ML20210U607

Forwards Results of 860930 Meeting W/Nrc Re Issues in Technical Evaluation Rept Including Reactor Coolant Pump Oil Collection Sys,Structural Steel,Main Control Room & 579 Ft Elevation of Auxiliary Bldg.W/One Oversize Drawing

ML20210U607
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/09/1987
From:	Leblond P COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20210U611	List: ML20210U607 ML20266B386
References
2645K, NUDOCS 8702180523
Download: ML20210U607 (31)

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3 One First Nabonal Plaza, Chicago, Cnois Address Reply to: Post Cmco Box 767 Chicago, Illinois 60690 0767 February 9, 1987 Mr. Harold R. Denton, Director Office of Nucleur Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Zion Nuclear Power Station Units 1 and 2 Fire Protection NRC Docket Nos. 50-295 and 50-304 References (a): August.12, 1986 letter from J. A. Norris to D. L. Farrar.

(b): July 27, 1984 letter from R. N. Cascarano to H. R. Denton.

(c): August 31, 1984 letter from R. N. Cascarano to H. R. Denton.

(d): January 24, 1985 letter from R. N. Cascarano to H. R. Denton.

(e): February 18, 1986 letter from P. C. LeBlond to H. R. Denton.

Dear Mr. Denton:

Reference (a) provided Commonwealth Edison Company (Ceco) with a Technical Evaluation Report (TER) prepared by the NRC Staff's contractor, Franklin Research Center. The TER was provided to CECO for review and comments regarding CECO's exemption request from Sections III.G and III.O of 10 CPR 50, Appendix R.

These requests were originally made in reference (b) and were augmented by references (c), (d) and (e).

A meeting was held in Bethesda, MD on September 30, 1986 between Ceco personnel and Mr. J. A. Norris, along with other members of your staff.

The purpose of this meeting was to discuss the content of the TER transmitted by reference (a).

The TER had identified concerns with four exemption requests. Those four requests involved the following:

(1) Reactor coolant pump lube oil collection system (2) Structural steel 8702180523 870209 5

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(3) Main control room (4) The 579' elevation of the auxiliary building This letter documents the results of the September 30 meeting regarding the above four issues. The conclusion of that meeting was that exemption requests were no longer required for Items 1, 2 and 3 above. In addition, Issue 4 was determined to require additional modifications to the 579' elevation of the auxiliary building. These issues are discussed separately below:

Reactor Pump Lube Oil Collection System The draft TER transmitted by reference (a) proposed denial of the j

exemption request for RCP lube oil collection system based upon the following concerns:

(1) that the entire system is not capable of 4

f collecting oil from all pressurized leakage sites and (2) that there is no reasonable assurance that the entire system including the rubber hose connections will withstand a safe Shutdown Earthquake (SSE).

Ceco's response to Item (1) was that the system could collect and contain all the oil from both pressurized and non-pressuirzed leakage sites.

Photographs and drawings of the system were presented indicating that the installed shields and associated drip pans provided adequate coverage, and compared favorably with configurations approved by the NRC at similar plants. Also, Ceco personnel pointed out that the systems drained into the abandoned PLOCAP sump which has a capacity well in excess of the i

quantity of oil contained in all four RCP lube oil systems. Furthermore, this sump was designed integral to the containment structure base mat, and was therefore, by definition, seismically designed. The NRC staff l

members present concurred with Ceco's position at the time of this discussion. No further action is planned on this item.

CECO's response to-Item (2) was that the hard pipe ring header and associated drain piping to the PLOCAP sump was designed to withstand an i

SSE.

NRC Staff members stated that, while the hard pipe portion of the system was seismically designed, no assurance or calculations verifying the seismic adequacy of the rubber hoses that connect all of the drip pans to the ring header, had been provided.

CECO has performed and completed seismic calculations on the rubber hose i

portion of the lube oil collection system and, determined that once minor modifications to the system are completed, that the entire RCP lube oil collection system will be seismically qualified. These minor modifica-tions, which consist of rerouting hose and adding additional hose clamps, l

will be completed during the current Unit I refueling outage, and for Unit 2, by the end of the Spring 1987 refueling outage.

