition resistance. In addition, the batteries are filled with an aqueous solution. Therefore, the station batteries do not pose a realistic fire ignition concern.

l PBAPS Units 2/3 (Dock:t Nos. 50-277/278) l 10CFR50, Appendix R Exemption Rtquest l Page 17 of 44 1

4. Challenge to Fire Barrier Combustibles within the battery rooms consist of the battery cases themselves. As previously discussed, the battery cases are not considered a credible combustible

( material; therefore, it is not expected that a fire could occur in the room that could .

present a challenge to the 1-hour rated fire barrier assemblies.

f Fire Detection and Suporession Caoability

1. Automatic Fire Detection Capability li l

The battery rooms have area detection which actuate audible and visual alarms in the main control room. Two (2) smoke detectors are located within each room in l accordance with the requirements of NFPA 72E,1984.

l 2. Manual Fire Fighting Capability Upon receipt of an alarm in the main control room, the Fire Brigade will be dispatched to extinguish the fire using the guidance provided in the area specific pre-fire strategy plans. There are no obstructions to access the areas. Hose stations for manual fire fighting are available within the Control Structure area. Each hose station is provided with 100 feet of 1-1/2" hose, which is capable of covering the ,

entire area. Two (2) foam carts are also available in the Control Structure area should they be required during fire fighting operations.

6.1.3.1 Fire Area 31- Unit 3, A and C Safeguard Battery Rooms Fire Area Description i

1. Construction Fire Area 31 is located on the 135' elevation of the Control Structure. The area of the room is approximately 500 ft.2 with a volume of approximately 7100 ft.'. The fire area is bounded by 3-hour fire rated barriers to the north, floor and ceiling _ The south, east and west walls are rated for 2-hour fire resistance. All penetrations in the area have been sealed to provido a 3-hour fire resistance rating except for a fire damper assembly in the east wall. Two (2) 1.5-hour rated fire dampers are installed d

in series in lieu of one (1) 3-hour rated damper assembly . 4 1

Safety Train Information

1. Layout and Configuration of Safety Trains The layout of Fire Area 31, including the arrangement of major equipment, is shown l in Appendix B, Figure 5. The major safe shutdown equipment located in this fire area is:

I i

d These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

PBAPS Uni's 2/3 (Docket Nos. 50-277 /278) 10CFR50, Appendix R Exemption Regaest Page 18 of 44

. 125V DC Station Battery 3AD01

. 125V DC Station Battery 3CD01

. 250V DC Distribution Panel 3AD18

. 250V DC Fuse Box 3AD17

. 125V DC Fuse Box 3AD19

. 250V DC Fuse Box 3CD17 e 125V DC Fuse Box 3CD19 The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shutdown functions:

. 250V DC Train 3B Power Distribution

. 250V DC Train 3D Power Distribution Appendix A, Table 3 specifies by fire barrier, the safe shutdown protected cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 6 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 31 contains cables and equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The primary safe shutdown equipment located in this fire area is the Unit 3 Division A and C station batteries. Cables required to suppc-' UMt 3 Safe Shutdown Method B in this fire area are encapsalated by a 1-hour rated fire barrier, or for cables that are not encapsulated, redundant cables exist outside the fire area. Equipment associated with Unit 3 Safe Shutdown Method B and Unit 2 Safe Shutdown Method B located in this fire area have a redundant component located outside the fire area. No manual operator actions are required to support safe shutdown for either unit. Therefore, Unit 3 Safe Shutdown Method B and Unit 2 Safe Shutdown Method B will be available in Fire Area 31 to safely shutdown the respective units.

6.1.3.2 Fire Area 40 - Unit 2, B and D Safeguard Battery Room Fire Area Description

1. Construction Fire Area 40 is located on the 135' olevation of the Control Structure. The fire area is approximately 600 ft.2 in area and approximately 8400 ft. in volume. The area is bounded by 3-hour fire rated barriers to the east, south, floor and ceiling. The north and west walls are rated for 2-hour fire resistance. All penetrations in the area barriers have been sealed to provide a 3-hour fire resistance rating except for a fire damper assembly in the north wall. A fire damper assembly of two (2) 1.5-hour rated fire dampers are installed in series in lieu of one (1) 3-hour rated damper assembly in the north wall'.

5 These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

PBAPS Units 2/3 (Docket Nos. 50-277/278) l 10CFR50, Appendix R Ex:mption R: quest Page 19 of 44 l

Safety Train Information i

1. Layout and Configuration of Safety Trains The layout of Fire Area 40 including the arrangement of major equipment, is shown  ;

in Appendix B, Figure 7. The major safe shutdown equipment located in this fire I area is:

I

. 125V DC Station Battery 2BD01

. 125V DC Station Battery 2DD01

. 250V DC Distribution Panel 2BD18 e 250V DC Fuse Box 2BD17

. 125V DC Fuse Box 2BD19

. 250V DC Fuse Box 2DD17 e 125V DC Fuse Box 2DD19 The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shutdown function:

. 4.16kV AC Train 2A Power Distribution to Emergency Load Center Appendix A, Table 4 specifies by fire barrier, the protected safe shutdown cables  ;

and identifies the associated safe shutdown function / equipment protected in this fire l area. Appendix B, Figure 8 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 40 contains cables and equipment associated with both Unit 2 and Unit 3 I Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The primary safe shutdown equipment located in this fire area is the Unit 2 Division B and D station batteries. Cables required to support both Unit 2 and Unit 3 Safe Shutdown Methods A and C in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables that are not encapsulated, redundant cables exist outside the fire area.

Equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A and C located in this fire area have a redundant component located outside the fire area.

No manual operator actions are required to support the available safe shutdown methods for either unit. Therefore, Unit 2 and Unit 3 Safe Shutdown Methods A and C will be available in Fire Area 40.

6.1.3.3 Fire Area 41 - Unit 2, A and C Safeguard Battery Room Fire Area Description

1. Construction Fire Area 41 is located on the 135' elevation of the Control Structure. The fire area is approximately 400 ft.' in area and approximately 5600 ft.' in volume. The area is bounded by 3-hour fire rated barriers to the south, floor and ceiling. The north, east, and west walls are rated for 2-hour fire resistance. All penetrations in the area barriers have been sealed to provide a 3-hour fire resistance rating except for a fire damper assembly in the north wall. A fire damper assembly of two (2) 1.5-hour rated l

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex:mption R:qu:st '

Page 20 of 44 I fire dampers are installed in series in lieu of one (1) 3-hour rated damper assembly in the north wall'. i Safety Train Information i

1. Layout and Configuration of Safety Trains l The layout of Fire Area 41, including the arrangement of major equipment, is shown l in Appendix B, Figure 9. The major safe shutdown equipment located in this fire  !

area is:

J e 125V DC Station Battery 2AD01 e 125V DC Station Battery 2CD01 e 250V DC Distribution Panel 2AD18 i

. 250V DC Fuse Box 2AD17 l

. 125V DC Fuse Box 2AD19

. 250V DC Fuse Box 2CD17

. 125V DC Fuse Box 2CD19 The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shetdown functions:

. 250V DC Train 2B Power Distribution

. 250V DC Train 2D Power Distribution Appendix A, Table 5 specifies by fire barrier, the safe shutdown protected cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 10 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability )

Fire Area 41 contains cables and equipment associated with both Unit 2 and Unit 3 I Safe Shutdown Methods A. B, and C, as described in the PBAPS FPP. The primary l safe shutdown equipment located in this fire area is the Unit 2 Division A and C i station batteries. Cables required to support Unit 2 Safe Shutdown Method B in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables that are not encapsulated, redundant cables exist outside the fire area. Equipment associated with Unit 2 Safe Shutdown Method B and Unit 3 Safe Shutdown Methods B and C located in this fire area have a redundant component located outside the fire area. l No manual operator actions are required to support safe shutdown for either unit.

Therefore, Unit 2 Safe Shutdown Method B and Unit 3 Safe Shutdown Methods B and C will be available in Fire Area 41 to safely shutdown the respective units.

8 These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

PBAPS Units 2/3 (Docket N:s. 50-277/278) l 10CFR50, Appendix R Ex:mption Requ:st Page 21 of 44 l 6.1.4 Safeguard Switchgear Rooms i

U2 U3 g yl W- 4 1 M l

% h

>pf \

N h-- - ,, / / )

Ji(-x '

I 37 [ ] 3d Fire Areas 32,33,34,35,36,37. 38,

& 39 Switchgear Rooms  ;

Elevation 135'-0" l The following eight (8) fire area discussions are for Fire Areas 32, 33, 34, 35, 36, 37, l 38, and 39 which are 4 kV safeguard switchgear rooms. The rooms are similar in function, size, and equipment content; therefore, the fire protection afforded is similar.

The information applicable to all fire areas is summarized here, while fire area specific information is provided in subsequent sections. l Fire Area Description

1. Ventilation / Availability of Oxygen Each fire area communicates to adjacent fire areas through two fire rated doors, one each in the east and west walls. HVAC openings into the switchgear rooms are provided with fire rated dampers which will close during a fire in the room, thereby eliminating mechanical ventilation to the room. The doors are administratively controlled and electronically supervised to be kept in a closed and latched position.

Because the doors are the only manual ventilation paths to the room, a fire in the room would be expected to be ventilation controlled.

2. Use of Area Each fire area is a 4 kV emergency switchgear room which may also contain battery chargers and/or motor control centers associated with the same electrical load group.

Fire Loadina information

1. in-Situ Fire Hazards Fire loading in the switchgear rooms is classified as " Low", with an associated fire duration of less than 45 minutes. Fixed combustibles within the fire areas consist of combustible fire barrier material and cable insulation. The combustible fire barrier

. I PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exemption RequG;st Page 22 of 44 material in the individual fire areas accounts for between 40 and 75 percent of the total calculated combustible loading of the area.

2. Transient Combustibles The use or storage of combustible materials is not permitted without compensatory measures. The use of transient combustibles in the switchgear rooms and the compensatory measures are controlled by administrative procedures with guidance provided by site fire protection personnel.

3. Fire initiators Ignition sources in the areas consist of the switchgear and battery chargers. Each of these sources is contained within metal enclosures with small or no ventilation openings, and therefore do not pose a realistic fire ignition concern. Electrical cabling within the switchgear is type SIS, flame retardant thermoset, or equivalent i rated for fire resistance and flame propagation properties. Cabling entering or I exiting the switchgear is sealed at the switchgear/ cable interface to preclude flame propagation outside the switchgear.

4. Challenge to Fire Barrier The switchgear in the room contain cable insulation. The cable is type SIS, flame retardant thermoset, or equivalent rated for flame spread. In the unlikely event that l cabling within the switchgear is ignited, it is not expected that the fire would propagate beyond the switchgear enclosure. Cables entering and exiting the switchgear are sealed to prevent flame propagation past the seal /switchgear interface.

The battery chargers in the room are a possible ignition source, but it is not considered a credible event that a fire initiated in a battery charger would spread beyond its point of origin.

It is not expected that a fire within the switchgear room will challenge the 1-hour fire resistance rated barriers. The hot gas layer developed by the switchgear fire will not be sufficient to challenge the barrier prior to the arrival of the site Fire Brigade.

Fire Detection and Suppression Capability

1. Automatic Fire Detection Capability Each switchgear room has area detection which actuates audible and visual alarms in the main control room. A smoke detector is located within each room in accordance with the requirements of NFPA 72E,1984.