As, upon completion of the modifications, the reactor coolant pump lube oil collection system will be able to withstand the dynamic loads associated l

with a SSE, Ceco formally withdraws the exemption request regarding 10 l

CPR 50, Appendix R,Section III.O.

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'l Mr. H. R. Denton February 9, 1987 Structural steel The draft TER proposed denial of the exemption request for structural steel based upon the following concerns:

(1) that the fire duration was not representative of the actual burn rates for the combustibles installed, and (2) that the effects of localized heating on unprotected structural steel due to direct exposure to fire plumes from localized combustible packages, were not evaluated.

CECO's response to Items 1 and 2, given the clarification and guidance provided in Generic Letter 86-10, is to withdraw the exemption request for structural steel. CECO withdraws this exemption based upon statements in Generic Letter 86-10 which specifically identifies that where structural steel has been previously reviewed and approved under Appendix A to Branch Technical position 9.5-1, no further protective measures need be required for Appendix R.

We have reviewed CECO's BTp 9.5-1 submittal and have found that, for those structural steel members identified in the exemption requests transmitted by reference (b), the same structural members were previously reviewed and approved under the Appendix A submittal.

Main Control Room The draft TER proposed denial of the exemption request for the main control room based upon the following concerns: (1) that a fire in one control room or in the common corridor between the unit control boards could affect both control rooms simultaneously and/or cause simultaneous control room evacuations; and (2) that the main control boards for the two units in a single fire zone represent a significant given current alternative shutdown manpower require;aents.

CECO has maintained that, due to continuous manning requirements, the location of detection in the control room ceiling and the separation of the two units control boards, that in the unlikely event of a fire, the fire would be detected in its incipient stages and quickly extinguished.

Consequently, a single fire could only affect the control boards of one unit.

However, in order to meet the requirements, address the NRC Staff's concerns and to expedite the process, Ceco will revise the existing one unit affected, two unit remote shutdown procedure to include a two unit affected, two unit shutdown scenario. We have confirmed that adequate manpower is available to accomplish the required actions.

s Mr. H. R. Denton February 9, 1987 These procedures are currently being written. We anticipate that these procedures will be completely written by January 31, 1987. Past experience with these procedures for the one-unit:affected scenario has shown that after the first draft is complete another 4-6 months of refinement and training of the operators to the procedures is required to assure a completely workable plant shutdown. Ceco, therefore, is projecting that these two unit affected, alternate-(remote) shutdown procedures will be completely implemented by August 1, 1987. In parallel with this effort, a revised Section 6 to the Zion Station Appendix R Safe Shutdown Report dated July 1984, will be completed and incorporated into the 1984 submittal by July 15, 1987.

Based upon the above discussion, the exemption request from section III.G of Appendix R is no longer required. Ceco therefore formally withdraws the exemption request from Section III.G requirements.

579' Elevation of the Auxiliary Building The draft TER identified a number of those areas of concern for this elevation of the auxiliary building. These areas of concern were the following: (1) that access was restricted to the governor control valve associated with the turbine driven auxiliary feedwater pump as a result of a fire at the motor drive auxiliary feedwater pump and local carbon dioxide hetuation; (2) close proximity of safe shutdown components and circuits in the southern portion of fire zone 11.3-0; and (3) that the ionization detectors in the fire zone 11.3-0 containing the Unit 1 auxiliary feedwater pumps are not installed in accordance with NFPA 72E.

During the discussion of the items, the NRC Staff clarified their position stating that the main concern on this level of the auxiliary building was the effects of an exposure fire in the area of the auxiliary feedwater pumps. The concern was expressed that given the congested nature in the areas of these pumps, a fire, placed in certain areas around the perimeter of the pumps, had the potential for damaging all three auxiliary feedwater pumps.

Ceco continues to maintain that this area is adequately protected for the hazards in the area by rerouting and rewrapping the auxiliary feedwater pump power cables and by having local application of carbon dioxide on the pumps themselves. However, in order to expedite the Appendix R review process, Ceco will provide an extension of the existing part height, part length wall that separates the turbine driven auxiliary feedwater pump from the motor driven pumps such that a fire in the area of the auxiliary feedwater pump could not be postulated to affect all three pumps. Attachment 1 to this letter provides a plan view and details of this wall extension, CECO requests a review be performed by the NRC such that concurrence to the details as identified in the attachment can be obtained. Upon concurrence from the NRC on the modified wall details, CBCo will commit to having the walls installed on both units within a period not to exceed six months.

I Mr. H. R. Denton February 9, 1987 CECO therefore requests that the NRC grant the exemption previously requested for the Auxiliary Building in the July 1984 submittal, as modified by the addition of the above modification. The original exemption request for the 579' level contained in reference (b) is reproduced in Attachment 2 for ease of review.

If any further questions arise regarding this matter, please direct them to this office.

Very truly yours, PA 4LLol P. C. LeBlond Nuclear Licensing Administrator 1m cc: Resident Inspector - Zion J. A. Norris - NRR Regional Administrator - RIII (w/o Att.)

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4 a O I s ? ATTACHMENT 2 2645K I

592, and 617 ft elevations, respectively) prior to entering Fire Area 3.1-1, the Unit 1 outer Cable Spreading Room, on the 630 ft elevation. The routing of the CCW pump power feeds, with those for pumps OA and OB run on the Unit 2 half of the Auxiliary Building and those for pumps OC, OD, and OE run on the Unit I half within radwaste rooms, ensures that at least two CCW pump power feeds will remain free of fire damage on the upper elevations of the Auxiliary Building fire area (see Figures 7.4-2 through 7.4-5). 7.4.4.3 579 ft Elevation The 579 ft elevation, as shown in Figure 7.4-3, consists of the following fire zones having floor areas, clear floor-to-ceiling heights, and equivalent fire severities in terms of minutes of burn time and combustible loading as indicated: Floor to Equivalent Floor Ceiling Fire Combustible Height Severity Loading Areg) (ft (ft) (min.) Btu /ft Fire Zone 11.10-0 2,312 ~ 49 <1 Negligible 11.2C-1 185 ~ 11 <l Negligible ll.2C-2 185 ~ 11 <1 Negligible ll.2D-1 185 - 11 <1 Negligible ll.2D-2 185 ~ 11 <1 Negligible 4 11.3-0 12,490 - 11 14 1.915 x 10 4 ll.3A-1 313 - 11 19 2.575 x 10 4 11.3A-2 313 ~ 11 19 2.575 x 10 Page 7-33

.=. Floor to Equivalent Floor Ceiling Fire Combustible Height Severity Loading Areg) (ft (ft) (min.) Btu /ft Fire Zone 4 11.3B-1 302 ~ 11 20 2.67 x 10 4 11.3B-2 302 ~ 11 20 2.67 x 10 4 ll.3C-1 279 ~ 11 23 3.06 x 10 4 11.3C-2 279 ~ 11 23 3.06 x 10 11.3D-1 1,369 ~ 11 <1 Negligible 11.3D-2 1,369 ~ 11 <1 Negligible 4 ll.3E-1 1,787 - 11 9 1.15 x 10 3 ll.3E-2 2,403 ~ 11 6 7.99 x 10 The majority of the combustible loading on this elevation is confined to the centrifugal and reciprocating charging pump cubicles located in Fire Zones 11.3A-1, 11.3A-2, 11.38-1, 11.3B-2, ll.3C-1 and ll.3C-2. This consists of 52 to 55 gallons of lubricating oil located inside each charging pump cubicle. These fire zones are constructed such that any postulated fire would be essentially confined to the cubicle in which it occurs due to the 24-in.-thick reinforced concrete wall construction and the unrated hollow metal access doors with sheet metal transoms. Although fire could spread to the general floor area of this elevation through the unrated door with metal transom, there is a low probability that the lubricating oil would become involved in a fire due to the location of the oil (within the pumps), its high flashpoint (~ 450 F), lack of sufficiently hot surfaces 0 Page 7-34