2. Manual Fire Fighting Capability Upon receipt of an alarm in the main control room, the Fire Brigade will be dispatched to extinguish the fire using the area specific pre-fire strategy plan. There

are no obstructions to access the areas. Hose stations for manual fire fighting are l available adjacent to the Control Structure area. Each hose station is provided with 100 feet of 1-1/2" hose, which is capable of covering the entire area. Two (2) foam carts are also available in the Control Structure area should they be required during

PBAPS Units 2/3 (Dock;t Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Request Page 23 of 44 fire fighting operations. In addition, portable extinguishers are located within the room or adjacent rooms.

6.1.4.1 Fire Area 32 - Unit 3, C Emergency Switchgear Room Fire Area Description

1. Construction Fire Area 32 is located on the 135' elevation of the Control Structure. The fire area is approximately 500 ft.' in area and approximately 7100 ft.' in volume. The area is bounded by 3-hour fire rated barriers to the floor and ceiling. The north, south, east and west walls are rated for 2-hour fire resistance. All penetrations in the area have been sealed to provide a 3-hour fire resistance rating except for a fire damper assembly in the east wall, and the bus duct penetration seals in the east and south walls. A Lre damper assembly of two (2) 1.5-hour rated fire dampers are installed in series in lieu of one (1) 3-hour rated damper assembly in the east wall. The bus duct penetrations are sealed to provide a fire resistance equivalent to that required 7

by the barrier .

Safety Train Information 1

1. Layout and Configuration of Safety Trains i The layout of Fire Area 32, including the arrangement of major equipment, is shown in Appendix B, Figure 11. The major safe shutdown equipment located in this fire area is as follows:

. 4.16kV AC Emergency Switchgear 30A17

. 125V DC Battery Charger 3AD03

. 125V DC Battery Charger 3CD03 The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shutdown functions:

. 480V AC Train 3B Power Distribution to Emergency Motor Control Centers

. 480V AC Train 3D Power Distribution to Emergency Motor Control Centers Appendix A, Table 6 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B Figure 12 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 32 contains cables and equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. Primary safe shutdown equipment within this fire area is the Unit 3 Division C emergency switchgear and Division A and C battery chargers. Cables required to support both Unit 2 and Unit 3 Safe Shutdown Methods B and C in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables that are not encapsulated, manual operator actions can be taken to recover any functions that could be lost.

7 These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

PBAPS Units 2/3 (Dock:t Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Requ:st Page 24 of 44 Equipment associated with Unit 2 and Unit 3 Safe Shutdown Methods B and C located in this fire area either have a redundant component located outside the fire area or manual operator actions can be taken to recover any functions that could be lost. Therefore, Unit 2 and Unit 3 Safe Shutdown Methods B and C will be available in Fire Area 32 to safely shutdown the respective units.

6.1.4.2 Fire Area 33 - Unit 3, A Emergency Switchgear Room Fire Area Description

1. Construction Fire Area 33 is located on the 135' elevation of the Control Structure. The fire area is approximately 500 ft.2 in area and approximately 7400 ft.' in volume. The fire area is bounded by 3-hour fire rated barriers to the east, floor and ceiling. The north, south and west walls are rated for 2-hour fire resistance. All penetrations in the area barriers have been sealed to provide a 3-hour fire resistance rating except for the bus duct penetration seals in the west and south walls. The bus duct penetrations are sealed to provide a fire resistance equivalent to that required by the barrier

• Safety Train information

1. Layout and Configuration of Safety Trains The layout of Fire Area 33, including the arrangement of major equipment, is shown in Appendix B, Figure 13. The major safe shutdown equipment located in this fire area is:

. 4.16kV AC Emergency Switchgear 30A15

. 480V AC Emergency Motor Control Center MCC30859

. Panel 30Y33 Power Transformer 30X133 The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shutdown function:

. 250V DC Train 3D Power Distribution Appendix A, Table 7 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 14 depicts the protected safe shutdown cable routings.

2. Safe Shutdown Capability Fire Area 33 contains cables and equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The primary safe shutdown equipment within this fire area is the Unit 3 Division A emergency switchgear and Division A motor control center (MCC). Cables required to support Unit 2 Safe Shutdown Methods B and C and Unit 3 Method C in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables that are not encapsulated, manual operator actions can be taken to recover any functions that could be lost.

Equipment associated with Unit 2 Methods B and C for and Unit 3 Method C located a These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

PBAPS Units 2/3 (Docket Nos. 50-277/278)

, 10CFR50, Appendix R Exemption R@ quest Page 25 of 44 in this fire area either have a redundant component located outside the fire area or manual operator actions can be taken to recover any functions that could be lost.

l Therefore, Unit 2 Safe Shutdown Methods B and C and Unit 3 Method C will be l available in Fire Area 33 to safely shutdown the respective units.

l 6.1.4.3 Fire Area 34 - Unit 3, D Emergency Switchgear Room Fire Area Description i 1. Construction l l Fire Area 34 is located on the 135' elevation of the Control Structure. The fire area l

is approximately 500 ft.: in area and approximately 7400 ft.' in volume. The area is l bounded by 3-hour fire rated barriers to the floor and ceiling. The north, south, east l and west walls are rated for 2-hour fire resistance. All penetrations in the area ,

barriers have been sealed to provide a 3-hour fire resistance rating except for a fire damper assembly in the west wall, and the bus duct penetration seats in the east l and south walls. A fire damper assembly of two (2) 1.5-hour rated fire dampers are l

installed in series in lieu of one (1) 3-hour rated damper assembly in the west wall.

The bus duct penetrations are sealed to provide a fire resistance equivalent to that required by the barrier *.

Safety Train Information I

1. Layout and Configuration of Safety Trains The layout of Fire AJea 34, including the arrangement of major equipment is shown l in Appendix B, Figure 15. The major safe shutdown equipment located in this fire area is:

. 4.16kV AC Emergency Switchgear 30A18 ,

. 480V AC Emergency Motor Control Center MCC00B50 l

. 125V DC Distribution Panel 3DD306 l

. 125V DC Battery Charger 3BD03

+ 125V DC Battery Charger 3DD03 e 125V DC Fuse Box 3DD19X The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shutdown functions:

. 125V DC Breaker Control Power for Loads off 4.16kV AC Emergency Switchgear E32 (20A17)

. 125V DC Train C Power Distribution to E3 Diesel Generator Controls ,

. Control of Unit 2 RHR Pump C (2CP35) l

. Control of E3 Diesel Generator and Diesel Generator Breakers Appendix A, Table 8 specifies by fire barrier, the protected safe shutdown cables l and identifies the associated safe shutdown function / equipment protected in this fire a,'ea. Appendix B, Figure 16 depicts the protected safe shutdown circuit routings.

l

( ' These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively. '

l i -*'

• PBAPS Units 2/3 (Dockit Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Rtquest Page 26 of 44

2. Safe Shutdown Capability 1-

Fire Area 34 contains cables and equipment associated with both Unit 2 and Unit 3 l

Safe Shutdown Methods A, B, and C as described in the PBAPS FPP. The primary safe shutdown equipment in this fire area is the Unit 3 Division D emergency  ;

switchgear and Division B and D battery. chargers. Cables required to support both '

i Unit ~ 2 and Unit 3 Safe Shutdown Methods A and C in this fire area are -

. encapsulated by a 1-hour fire rated fire barrier, or for cables t'1at are not

]. encapsulated, manual operator actions can be taken to recover any functions that could be lost. Equipment associated with both Unit 2 and Unit 3 Methods A and C l located in this fire area either have a redundant component located outside the fire area or manual operator actions can be taken to recover any functions that could be lost. Therefore, Unit 2 and Unit 3 Safe Shutdown Methods A and C will be available in Fire Area 34 to safely shutdown the respective units.

6.1.4.4 Fire Area 35 - Unit 3, B Emergency Switchgear Room Fire Area Descriotion 1

1. Construction Fire Area 35 is located on the 135' elevation of the Control Structure. The fire area is approximately 500 ft.2 in area and approximately 7400 ft. in volume. The fire area is bounded by 3-hour fire rated barriers to the east, floor and ceiling. The north, south, and west walls are rated for 2-hour fire resistance. All penetrations in the area barriers have been sealed to provide a 3-hour fire resistance rating except for the bus duct penetration seats in the north, west and south walls. The bus duct penetrations are sealed to provide a fire resistance equivalent to that required by the barrier".

Safety Train Information

1. Layout and Configuration of Safety Trains The layout of Fire Area 35, including the arrangement of major equipment, is shown )

in Appendix B, Figure 17.-The major safe shutdown equipment located in this fire i

. area is: '

. 4.16kV AC Emergency Switchgear 30A16 ,

. 480V AC Emergency Motor Control Center MCC30860 j

. Panel 30Y34 Power Transformer 30X134 The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire I area are associated with the following safe shutdown functions:

I l

" These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

PBAPS Units 2/3 (Docket Nos. 50-277/278)  !

10CFR50, Appendix R Ex;mption Request Page 27 of 44 i

. 125V DC Breaker Control Power for Loads off 4.16kV AC Emergency j Switchgear E13 (30A15) '

. 125V DC Train A Power Distribution to E1 Diesel Generator Controls

. Control of Unit 2 RHR Pump A (2AP35)

. Control of E1 Diesel Generator and Diesel Generator Breakers Appendix A, Table 9 specifies by fire barrier, the protected safe shutdown cables )

and identifies the associated safe shutdown function / equipment protected in this fire  !

area. Appendix B, Figure 18 depicts the protected safe shutdown circuit routings.  !

2. Safe Shutdown Capability I Fire Area 35 contains cables and equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The primary i safe shutdown equipment within the fire area is the Unit 3, Division B emergency I switchgear and Division B motor control center. Cables required to support Unit 2 ,

Methods A and C, and Unit 3 Method A in this fire area are encapsulated by a 1- 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated fire barrier, or for cables that are not encapsulated, manual operator .

actions can be taken to recover any functions that could be lost. Equipment  !

associated with Unit 2 Methods A und C, and Unit 3 Method A located in this fire l area either have a redundant component located outside the fire area or manual '

operator actions can be taken to recover any functions that could be lost. Therefore, Unit 2 Methods A and C, and Unit 3 Safe Shutdown Method A will be available in Fire Area 35 to safely shutdown the aespective units.

6.1.4.5 Fire Area 36 - Unit 2, D Emergency Switchgear Room Fire Area Description

1. Construction Fire Area 36 is located on the 135' elevation of the Control Structure. The fire area is approximately 500 ft.2 in area and approximately 7400 ft.' in volume. The area is bounded by 3-hour fire rated barriers to the floor and ceiling. The north, south, east i and west walls are rated for 2-hour fire resistance. All penetrations in the area  !

barriers have been sealed to provide a 3-hour fire resistance rating except for a fire damper assembly in the west wall, and the bus duct penetration seals in the north, east, west and south walls. A fire damper assembly of two (2) 1.5-hour rated fire dampers are installed in series in lieu of one (1) 3-hour rated damper assembly in the west wall. The bus duct penetrations are sealed to provide a fire resistance equivalent to that required by the barrier".

Safety Train information

1. Layout and Configuration of Safety Trains The layout of Fire Area 36, including the arrangement of major equ(ment, is shown in Appendix B, Figure 19. The major safe shutdown equipment located in this fire area is:

" These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

PBAPS Units 2/3 (Dock t Nos. 50-277/278) 10CFR50, Appendix R Ex mption R quist Page 28 of 44

. 4.16kV AC Emergency Switchgear 20A18 e 125V DC Battery Charger 2BD03 j_ e 125V DC Battery Charger 2DD03

! The specific safe shutdown circuits protected by 1-hour fire rated barriers in this ' ire area are associated with the following safe shutdown functions:

! e 125V DC Breaker ' Control Power for Loads off 4.16kV AC Emergency i Switchgear E32 (20A17)

e. 125V DC Train C Power Distribution to E3 Diesel Generator Controls

.- Control of Unit 2 RHR Pump C (2CP35)

• ' Control of E3 Diesel Generator and Diesel Generator Breakers Appendix A, Table 10 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 20 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 36 contains cables and equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The primary safe shutdown equipment within the fire area is associated with the Unit 2 Division D emergency switchgear and Division B and D battery chargers. Cables required to support both Unit 2 and Unit 3 Safe Shutdown Method A in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables that are not encapsulated, manual operator actions can be taken to recover any functions that could be lost.

Equipment associated with Unit 2 and Unit 3 Method A located in this fire area either have a redundant component located outside the fire area or manual operator actions can be taken to recover any functions that could be lost. Therefore, both Unit 2 and Unit 3 Safe Shutdown Method A will be available in Fire Area 36 to safely shutdown the respective units.

6.1.4.6 Fire Area 37 - Unit 2, B Emergency Switchgear Room Fire Area Descriotion

1. Construction Fire Area 37 is located on the 135' elevation of the Control Structure. The fire area is approximately 525 ft.2 in area and approximately 7350 ft.* in volume. The area is bounded by 3-hour fire rated barriers to the east, floor and ceiling. The north, south and west walls are rated for 2-hour fire resistance. All penetrations in the area barriers have been sealed to provide a 3-hour fire resistance rating except for the bus duct penetration seals in the north, west and south walls. The bus duct penetrations are sealed to provide a fire resistance equivalent to that required by the barrier.

These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively,

4 _ ._ _ _ _ _ _ _ . . . _ . _ . _ _ . _ . _ _ . _ . _ _ _ _ . _ . _ . _ . _ _ _ _ . . . . -

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Examption Rrqu::st Page 29 of 44 l

l Safety Train information -

1. - Layout and Configuration of Safety Trains l The layout of Fire Area 37, including the arrangement of major equipment, is shown '

in Appendix B, Figure 21. The ' major safe shutdown equipment located in this fire area is: ,

e. 4.16kV AC Emergency Switchgear 20A16 e 480V AC Emergency Motor Control Center MCC20B60

]

j

• Panel 20Y34 Power Transformer 20X134 ,

The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire  !

area are associated with the following safe shutdown functions: j e 125V DC Breaker Control Power for Loads off 4.16kVKV AC Emergency l Switchgear E13 (30A15) e E1 Diesel Generator Controls

. Control of Unit 2 RHR Pump A (2AP35)

. Control of E1 Diesel Generator and Diesel Generator Breakers Appendix A, Table 11 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 22 depicts the protected safe shutdown circuit routings.  ;

2. Safe Shutdown Capability )

Fire Area 37 contains cables and equipment associated with both Unit 2 and Unit 3 l Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The primary  !

safe shutdown equipment within the fire area is the Unit 2 Division B emergency - I switchgear and a Division B motor control center. Cables required to support both Unit 2 Method A and Unit 3 Method A in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables that are not encapsulated, manual operator actions can be taken to recover any functions that cou!d be lost. Equipment associated with Unit 2 Method A and Unit 3 Method A located in this fire area either have a  !

redundant component located outside the fire area or manual operator acti6ns can be taken to recover any functions that could be lost. Therefore, Unit 2 Safe Shutdown Method A and Unit 3 Safe Shutdown Method A will be available in Fire Area 37 to safely shutdown the respective units.

6.1.4.7 Fire Area 38 - Unit 2, C Emergency Switchgear Room

- Fire Area Description

1. Construction Fire Area 38 is located on the 135' elevation of the Control Structure. The fire area is approximately 500 ft.2 in area and approximately 7100 ft.' in volume. The area is bounded by 3-hour fire rated barriers to the floor and ceiling. The north, south, east and west walls are rated for 2-hour fire resistance. All penetrations in the area barriers have been sealed to provide a 3-hour fire resistance rating except for a fire l damper assembly in the west wall, and the bus duct penetration seals in the north, t

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Request Page 30 of 44 I

east and west walls. A fire damper assembly of two (2) 1.5-hour rated fire dampers are installed in series in lieu of one (1) 3-hour rated damper assembly in the west i wall. The bus duct penetrations srn sealed to nrovide a fire resistance equivalent to  !

that required by the barrier.

Safety Train Information

1. Layout and Configuration of Safety Trains The layout of Fire Area 38, including the arrangement of major equipment, is shown in Appendix B, Figure 23. The major safe shutdown equipment located in this fire area is:

. 4.16kV AC Emergency Switchgear 20A17

. 125V DC Battery Charger 2AD03 e 125V DC Battery Charger 2CD03 The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shutdown functions:

. 250V DC Train 2B Power Distribution

. 250V DC Train 2D Power Distribution Appendix A, Table 12 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 24 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 38 contains cables and equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The primary safe shutdown equipment within the fire area is the Unit 2 Division C emergency switchgear and Division A and C battery chargers. Cables required to support both Unit 2 and Unit 3 Methods B and C in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables that are not encapsulated, manual operator actions can be taken to recover any functions that could be lost. Equipment associated with both Unit 2 and Unit 3 Methods B and C located in this fire area either have a redundant component located outside the fire area or manual operator actions can be taken to recover any functions that could be lost. Therefore, for both Unit 2 and Unit 3 Safe Shutdown Methods B and C will be available in Fire Area 38 to safely shutdown the respective units.

6.1.4.8 Fire Area 39 - Unit 2, A Emergency Switchgear Room >

Fire Area Description

1. Construction Fire Area 39 is located on the 135' elevation of the Control Structure. The fire area is approximately 500 ft.' in area and approximately 7400 ft.' in volume. The area is bounded by 3-hour fire rated barriers to the east, floor and ceiling. The north, south,

' These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

~ '

PBAPS Units 2/3 (Dock:t Nos. 50-277/278) 10CFR50, Appendix R Exernption R:qu:st Page 31 of 44 and west walls are rated for 2-hour fire resistance. All penetrations in the area barriers have been sealed to provide a 3-hour fire resistance rating except for the bus duct penetration seals in the north and west walls. The bus duct penetrations are sealed to provide a fire resistance equivalent to that required by the barrier" Safety Train Information

1. Layout and Configuration of Safety Trains The layout of Fire Area 39, including the arrangement of major equipment, is shown in Appendix B, Figure 25. The major safe shutdown equipment located in this fire area is:

. 4.16kV AC Emergency Switchgear 20A15

. 480V AC Emergency Motor Control Center MCC20B59

. Panel 20Y33 Power Transformer 20X133 The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire area are associated with the following safe shutdown functions:

. 250V DC Train 2B Power Distribution

. 250V DC Train 2D Power Distribution Appendix A, Table 13 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 26 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 39 contains cables and equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. The primary safe shutdown equipment within the fire area is the Unit 2 Division A emergency switchgear and an Division A motor control center. Cables required to support both Unit 2 Method B and Unit 3 Methods B and C in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables that are not encapsulated, manual operator actions can be taken to recover any functions that could be lost. Equipment associated with Unit 2 Method B and Unit 3 Methods B and C located in this fire area either have a redundant component located outside the fire area or manual operator actions can be taken to recover any functions that could be lost. Therefore, Unit 2 Safe Shutdown Method B and Unit 3 Safe Shutdown Methods B and C will be avaliable in Fire Area 39 to safely shutdown the respective units.

" These configurations were accepted in SERs dated 10/3/91 and 3/13/85, respectively.

)

1 PBAPS Units 2/3 (Docket N:s. 50-277/278) I

, 10CFR50, Appendix R Ex mption R:qu:st Page 32 of 44 6,2 REACTOR BUILDINGS i

4 4  !

l 6N h < ,.

.o -p- 113Sl F l J

Fire Areas 6N and 13S U2 and U3 Reactor Buildings Elevation 135' 0" 1

Backaround An exemption from the1QCFR 50, Appendix R requirement for fire suppression in Fire Areas 6 and 13 was previously granted (3/13/85) based on the then known fire loading'5. Affirmation of the exemption based on the existing fire loading is requested.

6.2.1 Fire Area 6N - North CRD Equipment Area Fire Area Description '

1. Construction I Fire Area 6N is in the Unit 2 Reactor Building, at the 135' elevation, and encompasses the North Control Rod Drive (CRD) Equipment Area, the North Isolation Valve Compartment, Drywell Access and Corridors. The combined area of Fire Area 6N is approximately 6200 ft.' in area and approximately 173,500 ft.8 in volume. The area is bounded by 3-hour fire rated barriers to the north, east, south, west, floor and ceiling, except for the following: areas adjacent to stairwells have a

! 2-hour fire rating; the area adjacent to the drywell (not rated) is constructed of approximately 6-feet thick reinforced concrete; and, a combustible free zone (CFZ) separates fire area 6N from the remainder of the Reactor Building (fire area 6S).

The CFZ is constructed and maintained to meet the requirements of Appendix R, Section Ill.G.2. Penetrations in the area have been sealed to provide a 3-hour fire resistance rating except for areas of grating and ventilation ductwork which were previously evaluated as acceptable. The area where the raceway encapsulations are installed (fire zone 6N-5H) is approximately 5400 ft.' in area, and approximately 151,200 ft.'in volume. The fire zone encompasses the northern section of the 135' elevation of the Unit 2 Reactor Building.

Accepted in SER dated 3/13/85.

d 1

' ~

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Eximption R:qu;st Page 33 of 44

2. Ventilation / Availability of Oxygen Fire Area 6N communicates directly to other fire areas within the Unit 2 Reactor  !

Building. As required to achieve Appendix R separation, CFZs are provided at the ,

fire area interfaces. Due to the volume of the fire area and the direct openings to I other areas of the Reactor Building, sufficient oxygen is available to support a fuel controlled fire within the fire area.

3. Use of Area Fire Area 6N supports operations associated with the north bank of control rod drive mechanisms and isolation valve manipulation. During unit outages, access into the drywell is through this area. Access to the Unit 2 elevator is also from this area on the 135' elevation. '

Fire Loadina information

1. In-Situ Fire Hazards Fire loading in Fire Area 6N is classified as " Low", with an associated fire duration of less than 45 minutes. Fixed combustibles within the area consist of combustible fire barrier material, cable insulation and wood. The wood, used as a shield bracing, has been evaluated as not creating a hazard due to its location (approximately 12 feet above fixed floor) and configuration. The combustible fire barrier material in the area accounts for less than 10% of the total combustible loading within the area.

2. Transient Combustibles The use, storage and types of combustibles materials permitted within Fire Area 6N are strictly controlled by plant administrative procedures. If required, compensatory measures are implemented as directed by administrative procedures and site fire protection personnel.

3. Fire Initiators Ignition sources in Fire. Area 6N consist mainly of enclosed electrical panels and several small transformers. Electrical cabinets in the building are sealed, except for ventilation louvers that are required for component cooling. Electrical cabling within the cabinets is type SIS, flame retardant thermoset or equivalent rated for fire resistance and flame propagation properties. Cabling entering or exiting the cabinets is sealed at the cabinet / cable interface to preclude flame propagation outside the cabinet. All transformers used within the plant structures are small dry transformers, which are classified as ignition sources due to their construction and function. Because they do not contain exposed combustible materials, they do not constitute a credible ignition source for a fire in the area.

4. Challenge to Fire Barrier Combustibles within Fire Area 6N consist mainly of electrical cable insulation which is run in cable trays or located within electrical penels. Exposed cable is IEEE 383 or equivalent rated for flame spread characteristics, and it is therefore not expected that a fire could develop within a cable tray and spread throughout the fire area

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Requ;st Page 34 of 44 l prior to the arrival of the site Fire Brigade. Electrical cabinets within the area are sealed, with the exception of required ventilation louvers. Cables exiting and entering the cabinets are sealed at the cabinet interface to prevent flame  ;

propagation past the cabinet / seal interface. Therefore, it is not expected that a fire '

initiated in an electrical cabinet would propagate out of the cabinet.

The fire area is open to other fire areas within the Unit 2 Reactor Building. Should a 1 fire initiate in transient combustibles, the smoke and hot gases would vent I throughout the building. Due to the volume of the building and the cooling effects of i entrained air it is not postulated that a transient fire would be of the magnitude  !

required to damage equipment outside of the immediate area of fire origin prior to l the arrival of the site Fire Brigade.  !

Due to the configuration and quantity of combustibles within the reactor building and the volume of the enclosure, it is not expected that a fire could develop which would i challenge the 1-hour fire resistance rated Iaceway barriers.

Fire Detection and Suppression Capability

1. Automatic Fire Detection Capability Fire Area 6N is provided with area detection which actuates audible and visual alarms in the main control room. Ten (10) smoke detectors are arranged in the area i in accordance with the requirements of NFPA 72E,1984. Four (4) heat detectors are located in the west corridor. The heat detectors are logically tied to activate the

)

water curtain system that is part of the west corridor CFZ design.

2. Automatic Fire Suppression A water curtain suppression system is provided as part of the west corridor CFZ to establish division between fire areas GN and 6S. Fire Area 6S is the remainder of

, the reactor building in the western corridor.

The water curtain consists of a piping distribution system with open spray heads.

The distribution piping is located at the floor level and positioned along one side of the corridor with spray heads spaced evenly from the floor to the ceiling. The system is actuated by a cross-zone detection system located at the ceiling level or by manual actuation at one of the two (2) local control stations. The system must be shut-off manually.

3. Manual Fire Fighting Capability Upon receipt of an alarm in the main control room, the Fire Brigade will be dispatched to extinguish the fire. The fire area specific pre-fire strategy plan for Fire Area 6N will be used by the Fire Brigade. Fire Area 6N is a radiation area, and therefore, some specific areas may be contaminated but will not obstruct access to the area. Hose stations for manual fire fighting are available within the area. Each hose station is provided with 100 feet of 1-1/2" hose, which is capable of covering the entire area. In addition, dry chemical, pressurized water and CO2 extinguishers are available to assist in manual fire fighting operations.

I i .. .- i t -* -'

PBAPS Units 2/3 (Dock:t Nos. 50-277/278) l 10CFR50, Appendix R Ex:mption Rrqu st

Page 35 of 44 Safety Train Information

1. Layout and Configuration of Safety Trains -

The layout of Fire Area 6N, including the arrangement of major equipment, is shown in Appendix B, Figure 27. The major safe shutdown equipment located in this fire

area is:

j. . 250V DC HPCI Bus 20D11

- ' . MSRV Nitrogen Supply Flow Transmitter FT-8130A

. Jet Pump Flow Transmitter FT2-2-3-63A

[ . Reactor Vessel Water Level Transmitter LT2-2-3-113

^. RHR Shutdown Cooling isolation Valve MO2-10-017 l . RHR LPCI injection Valve MO2-10-0258 2- . Core Spray Loop B Outboard Discharge Valve MO2-14-0118 l . Core Spray Loop B Inboard Discharge Valve MO2-14-012B i . . HPCI Steam Supply Outboard Isolation Valve MO2-23-016

. 480V AC Emergency Motor Control Center MCC20B37

) . . MSRV Position Amplifiers POAM2-2-71 A, B, C, D, E, F, G, M, J, K, & L i . Reactor Vessel Pressure Switch (open permissive for MO2-10-017) PS-80487

. MSRV Nitrogen Supply Pressure Transmitter PT-8142A

. Reactor Vessel Pressure Transmitter PT2-2-3-404C L . Reactor Vessel Pressure Transmitter PT2-6-105

e MSRV Back-up Nitrogen Supply Valve SV-8130A g . HPCI Steam Leak Detection Temperature Element TE-4944B  ;

p . HPCI Steam Leak Detection Temperature Element TE-4944D  ;

l'- The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire [

area are associated with the following safe shutdown functions: ,

4 i

. Control of Unit 2 Main Steam Line Safety Relief Valves RV2-02-071 A, B, C, D, i

F, G, K & L. i

[ Append'x i A, Table 14 specifies by fire barrier, the protected safe shutdown cables i and identifies the associated safe shutdown function / equipment protected in this fire

!- area. Appendix B,' Figure 28 depicts the protected safe shutdown circuit routings.  !

! 2. Safe Shutdown Capability Fire Area 6N contains cables and equipment associated with both Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. Cables required to support Unit 2 Method C in this fire area are encapsulated by a 1-hour

[t rated fire barrier, or for cables which are not encapsulated, manual operator actions L can be taken to recover any functions that could be lost. Equipment associated with

';. Unit 2 Method C and Unit 3 Methods A, B, and C located in this fire area either have a redundant component located outside the fire area or manual operator actions can be taken to recover any functions that could be lost. Therefore, Unit 2 Safe

{ Shutdown Method C and Unit 3 Methods A, B, and C will be available in Fire Area i 6N to safely shutdown the respective units.

I l i

- .n- . . .,m -

a-, ,-- r 1- - -- --,.--._ r , . . -e _ . . . , . _ - . - - - ,r. , --

. __.._.________._.___.__.-_.____....__m_._- _..- _ _.

- i

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Eximption Rrquist Page 36 of 44 l 1

6.2.2 Fire Area 138 - South CRD Equipment Area l i

Fire Area Descriotion I b 1. Construction

! Fire Area 13S is located on the 135' elevation of the Unit 3 Reactor Building. The l fire area is approximately' 5100 ft.' in area and approximately 141,900 ft.' in volume.

t The area is bounded by 3-hour fire rated barriers to the north, east, south, west, .

i floor and ceiling, except for the following: areas adjacent to stairwells have a 2-hour

! fire rating; the area adjacent to the drywell (not fire rated) is constructed of

,^

approximately 6-feet thick reinforced concrete; and, a combustible free zone (CFZ) separates fire area 13S from the remainder of the Reactor Building (Fire Area 13N) p The CFZ is constructed and maintained to meet the requirements of Appendix R,

, . Section Ill.G.2. Penetrations in the area have been sealed to provide a 3-hour fire

[

resistance rating except for areas of grating and ventilation ductwork which were previously evaluated as acceptable. The area where the raceway encapsulations are installed (fire zone 13S-13P) is approximately 4200 ft.' in area and 117,600 ft.'

i in volume. The fire zone encompasses the southern section of the 135' elevation of the Unit 3 Reactor Building.

2. Ventilation / Availability of Oxygen Fire Area 13S communicates directly to other fire areas within the Unit 3 Reactor Building. Where required to provide Appendix R separation, CFZs are provided at the fire area interfaces. Due to the volume of the fire area and the direct openings to other areas of the Reactor Building, sufficient oxygen is available to support a fuel controlled fire.

3. Use of Area Fire Area 13S supports operations associated with the north bank of control rod drive mechanisms and isolation valve manipulation. Access to the Unit 3 elevator is also from this fire area on the 135' elevation.

Fire Loadino information

1. In-Situ Fire Hazards Fire loading in Fire Area 13S is classified as " Low", with an associated fire duration of less than 45 minutes. Fixed combustibles within the area consist of exposed cable insulation and combustible fire barrier material. The combustible fire barrier material in the area acccunts for less than 10% of the total combustible loading.

2. Transient Combustibles The use, storage and types of combustibles materials permitted within Fire Area 1 13S are strictly controlled by plant administrative' procedures. If required, j compensatory measures are implemented as directed by administrative procedures j and site fire protection personnel, j i

l 1

_ j

. . 1 PBAPS Units 2/3 (Dock;t N:s. 50-277/278) I 10CFR50, Appendix R Ex;mption Request  !

Page 37 of 44

3. Fire initiators Ignition sources in Fire Area 13S consist mainly of enclosed electrical panels and several small transformers. Electrical cabinets in the building are sealed, except for ventilation louvers that are required for component cooling. Electrical cabling within the cabinets is type SIS, flame retardant thermoset or equivalent rated for fire resistance and flame propagation properties. Cabling entering or exiting the cabinets is sealed at the cabinet / cable interface to preclude flame propagation outside the cabinet. All transformers used within the plant structures are small dry transformers, which are classified as ignition sources due to their construction and '

function. Because they do not contain exposed combustible materials, they do not constitute a credible ignition source for a fire in the area.

4. Challenge to Fire Barrier Combustibles within Fire Area 13S consist mainly of electrical cable insulation which is run in cable trays or located within electrical panels. Exposed cable is IEEE l 383 or equivalent rated for flame spread characteristics, and it is therefore not expected that a fire could develop within a cable tray and spread throughout the fire area prior to the arrival of the site Fire Brigade. Electrical cabinets within the area are sealed, with the exception of required vent!!stion louvers. Cables exiting and  ;

entering the cabinets are sealed at the cabinet interface to prevent flame propagation past the cabinet / seal interface. Therefore, it is not expected that a fire  ;

initiated in an electrical cabinet would propagate out of the cabinet.  !

The fire area is open to other fire areas within the Unit 3 Reactor Building. Should a fire initiate in transient combustibles, the smoke and hot gases would vent throughout the building. Due to the volume of the building and the cooling effects of entrained air it is not postulated that a transient fire would be of the magnitude required to damage equipment outside of the immediate area of fire origin prior to the arrival of the site Fire Brigade.

Due to the configuration and quantity of combustibles within the reactor building and the volume of the enclosure, it is not expected that a fire could develop which would ,

challenge the 1-hour fire resistance rating of the installed raceway fire barriers. l Fire Detection and Suppression Capability

1. Automatic Fire Detection Capability Fire Area 13S is provided with area detection which actuates audible and visual alarms in the main control room. Ten (10) smoke detectors are arranged in the area in accordance with the requirements of NFPA 72E,1984. Four (4) heat detectors are located in the west corridor. The heat detectors are logically tied to activate the west corridor CFZ water curtain system.

l PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R ExGmption R;quGst Page 38 of 44

2. Automatic Suppression System A water curtain suppression system is provided as part of the west corridor CFZ to establish divisior, between fire areas 13S and 13N which is the remainder of the reactor building in the western corridor.

The water curtain consists of a piping distribution system with open spray heads.

The distribution piping is located at the floor level and positioned along one side of the corridor with spray heads spaced evenly from the floor to the ceiling. The system is actuated by a cross-zone detection system located at the ceiling level or by manual actuation at one of the two (2) local control stations. The system must be ,

shut-off manually. l

3. Manual Fire Fighting Capability .

1 Upon receipt of an alarm in the main control room, the Fire Brigade will be i dispatched to extinguish the fire. The fire area specific pre-fire strategy plan for Fire i Area 13S will be used by the Fire Brigade. Fire Area 13S is a radiation area, i therefore some specific areas may be contaminated but will not obstruct access to the area. Hose stations for manual fire fighting are available within the area. Each i hose station is provided with 100 feet of 1-1/2" hose, which is capable of covering the entire area. In addition, dry chemical, pressurized water and CO2 extinguishers .

are available to assist in manual fire fighting operations.

Safety Train Information

1. Layout and Configuration of Safety Trains The layout of Fire Area 13S, including the arrangement of major equipment, is shown in Appendix B, Figure 29. The major safe shutdown equipment located in this fire area is:

. Panel 30Y32 Power Transformer 30X132

. Panel 30Y35 Power Transformer 30X135

. 120V AC Distribution Panel 30Y32

. 120V AC Distribution Panel 30Y35

. Jet Pump Flow Transmitter FT3-2-3-63C

. Reactor Vessel Water Level Transmitter LT3-2-3-112

. Reactor Vessel Water Level Transmitter LT3-2-3-113

. Reactor Vessel Water Level Transmitter LT3-2-3-728

. 480V AC Emergency Motor Control Center MCC30B38

. RHR LPCI Injection Valve MO3-10-025A

. Core Spray Loop A Outboard Discharge Valve MO3-14-011 A

. Core Spray Loop A Inboard Discharge Valve MO3-14-012A

. High Drywell Pressure Indicating Switch PISHH3-10-1008

. High Drywell Pressure Indicating Switch PISHH3-10-100D e Reactor Vessel Pressure Indicator Transmitter PIT 3-2-3-60B

. Drywell Pressure Transmitter PT-91028

. Drywell Pressure Transmitter PT-9102D

e- .  !

PBAPS Units 2/3 (Docket Nos. 50-277/278) i 10CFR50, Appendix R Eximption Rtqu:st l Page 39 of 44

. Drywell Pressure Transmitter PT-9458

. Drywell Pressure Transmitter PT3-10-1008

• Drywell Pressure Transmitter PT3-10-100D

. Reactor Vessel Pressure Transmitter PT3-2-3-404B e Reactor Vessel Pressure Transmitter PT3-2-3-404D e Reactor Vessel Pressure Transmitter PT3-6-105 i e Reactor Vessel Pressure Transmitter PT3-6-53B  !

. MSRV Back-up Nitrogen Supply Valve SV-9130B The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire

, area are associated with the following safe shutdown functions:

. . Control of Unit 3 Main Steam Line Safety Relief Valves RV3-02-071E, H & J

. Unit 3 RHR Flow Indication

. Unit 3 Drywell Pressure and Suppression Pool Level Instrumentation

_ Appendix A, Table 15 specifies by fire barrier, the protected safe shutdown cables  ;

and identifies the associated safe shutdown function / equipment protected in this fire  ;

4 area. Appendix B, Figure 30 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 13S contains cables and equipment associated with Unit 2 and Unit 3  !

Safe Shutdown Methods A, B, and C, as described in the PBAPS FPP. Cables l required to support Unit 3 Method B in this fire area are encapsulated by a 1-hour  !

rated fire barrier, or for cables which are not encapsulated, manual operator actions l can be taken to recover any functions that could be lost. Equipment associated with Unit 3 Method B and Unit 2 Methods A, B, and C located in this fire area either have a redundant component located outside the fire area or manual operator actions can be taken to recover any functions that could be lost. Therefore, Unit 3 Safe

, . Shutdown Method B and Unit 2 Methods A, B, and C will be available in Fire Area 13S to safely shutdown the respective units.

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PBAPS Units 2/3 (Docket N:s. 50-277/278) 10CFR50, Appendix R ExImption Requ:st l Page 40 of 44 6.3 TURBINE BUILDING U2 U3

+

R+J <+> m i namen inn i

r J_

Fire Arta 150 Turbine E uilding Elevations 91'-6",102W 116' 0" 1 and 135'-0" to 165'-0" l

i 6.31 Fire Area 150 - Turbine Building " Wing" Areas )

l Fire Area Description l

This area was previously included in Fire Area 50. During the Thermo-Lag reduction and IPEEE Fire Risk Analyses, the barriers (walls) within Fire Area 50 were evaluated.

4 The evaluation concluded that by qualifying certain walls as 3-hour barriers to create additional fire areas, the subdivision would result in lower plant risk due to fire and reduce need for raceway encapsulation.

1. Construction l

!' Firo Area 150 consists of the " wing" areas of the Units 2 and 3 Turbine Building.

The area consists of rooms on the 91',102',116',135' and 1G5' elevations of the 4 Unit 2 and Unit 3 Turbine Building. The area for which an exemption request is applicable consists of rooms 16,17 and 53 on the 91' and 102' elevations.

The Turbine Building condensate demineralizer pump and condensate backwash i

, pump and tank areas on the 91' and 102' elevations of the Units 2 and 3 Turbine Building consist of the two lowest elevations of Fire Area 50. These rooms are bounded by 3-hour fire rated barriers to the east and west where they are exposed to the pipe tunnels, reactor and radwaste buildings. The floor, north and south barriers are below grade and are not rated. The ceiling is exposed to the upper elevations of the fire area through open stairwells and equipment hatches. ,

Penetrations in the rated barriers are sealed to provide a 3-hour fire resistance l rating. '

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PBAPS Units 2/3 (Docket Nos. 50-277/278) '

( 10CFR50, Appendix R Ex:mption R:qu;st j~ Page 41 of 44 j t .

J l 2. Ventilation / Availability of Oxygen Fire Area 150 is an open fire area which encompasses several elevations of the i

, Turbine Building. Due to the size of the area, sufficient oxygen is available to  :

i support a fuel controlled fire within the area. j

3. . Use of Area i Fire Area 150 encompasses several elevations of the Units 2 and 3 Turbine

, Building. The bottom elevation at 91'6" contains the condensate backwash transfer l pumps and receiving tanks. The 102' elevation contains the condensate domineralizer hold pumps for both Units 2 and 3. It is in these two areas where the raceway encapsulations (fire barriers) are located. Other elevations within this fire area are 116',135' and 165' which contain motor control centers, pumps, feedwater l heaters, reactor feed pumps and other equipment associated with Turbine Building i i

operations. 1 Fire Loadina information

1. In-Situ Fire Hazards Fire loading in Fire Area 150 is classified as " Low", with an associated fire duration of less than 45 minutes. Fixed combustibles within the area consist of combustible fire barrier material, cable insulation and small amounts of oil associated with the pumps. On the 91'-6" elevation, polycarbonate sheets have been installed to permit transparent separation of the transfer pumps. The combustible fire barrier material accounts for approximately 60.% of the total combustible loading in the rooms (16 and .17) where it is present.

2. Transient Combustibles The use, storage and types of combustibles materials permitted within this fire area are strictly controlled by plant administrative procedures. If required, compensatory measures are implemented as directed by administrative piocedures and site fire protection personnel.

3. Fire initiators There are several possible ignition sources on the 91' and 102' elevations of Fire Area 150. The 91' elevation, room 17, contains the 2A,2B,3A and 3B Condensate Backwash Transfer Pumps, the Equipment Drain Sump, and the Floor Drain Sump.

The 102' elevation, rooms 16 (Unit 2) and 53 (Unit 3), contains the Unit 2 and Unit 3 A, B, C, D, E, and F Demineralizer Hold Pumps, and the Unit 2 and Unit 3 Demineralizer Pre-coat Pumps. These pumps contain minimal quantities (less than one gallon) of lubricating oil, which is contained within the metal pump casing.

Therefore, the ignition risk from these sources is concidorod to be low.

4. Challenge to Fire. Barrier  !

If a fire were initiated in one of the pump motors, it would be contained within the  !

pump motor. enclosure. Any spill of lubricating oil would spread around the immediate vicinity of the pump itself. In the unlikely event of ignition of the tube oil, l ll

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PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exsmption Requ:st Page 42 of 44 j i

heat and products of combustion would spread along the ceiling and vent into the upper elevations of the fire area. Due to the large volume of the lower elevation rooms, and the location and configuration of the raceway encapsulations, it is not expected that a fire in this area would challenge the 1-hour rated enclosure.

Fire Detection and Suporession Capability

1. Automatic Fire Detection Capability Fire Area 150 is provided with automatic fire detection which actuates audible and visual alarms in the control room. Four (4) smoke detectors are provided on the 91' I elevation and ten (10) smoke detectors are provided on the 102' elevation for both the Unit 2 and Unit 3 sections of the area. The smoke detectors have been arranged in the area in accordance with the requirements of NFPA 72E,1984.

2. Manual Fire Fighting Capability Upon receipt of an alarm in the main control room, the Fire Brigade will be dispatched to extinguish the fire. Fire area specific pre-fire strategy plans for Fire Area 150 will be used by the Fire Brigade. The areas around the pumps are usually contaminated. This will not obstruct access in the area, but may cause l extinguishment concerns associated with run-off. Two (2) hose stations for manual fire fighting are available within the area in the vicinity of the stairwells leading down to the 91' elevation. Each hose station is provided with 100 feet of 1-1/2" hose, which is capable of covering the entire area. Dry chemical fire extinguishers are located in the area to assist in incipient fire fighting operations. l Safety Train Information i

1. Layout and Configuration of Safety Trains The layout of Fire Area 150, including the arrangement of major equipment, is shown in Appendix B, Figure 31. There is no major safe shutdown equipment located in this fire area.

The specific safe shutdown circuits protected by 1-hour fire rated barriers in this fire I area are associated with the following safe shutdown functions:

l

• 4.16kV AC Power to Unit 2 RHR Pump A (2AP35)

. 4.16kV AC Power to Unit 2 RHR Pump C (2CP35)

Appendix A, Table 16 specifies by fire barrier, the protected safe shutdown cables and identifies the associated safe shutdown function / equipment protected in this fire area. Appendix B, Figure 32 depicts the protected safe shutdown circuit routings.

2. Safe Shutdown Capability Fire Area 150 contains cables and equipment associated with Unit 2 and Unit 3 Safe Shutdown Methods A, B, and C. Cables required to suppori both Unit 2 and Unit 3 Method A in this fire area are encapsulated by a 1-hour rated fire barrier, or for cables which are not encapsulated, manual operator actions can be taken to recover any functions that could be lost. Equipment associated with both Unit 2 and Unit 3 Method A located in this fire area either have a redundant component located i

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PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFRSO, Appendix R Exemption Request Page 43 of 44 outside the fire area or manual operator actions can be taken to recover any functions that could be lost. Therefore, Unit 2 and Unit 3 Safe Shutdown Method A will be available in Fire Area 150 to safely shutdown.

7.0 COST OF COMPLIANCE e

PECO Energy is committed to safely resolving the Thermo-Lag 330-1 operability issue and attaining regulatory compliance with 10CFR50, Appendix R. The concept of reanalyzing the safe shutdown compliance configuration of PBAPS was promulgated by a desire to attain compliance cost effectively. The expenditures for work required to '

attain compliance, current and planned, are estimated at $3-3.5 million.

The fire protection alternatives available to attain full regulatory compliance for the fire

• areas discussed in this Exemption Request are, as discussed in Section 3.0, to install automatic fire suppression or upgrade the raceway encapsulations to 3-hour fire resistance rated barriers. Cost estimates (+/- 25%) for both options are shown below.

Included in the ostimate for upgrading to 3-hour barriers is the cost of removal of existing fire barrier materials.

Fire Area Upgrade to 3-Hour Barrier install Automatic Suppression 102 $190,000 $ 45,400 6N $ 18,000 $ 87,600 13S $ 38,800 $ 37,650 25 $159,000 $101,100 31 $ 38,800 $ 45,400 ,

32 $ 97,000 $ 45,400 33 $ 50,000 $ 45,400

]

34 $ 50,800 $ 45,400 35 $ 38,800 $ 45,400 j 36 $ 50,800 $ 45,400 37 $ 70,800 $ 45,400 38 $ 70,200 $ 45,400 39 $ 27,700 $ 45,400 40 $ 38,800 $ 45,400  ;

41 $ 38,800 $ 45,400 150-1 $ 36,650 $ 44,000 150-2 $ 50,800 $ 45,400 j 150-4 $ 27,700 $ 44,000 Totals $1,093,450 $904,550 l

Although the automatic suppression appears to be a viable option in the switchgear areas (Fire Areas 32, 33, 34, 35, 36, 37, 38, & 39), it is not preferred because of the

, potential for inadvertent actuation which may disable the switchgear. Therefore the option required is the 3-hour barrier upgrade. Not included in the cost estimate is the consideration for removal and disposal of material potentially contaminated which

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PBAPS Units 2/3 (Dock 3t Nos. 50-277/278) ,

10CFR50, Appendix R Exemption Request 1 l Page 44 of 44 would require decontamination or disposal as radiation waste. This potential exists for l barriers located in the Turbine and Reactor Buildings. l l

8.0 CONCLUSION

PECO Energy is committed to the principle of defense-in-depth fire protection strategy )

i as discussed in this report. Provided are discussions on activities designed to prevent j fires from starting, and activities associated with fire detection and manual suppression

, to rapidly identify and extinguish fires that do occur, if a fire were to start, area fire detection would actuate providing local and Control Room alarms, resulting in the rapid l_ response of a trained Fire Brigade with fire area specific procedures providing guidance for manual suppression. Should the fire propagate to a point the safe

! operation of the plant is jeopardized, fire. area specific procedures, when used in i

[ conjunction with the TRIP procedures, provide the guidance necessary for Plant '

Operators to achieve safe shutdown. Deterministic evaluations using fire area specific

, plant data demonstrate that plant systems are designed to insure that essential plant  !

functions will not be challenged by the effects of fire. These evaluations included the

structural aspects of the fire area, the characteristics of fixed combustibles including l the anticipated challenge to the raceway. encapsulations, the absence of, or l l administrative controls goveming transient combustibles, and the limited number of '

ignition sources. These evaluations show that in the extremely unlikely event that a fire

, would start, deterministically, it would not propagate to a size that it would challenge i the 1-hour fire resistance rated barriers protecting safe shutdown circuits. Therefore, it j L has been demonstrated that the 1-hour fire resistance rated barriers, with respect to  ;

actual fire loading configurations in the specific fire areas discussed, will, in the event l of a fire, preserve essential equipment operability by providing sufficient protection for  ;

! the protected safe shutdown cables.

! PECO Energy has concluded that these factors, taken together, provide sufficient ,

defense-in-depth to meet the intended level of protection required by 10CFR50, {

l Appendix R. Thus, the criteria of 10CFR50.12(a)(1) are duly met because this  !

4 exemption will not result in undue risk to the public health and safety. The financial cost j associated with replacement of 1-hour barriers with 3-hour barriers is estimated to be i approximately $1 million. This addition to the estimated $3-3.5 million cost of resolving  ;

the PBAPS Thermo-Lag operability issue would be a substantial financial burden and would not result in a net increase in fire protection safety.

.Since upgrading to 3-hour barriers is not, in the cases discussed above, necessary to i achieve the underlying purpose of the regulation, and such modifications would result in costs that significantly exceed those contemplated when the regulation was adopted, j y special circumstances 10CFR50.12(a)(2)(ii) and 10CFR50.12(a)(2)(iii) are applicable.

Therefore, the requested exemption to Appendix R, Section Ill.G.2 specified herein should be granted.

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APPENDIX A

I PBAPS Units 2/3 (Docket Nos. 50-277/278) l 10CFR50, Appendix R Exemption RequGst i Appendix A, Page 1 of 12 {

Table 1. Fire Area 102 Fire Barriers FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.) ,

(size; length) j 147-02 J1201 Junction Box ZA2A1505A 20B10 Load Center Transformer (20X30),  !

(10x10.5x30) 480V Bus Load Center E124 (20810), j 480V AC Motor Control Centers  ;

(MCC00853, MCC00862, MCC20B36, j MCC20B59)  !

14; 03 J535 Junction Box ZA2B1014A, 480V AC Motor Control Centers  !~

(24x26x36) ZA2B1021A (MCC20859, MCC00853), _

125V DC 3C-1 Battery Charger (3CD03-1),

125V DC 2A-1 Battery Charger (2AD03-1),  ;

Panel 20Y33 Power Transformer (20X133), j 120V AC Panel (20Y33), .

. 4.16kV E1 Diesel Generator (OAG12), ,

E1 DG Bldg. Vent Supply Fan (OAV64), [

E1 DG Bid 0. Supplemental Supply Fan j

~

(OAV91),

, E1 Fuel Oil Transfer Pump (OAP60)  !

147-01 ZA2B1249 RS Conduit ZA0AG12 A1, 4.16kV E1 Diesel Generator (OAG12), l (3*; 15ft.) ZA0AG12 A2, DG Directional Power Relay (0-132 AG12), ,

ZAOK40B P DG Protection Relays (0-151 AG12,0-194-  !

AG12),

E12 DG Breaker (2-152-1503), -

E13 DG Breaker (3-1521503),

4.16kV Emergency Aux. Swgr. E12  !

(20A15),  !

4.16kV Emergency Aux. Swor. E13 (30A15) l; 147-02 ZA20001 RS Conduit ZA2A1505A 20B10 Load Center Transformer (20X30),

(3"; inside 480V Bus Load Center E124 (20B10), [

J1201) 480V AC Motor Control Centers I (MCC00853, MCC00862, MCC20B36, i MCC20B59) 147-03 ZA2D432 RS Conduit ZA281021A 480V AC Motor Control Center f (3*; 15 ft.) (MCC00853), l 4.16kV E1 Diesel Generator (OAG12),  ?

E1 DG Bldg. Vent Supply Fan (OAV64), l E1 DG Bldg, Supplemental Supply Fan  :

(OAV91),

l E1 Fuel Oil Transfer Pump (OAP60) i 147-03 ZA2D477 RS Conduit ZA281014A 480V AC Motor Control Center  !

(3.5"; 10 ft.) (MCC20B59),

125V DC 3C-1 Battery Charger (3CD03-1), -

125V DC 2A-1 Battery Charger (2AD03-1),

Panel 20Y33 Power Transformer (20X133), t 120V AC Panel (20Y33) l 147-02 ZA2D855 RS Conduit ZA2A1505A 20B10 Load Center Transformer (20X30), [

(3"; 5 ft.) 480V Bus Load Center E124 (20B10), _

480V AC Motor Control Centers 6 (MCC00853, MCC00B62, MCC20B36.

MCC20B59)  !

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i PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Apper dix R ExGmption Request Appendix A, Page 2 of 12 Table 1. Fire Area 102 Fire Barriers (continued) 147-03 ZA2R006 RS Conduit ZA2B1014A 480V AC Motor Control Center I (5"; inside (MCC20B59), l J535 125V DC 3C-1 Battery Charger (3CD03-1),

125V DC 2A-1 Battery Charger (2AD03-1),

Panel 20Y33 Power Transformer (20X133), l 120V AC Panel (20Y33) 147-03 ZA2R008 RS Conduit ZA2B1021A 480V AC Motor Control Center (5"; inside (MCC00853),

J535) 4.16kV E1 Diesel Generator (OAG12),

E1 DG Bldg. Vent Supply Fan (OAV64),

E1 DG Bldg. Supplemental Supply Fan (OAV91),

E1 Fuel Oil Transfer Pump (OAP60) 147-08 ZA2S676 RS Conduit ZA2Q20758, Main Steam Line A SRVs (RV2-02-071 A, (2.5'; 6 ft.) ZA202075E, RV2-02-0718 )

ZA2Q20768, Main Steam Line B SRV (RV2-02-071C),

ZA2Q2076E, U2 MSRV Back up N2 Supff Valve (SV-ZA2Q20778, 8130A)

ZA202077E, ZA202212B, ZA202212E 147-07 ZA3D001 RS Conduit ZA3A1505A 30810 Load Center Transformer (30X30),

(3"; 5 ft.) 480V Sus Load Center E134 (30B10),

480V AC Motor Control Centers (MCC30836, MCC30B59) 147-06 ZA3D619 RS Conduit ZA3Q20758, Main Steam Line A SRVs (RV3-02-071 A, (2"; 6 ft.) ZA3Q2075E, RV3-02-071B)

ZA3Q20768, ZA302076E 147-01 ZB2B256 RS Conduit ZBOBG12 D1, 4.16kV E2 Diesel Generator (0BG12),

(3"; 15 ft.) ZBOK41B W, DG Protection Relay (0-194-BG12),

ZB2BG121C E23 DG Breaker (3-152-1606),

E22 DG Breaker (2-152-1606),

4.16kV Emergency Aux. Swgr. E22 (20A16),

4.16kV Emergency Aux. Swgr. E23 (30A16) 147-04 ZB3D002 RS Conduit ZB3A1605A 30811 Load Center Transformer (30X31),

(3*; 5 ft.) 480V AC Bus Load Center E234 (30B11),

480V AC Motor Control Centers (MCC00B54, MCC30B37, MCC30860) 147-07 ZB3D599 RS Conduit ZB381114A 480V AC Motor Control Center (4*; 15 ft.) (MCC30B60),

125V DC 3B-1 Battery Charger (3BD03-1),

Panel 30Y34 Power Transformer (30X134),

120V AC Panel (30Y34),

125V DC 2D-1 Battery Charger (2DD03-1),

125V DC 28-1 Battery Charger (2BD03-1)

. ___ . _ _ __._____.________________.m_

i PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50 Appendix R Ex:mption Request Appendix A, Page 3 of 12 l

[ Table 1. Fire Area 102 Fire Barriers (continued) 147-05 ZB3R013 RS Conduit ZB381121A 480V AC Motor Control Center (3"; 5 ft.) (MCC00854),

4.16kVKV E2 Diesel Generator (OBG12),

l E2 Fuel Oil Transfer Pump (OBP60),

! E2 DG Bldg. Vent Supply Fan (OBV64),

E2 DG Bldg. Supplemental Supply Fan (OBV91),

HPSW Discharge to Pond (MO-2486, MO-3486) -

N/A ZA2S106 EMT Conduit ZA2A15018 E312 Breaker (2-152-1501)

-(New' (2"; 20 ft.) ZA2A1501D E212 Breaker (2-152-1508)

Encaps.) ZA2A15088 l ZA2A1508D

! N/A ZB2S117 EMT Conduit ZB2A1601B E322 Breaker (2-152-1601) l (New . (2"; 20 ft.) ZB2A1601D E222 Breaker (2-152-1608)

Encaps.) ZB2A1608B ZB2A1608D Table 2 Fire Area 25 Fire Barriers FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

(size; length) 108A-04 J114 Junction Box ZB2A1605A 20B11 Load Center Transformer (20X31), -!

l (18x18x18) 460V Bus Load Center E124 (20B11),

480V AC Motor Control Centers (MCC00861, MCC20B37, MCC20B60) 108A 03 J116 Junction Box ZD2A1806A 20B13 Load Center Transformer (20X33),

(18x18x18) 460V Bus Load Center E424 (20B13), '

480V AC Motor Control Centers (MCC00850, MCC20B39) 108A-02 J4185 Junction Box ZB3B1121 A 480V AC Motor Control Center (8x24x24) (MCC00B54),

4.16kV E2 Diesel Generator (OBG12),

E2 Fuel Oil Transfer Pump (OBPS0),

E2 DG Bldg. Vent Supply Fan (OBV64),

HPSW Discharge to Pond (MO-2486, MO-3486),

E2 DG Bldg. Supplemental Supply Fan (OBV91),

108A-02 J4187 Junction Box ZD381321 A, 480V AC Motor Control Center (24x24x8) ZD3B1321C (MCC00856),

4.16kV E4 Diesel Generator (DDG12),

E4 Fuel Oil Transfer Pump (ODP60),

E4 DG Bldg. Vent Supply Fan (ODV64),

E4 DG Bldg. Supplemental Supply Fan (ODV91),

ESW DischarDe to Pond (MO-0498)

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Ex:mption Request Appendix A, Page 4 of 12 Table 2. Fire Area 25 Fire Barriers (continued) 108A-05 J515 Junction Box ZD2B1313A 480V AC Motor Control Center (12x36x24) (MCC20B39),

RHR Suction isolation Valve from Suppression Pool (MO2-10-013D),

RHR Suppression Pool Cooling isolation Valves (MO2-10-0348, MO2-10-0398),

RHR LPCI Injection Valves (MO2-10-154B, MO2-10-025A),

RHR HX Discharge Valve (HPSW Side)

(MO2-10-89D),

125V DC 2D-1 Battery Charger (2DD03-1) 10BA-01 J994 Junction Box ZB3A1605A 30611 Load Center Transformer (30X31),

(18x18x32) 480V Bus Load Center E234 (30811),

480V AC Motor Control Centers (MCC00B54, MCC30837, MCC30860) 108A-04 ZB2M002 RS Conduit ZB2A1605A 20B11 Load Center Transformer (20X31),

(3"; 8 ft.) 480V Bus Load Conter E124 (20B11),

480V AC Motor Control Centers (MCC00B81, MCC20B37, MCC20B60) 108A-04 ZB2M006 RS Conduit ZB2A1605A 20811 Load Center Transformer (20X31),

(3"; inside 480V Bus Load Center E124 (20B11),

J114) 480V AC Motor Control Centers (MCC00B61, MCC20B37, MCC20B60) 108A-01 ZB3M002 RS Conduit ZB3A1605A 30811 Load Center Transformer (30X31),

(3*; 15 ft.) 480V Bus Load Center E234 (30B11),

480V AC Motor Control Centers (MCC00B54, MCC30B37, MCC30B60) 108A-02 ZB3R009 RS Conduit ZB3B1121A 480V AC Motor Control Center (3"; 80 ft.) (MCC00854),

4.16kV E2 Diesei Generator (0BG12),

E2 Ft:el Oil Transfer Pump (CBP60),

E2 DG Bldg. Vent Supply Fan (OBV64),

HPSW Discharge to Pond (MO-2486, MO-3486),

E2 DG Bldg. Supplemental Supply Fan (OBV91),

108A-02 ZB3R011 RS Conduit ZB3B1121A 480V AC Motor Control Center (3*; 10 ft.) (MCC00B54),

4.16kV E2 Diesel Generator (0BG12),

E2 Fuel Oil Transfer Pump (OBP60),

E2 DG Bldg. Vent Supply Fan (OBV54),

HPSW Discharge to Pond (MO-2486, MO-3486),

E2 DG Bldg. Supplemental Supply Fan l (OBV91),

! 108A-03 ZD2M004 RS Conduit ZD2A1806A 20B13 Load Center Transformbr (20X33),

(3*; 25 ft.) 480V Bus Load Center E424 (20B13),

480V AC Motor Control Centers (MCC00B50, MCC20B39)

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendb' R Ex:mption Requ;st Appendix A, Page 5 of 12 Table 2. Fire Area 25 Fire Barriers (continued) 108A-03 ZD2M008 RS Conduit ZD2A1806A 20B13 Load Center Transformer (20X33),

(3"; inside 480V Bus Load Center E424 (20B13),

J116) 480V AC Motor Control Centers (MCC00850, MCC20B39) 108A-05 ZD2M073 RS Conduit ZD2B1313A 480V AC Motor Control Center (3.5'; inside (MCC20B39),

J515) RHR Suction isolation Valve from Suppression Pool (MO2-10-013D),

RHR Suppression Pool Cooling isolation Valves (MO2-10-034B, MO210-039B),

RHR LPCI Injection Valves (MO2-10-1548, MO2-10-025A),

RHR HX Discharge Valve (HPSW Side) 4 (MO2-10-89D),

4 125V DC 2D-1 Battery Charger (2DD03-1) 108A-05 ZD2M076 RS Conduit ZD2B1313A 480V AC Motor Control Center

{ (3.5"; 55 ft.) (MCC20B39),

RHR Suction isolation Valve from Suppression Pool (MO2-10-013D),

RHR Suppression Pool Cooling isolation Valves (MO2-10-0348, MO2-10-039B),

! RHR LPCI Injection Valves (MO2-10-1548, 4 MO2-10-025A),

l RHR HX Discharge Valve (HPSW Side) 1 (MO2-10-89D),

125V DC 2D-1 Battery Charger (2DD03-1) 108A-02 ZD3R010 RS Conduit ZD3B1321 A, 480V AC Motor Control Center

(3*; 80 ft.) ZD3B132iC (MCC00B56),

4.16kV E4 Diesel Generator (ODG12),

E4 Fuel Oil Transfer Pump (ODP60),

E4 DG Bldg. Vent Supply Fan (ODV64),

E4 DG Bldg. Supplementr! Supply Fan (ODV91),

ESW Discharge to Pond (MO-0498) 108A-02 ZD3R014 RS Conduit ZD3B1321 A, 480V AC Motor Control Center

, (3*; 10 ft.) ZD3B1321C (MCC00B56),

4.16kV E4 Diesel Generator (0DG12),

E4 Fuel Oil Transfer Pump (ODP60),

E4 DG Bldg. Vent Supply Fan (0DV64).

E4 DG Bldg. Supplemental Supply Fan

(0DV91),

j ESW Discharge to Pond (MO-0498)

)

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• - ..4 l' PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exsmption RequGst Appendix A, Page 6 of 12 i

f Table 3. Fire Area 31 Fire Barriers 4

I FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

{. (size; length)

I 118-01 ZD3D401 RS Conduit ZD3DD01E 125V DC 30 Station Battery (3DD01),

(3'; 10 ft.) 250V DC 3DPB Distribution Panel (3BD18),

125V DC 3 PPD Power Distribution Panel

(30024), ,

! 250V DC HPCI 3DB Bus (30D11), I i 125V DC Panel 3 PPD (300306)

118-01 ZB3D407 RS Conduit ZB301802A 250V DC HPCI 3DB Bus (30D11) i (4*; 25 ft.)

118-01 ZB3D408 EMT ZB301802B 250V DC HPCI 3DB Bus (30011) l (1.5'; 25 ft.)

i 118-02 ZB3D599 RS Conduit ZB3B1114A 480V AC Motor Control Center

(4*; 25 ft.) (MCC30860),

! 125V DC 38-1 Battery Charger (3BD03-1),

[ Panel 30Y34 Power Transformer (30X134),

120V AC Panel (30Y34)

! Table 4. Fire Area 40 Fire Barriers 1 FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

l (size; lenoth)

! 127-01 ZA20001 RS Conduit ZA2A1505A 20B10 Load Center Transformer (20X30),

j~ (3*; 25 ft.) 480V Bus Load Center E124 (20B10),

! 480V AC Motor Control Centers (MCC00862, l MCC20B36. MCC20B59) i

(

1 Table 5. Fire Area 41 Fire Barriers i  !

! FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

4 (size; length) 128-01 ZB2D407 RS Conduit ZB2D1802A 250V DC HPCI 2DB Bus (20011)

(4"; 20 ft.) ZB2D18028 128-02 ZB2D402 RS Conduit ZB2BD01E 125V DC 2B Station Battery (2BD01), ,

(3*; 10 ft.) 250V DC 2DPB Distribution Panel (2BD18),

125V DC 2 PPB Power Distribution Panel l (20D22), 1 250V DC HPCI 2DB Bus (20D11),

125V DC Panel 2 PPB (2BD306) l l

l i

l l

l

l

. , 1 l PBAPS Units 2/3 (Docket Nos. 50-277/278) l 10CFR50, Appendix R Ex:mption Request ,

i Appendix A, Page 7 of 12 l Table 6. Fire Area 32 Fire Barriers FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

(size; len0th) 119-02 J4151 Junction Box ZB381121 A 480V AC Motor Control Center (24x24x8) (MCC00B54),

4.16kV E2 Diesel Generator (OBG12),

E2 Fuel Oil Transfer Pump (OBP60),

E2 DG Bldg. Vent Supply Fan (OBV64),

E2 DG Bldg. Supplemental Supply Fan (OBV91),

HPSW Discharge to Pond (MO-2486, MO-3486) 119-02 J4153 Junction Box ZB3B1321 A, 480V AC Motor Control Center (24x24x8) ZB381321C (MCC00B56),  !

4.16kV E4 Diesel Generator (ODG12),

E4 Fuel Oil Transfer Pump (ODP60),

E4 DG Bldg. Vent Supply Fan (0DV64), l E4 DG Bldg. Supplemental Supply Faa )

(ODV91),

ESW Discharge to Pond (MO-0498),

HPSW Discharge to Reservoir (MO-3803) 119-02 ZB3D436 RS Conduit ZB3B1121 A 480V AC Motor Control Center (3*; 10 ft.) (MCC00B54),

4.16kV E2 Diesel Generator (OBG12), 1 E2 Fuel Oil Transfer Pump (OBP60), l E2 DG Bldg. Vent Supply Fan (OBV64), l E2 DG Bldg. Supplemental Supply Fan (OBV91),

HPSW Discharge to Pond (MO-2486, MO-3486) 119-02 ZB3R013 RS Conduit ZB3B1121A 480V AC Motor Control Center I (3"; 20 ft.) (MCC00B54),

4.16kV E2 Diesel Generator (OBG12),

E2 Fuel Oil Transfer Pump (OBP60), ,

E2 DG Bldg. Vent Supply Fan (OBV64), l E2 DG Bldg. Supplemental Supply Fan (OBV91),

HPSW Discharge to Pond (MO-2486, MO-3486) 119-01 ZD3D401 RS Conduit ZD3DD01E 125V DC 3D Station Battery (3DD01),  ;

(3*; 21 ft.) 250V DC 3DPB Distribution Panel (3BD18),  !

125V DC 3 PPD Power Distribution Panel  ;

(30D24), i 250V DC HPCI 3DB Bus (30D11),

i 125V DC Panel 3 PPD (3DD306) j l

, i f

l

~

PBAPS Units 2/3 (Docket Nos. 50-277/278) .

10CFR50, Appendix R ExGmption Request  !

- ~ + Appendix A, Page 8 of 12 1 4

- Table 6. Fire Area 32 Fire Barriers (continued)  !

~

I 119-02 ZD3D437 RS Conduit ZD381321A 480V AC Motor Control Center

[ (3*; 10 ft.) - ZD381321C (MCC00856), i 4.16kV E4 Diesel Generator (ODG12),  ;

E4 Fuel Oil Transfer Pump (ODP60),

, E4 DG Bldg. Vent Supply Fan (ODV64), t E4 DG Bldg. Supplemental Supply Fan (ODV91), ,

l ESW Discharge to Pond (MO-0498), l

. HPSW Discharge to Reservoir (MO-3803)  ;

119-02 ZD3R015 RS Conduit ZD381321A 480V AC Motor Control Center  !

(3*; 20 ft.) ZD381321C (MCC00B56),

4.16kV E4 Diesel Generator (ODG12), .

1 E4 Fuel Oil Transfer Pump (ODP60), i E4 DG Bldg. Vent Supply Fan (0DV64),

E4 DG Bldg. Supplemental Supply Fan  ;

(ODV91),  !

ESW Discharge to Pond (MO-0498), l HPSW Discharge to Reservoir (MO-3803) l Table 7. Fire Area 33 Fire Barriers I FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

(size: length) 120-03 ZD3D596 RS Conduit ZD3DD01H 250V DC 3DPB Distribution Panel (38018),

(3"; 24 ft.) 125V DC 3 PPD Power Distribution Panel (30D24),

250V DC HPCI 3DB Bus (30D11),

125V DC Panel 3 PPD (3DD306)

I Table 8. Fire Area 34 Fire Barriers FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

(size: length) 121-01 ZC3D481 RS Conduit ZC3D2306A 125V DC Distribution Panel E3 DG (2"; 20 ft.) (OCD13),

4.16kV E3 Diesel Generator (OCG12) 121-01 ZC3D482 RS Conduit ZC3D2302A E332 Breaker (2-152-1701),

(2*; 20 ft.) E232 Breaker (2-152-1708),

E32 DG Breaker (2152-1704),

ESW Pump B (OBP57),

20812 Load Center Transformer (20X32),

RHR Pump C (2CP35),

Core Spray Pump C (2CP37),

HPSW Pump C (2CP42),

4.16kV Emergency Aux. Swgr. E32 (20A17)  :

121-02 ZC3D600 RS Conduit ZC2A1702J, RHR Pump C (2CP35), 1 (1.5"; 22 ft.) ZC3A17 A DG Differential Relays (0-187-CG12, D 186- 1 CG12),

4.16kV E3 Diesel Generator (OCG12),

E32 DG Breaker (2-152-1704), ,

E33 DG Breaker (3-152-1704), )

4.16kV Emergency Aux. Swgr. E32 (20A17), j 4.16kV Emergency Aux. Swgr. E33 (30A17) i I

.. . - . - - . - . - - . ~ . . ~ - - - - - - - - - - - - - - - - - - -

I ' * '

PBAPS Units 2/3 (Docket Nos. 50-277/278) '

10CFR50, Appendix R Eximption Requist

j. Appendix A, Page 9 of 12

. Table 9. Fire Area 35 Fire Barriers  !

! FBS No. Raceway No. Raceway Type Cable No. Equipment Description (Eq. Nos.) i (size; length) 122-01 ZA2D747 RS Conduit ZA0G03,H 4.16kV Et Diesel Generator (OAG12)

(3*; 20 ft.)' i 122-02 ZA2D832 RS Conduit ZA2A1506K, RHR Pump A (2AP35), j (3*; 22 ft.) ZA2AG1218 DG Protective Relay (0-194-AG12) <i 122 02 ZA2D841 RS Conduit ZA2D2108A E313 Breaker (3-152-1501),

(3*; 22 ft.) E213 Breaker (3-152-1508),

E13 DG Breaker (3-152-1503) 30810 Load Center Transformer (30X50),

RHR Pump A (3AP35),

Core Spray Pump A (3AP37),

HPSW Pump A (SAP 42),

4.16kV Emergency Aux. Swor. E13 (30A15) 122-03 ZA3D600. RS Conduit ZA2A1506J RHR Pump A (2AP35), 4 (3"; 22 ft.) ZA3A15_D DG Differential Relay (0-187-AG12)

Table 10. Fire Area 36 Fire Barriers FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

(size; length) 123-01 ZC3D481 RS Conduit ZC3D2306A 125V DC Distribution Panel E3 DG (2"; 20 ft.) (OCD13),

4.16kV E3 Diesel Generator (OCG12) 123-01 ZC3D482 RS Conduit ZC3D2302A E332 Breaker (2-152-1701),

(2*; 20 ft.) E232 Breaker (2-152-1708),

E32 DG Breaker (2-152-1704),

ESW Pump B (OBP57),

20B12 Load Center Transformer (20X32),

RHR Pump C (2CP35),

Core Spray Pump C (2CP37),

HPSW Pump C (2CP42), J 4.16kV EmerDency Aux. Swor. E32 (20A17) l 123-01 ZC3D600 RS Conduit ZC2A1702J, RHR Pump C (2CP35), i (1.5"; 22 ft.) ZC3A17 A DG Differential Relays (0-187-CG12,0-186- I CG12),

4.16kV E3 Diesel Generator (OCG12),

E32 DG Breaker (2-152-1704),

E33 DG Breaker (3-152-1704),  ;

4.1BW Umergency Aux. Swgr. E32 (2M17),

4.16kV Emeruency Aux. Swor. E33 (30A17) i i

PBAPS Units 2/3 (Dock:t Nos. 50-277/278) 10CFR50, Appendix R Ex:mption R:qu:st Appendix A, Page 10 of 12 Table 11. Fire Area 37 Fire Barriers l

FBS No. Raceway No. Raceway Type Cable No. Equipment Description (Eq. Nos.)

(size; length)

, 124-01 ZA2D747 RS Conduit ZA0G03_H 4.16kV E1 Diesel Generator (OAG12) l (3*; 20 ft.)

124-02 ZA2D832 RS Conduit ZA2A1506K, RHR Pump A (2AP35),

(3*; 22 ft.) ZA2AG121B DG Protective Relay (0-194-AG12) 124-02 ZA2D833 RS Conduit ZA3A1506J RHR Pumo A (3AP35)

(3*,22 ft) 124-02 ZA2D641 RS Conduit ZA2D2108A E313 Breaker (3-152-1501),

(3"; 22 ft.) E213 Breaker (3-152-1508),

E13 DG Breaker (3-152-1503) 30810 Load Center Transformer (30X30),

RHR Pump A (3AP35),

Core Spray Pump A (3AP37),

HPSW Pump A (3AP42),

4.16kV Emergency Aux. Swgr. E13 (30A15) 124-02 ZA3D600 RS Conduit ZA2 1506J RHR Pump A (2AP35),

(3* 22 ft.) ZA3A15_D DG Differential Relay (0-187-AG12)

Table 12. Fire Area 38 Fire Barriers FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

(size: length) 125-02 J4205 Junction Box ZD2DD01E 125V DC 2D Station Battery (2DD01),

(18x18x18) 250V DC 2DPB Distribution Panel (2BD18),

125V DC 2 PPD Power Distribution Panel (20D24),

250V DC HPCI 2DB Bus (20D11) 125-01 ZB2D402 RS Conduit ZB2BD01E 125V DC 28 Station Battery (2BD01),

(3*; 20 ft.) 250V DC 2DPB Distribution Panel (2BD18),

125V DC 2 PPB Power Distribution Panel (20D22),

250V DC HPCI 2DB Bus (20D11),

125V DC 2 PPB Distribution Panel (2BD306) 125-02 ZD2D417 RS Conduit ZD2DOO1E 125V DC 2D Station Battery (2DD01),

(3"; 1 ft.) 250V DC 2DPB Distribution Panel (2BD18),

125V DC 2 PPD Power Distribution Panel (20D24),

-250V DC HPCl 2DB Bus (20D11) 125-02 ZD2D442 RS Conduit ZD2DD01E 125V DC 2D Station Battery (2DD01),

(3"; 19 ft.) 250V DC 2DPB Distribution Panel (2BD18),

125V DC 2 PPD Power Distribution Panel (20D24),

250V DC HPCl 2DB Bus (20D11) i

PBAPS Units 2/3 (Docket Nos. 50-277/278) 10CFR50, Appendix R Exemption Request Appendix A, Page 11 of 12 l Table 13. Fire Area 39 Fire Barriers '

FBS No. Raceway No. Raceway Type Cable No. Equipment Description (Eq. Nos.)

(size; length) 126-01 J4206 Junction Box ZD2DD01E 125V DC 2D Station Bettery (2DD01),

(12x18x18) 250V DC 2DPB Distribution Panel (2BD18),

125V DC 2 PPD Power Distribution Panel (20D24),

250V DC HPCl 2DB Bus (20D11) 126-01 ZD2D417 RS Conduit ZD2DD01E 125V DC 2D Station Battery (2DD01),

(3'; 20 ft.) 250V DC 2DPB Distribution Panel (2BD18),

125V DC 2 PPD Power Distribution Panel (20D24),

250V DC HPCl 2DB Bus (20D11) 126-01 ZD2D617 RS Conduit ZD2DD01E 125V DC 2D Station Battery (2DD01),

(3"; 5 ft.) 250V DC 2DPB Distribution Panel (2BD18),

125V DC 2 PPD Power Distribution Panet (20D24),

250V DC HPCl 2DB Bus (20D11) 126-02 ZB2D1020 RS Conduit ZB2BD01H 125V DC 2B Station Battery (2BD01),

(3*; 22 ft.) 250V DC 2DPB Distribution Panel (2BD18), ,

125V DC 2 PPB Power Distribution Panel i (20D22),

250V DC HPCI 2DB Bus (20D11) 125V DC Panel 2 PPB (2BD306)

Table 14. Fire Area 6N Fire Barriers l

FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.) l (size; length) 5H-02 ZA2S684 RS Conduit ZA2Q20758, Main Steam Line A SRVs (RV2-02-071 A, (2.5'; 5 ft.) ZA2Q2076B, RV2-02-0718),

ZA2020778, Main Steam Line B SRVs (RV2-02-071C, ZA2Q20788, RV2-02-071D, RV2-02-071F),

ZA2Q20798, Main Steam Line C SRV (RV2-02-071G),

ZA202080B, Main Steam Line D SRVs (RV2-02-071K, ZA2Q20828, RV2-02-071L)

ZA202085C Table 15. Fire Area 13S Fire Barriers FBS No. Raceway No. Raceway Type Cable Nos. Equipment Description (Eq. Nos.)

(size; length) 13P-02 ZB3S262 RS Conduit ZB3Q20810, Main Steam Line B SRV (RV3-02-071E),

(1.5'; 6 ft.) ZB302083C, Main Steam Line C SRVs (RV3-02-071H, ZB3Q2084B RV3-02-071J) 13P-03 ZC3S254 RS Conduit 3Q1414B, RHR Flow Indicator (Fl3-10-1398),

(2*; 6 ft.) ZC302251 A U3 Drywell Pressure Recorder (PR-3508) 13P-03 ZD3S255 RS Conduit ZD31892 A U3 Supp. Pool Level Recorder (LR 91238)

(1.5"; 6 ft.)

PBAPS Units 2/3 (Dockit N::s. 50-277/278) 10CFR50, Appendix R Ex;mption Requrst Appendix A Page 12 of 12

- Table 16. Fire Area 150 Fire Barriers FSS No. Raceway No, Raceway Type Cable Nos. Equipment Description (Eq. Nos.) i (size; length) 78A-02 J01 Junction Box ZA2A1506A RHR Pump A (2AP35)

(12x12x30) 78A-02 ZA2B143 RS Conduit ZA2A1506A RHR Pump A (2AP35)  ;

(6"; 15 ft.) 1 78A-02 ZA2 LOO 1 PVC Conduit ZA2A1506A RHR Pump A (2AP35) .

(6*; inside J01) 78A-04 J17 Junction Box ZC3A1702A RHR Pump C (3CP35) 2 (24x24x24) 78A-04 s20 Junction Box ZC3A1702A RHR Pump C (3CP35)

(18x30x12) 78A-04 ZC3B137 RS Conduit ZC3A1702A RHR Pump C (3CP35)

(6"; ift.)

78A-04 ZC38150 RS Conduit ZC3A1702A RHR Pump C (3CP35)

)

(6*; 10 ft.)

i 78A-04 ZC3LO10 PVC Conduit ZC3A1702A RHR Pump C (3CP35)

(6*; 2.5 ft.;

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ELEVATION 135' 0" FIRE AREA 32 ROOM 261

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.,., APPENDIX B FIGURE 23

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