e within each cubicle to raise the temperature of the lube oil up q ,co its flashpoint, and because each cubicle is a controlled location with the door normally locked and with daily fire hazards inspections. Transient combustibles will have a limited impact on safe I shutdown components on this elevation due to equipment separation distances, proposed one-hour protection for power feeds, and the large floor area in which transient combustibles would be located (Fire Zone 11.3-0 with an area of 12490 ft2). In Fire Zone 11.3-0, approximately 80 gallons of lube oil would be required to raise the combustible loading by 1000 Btu /ft2, Safe shutdown components on this elevation consist of the Unit 1 centrifugal charging pumps in Fire Zones ll.3A-1 and ll.3B-1, the Unit 2 centrifugal charging pumps in Fire Zones 11.3A-2 and ll.3B-2, the Unit 1 AFW pumps located along the east wall opposite the Unit 1 charging pump cubicles, the Unit 2 AFW l pumps located on the east wall opposite the Unit 2 charging pump

cubicles, the remote shutdown panels located outside the respective Unit 1 and Unit 2

charging pump cubicles, and the power feeds for the six service water pumps located in the Crib House. The separation analysis for each component is discussed below. (A) Centrifuoal Charging Pumos one centrifugal charging pump per unit is required to s? achieve'and maintain hot shutdown. The closest Unit 1 to Unit 2 6 Page 7-35 5 F 7-. - - -..,,. - -

charging pump cubicle and power feed separation distance is in excess of 70 ft. The centrifugal charging pump power feeds for each unit run up to the 617 ft elevation of the Auxiliary Building. Centr,ifugal charging pumps lA and 2A~ power feeds (from Fire Zones ll.3A-1 and ll.3A-2) will be rerouted such that they enter Fire Areas 18.6A-1 and 18.6A-2, respectively, on the 617 ft elevation. The routing of these feeds continues from Fire Zones 11.3B-1 and 11.3B-2 on the 579 ft elevation up to the 617 ft elevation and enters Fire Areas 3.1-1 and 3.1-2, respectively, on the 630 ft elevation (see Figures 7.4-3 through 7.4-5). Within each unit, the charging pump cubicles are located side-by-side, with the walls of each cubicle constructed of 18-in.-thick reinforced concrete. An unrated door with metal transom provides access into each cubicle through the east wall of each

cubicle, with the access doors into the redundant charging pump cubicles separated by a T-shaped extension of the common vall between cubicles.

The Unit 1 charging pumps in Fire Zones ll.3A-1 and ll.3B-1 are separated by a three-hour-rated wall; the only penetration of this wall is a ventilation duct that will have a three-hour fire-rated damper. This same configuration applies to the Unit 2 charging pumps in Fire Zones 11.3B-2 and ll.3A-2 resulting in conformance with Appendix R Section III.G.2(a) for redundant charging pump cubicles. Outside of the Unit 1 charging pump cubicles, the power feed for pump 1A vill be rerouted in conduit with approximately Page 7-36

20 ft of separation from the power feed for pump 1B. The power feeds for pumps lA and 1B will both be located in Fire Zones 11.3-0 and 11.4-0, which are the large open areas of the 579 and 592 ft elevations. On the 617 ft elevation, the power feed for pump 1A will run in Fire Zone ll.5D-0 (the Rad Protection / Health Physics offices) prior to entering Fire Area 18.6A-1, the Unit 1 enclosed stairwell; the power feed for pump 1B is run in Fire Zone 11.5-0 (the large open area on this elevation) prior to entering Fire Area 3.1-1, the Unit 1 Outer Cable Spreading Room. Except for the 579 ft elevation, a minimum of 20 ft free of intervening combustibles will exist between the Unit 1 redundant centrifugal charging pump (CCP) power feeds. Intervening combustibles between redundant CCP power feeds on the 579 ft elevation consist of the remote shutdown panels and an open cable tray. A one-hour wrap will be provided on the power feed for charging pump 1A from the point that it exits Fire Zone 11.3A-1 throughout its entire run on the 579 ft elevation (Fire Zone 11.3-0). Outside of the Unit 2 charging pump cubicles, the power feed l for pump 2A will be rerouted in conduit out the south wall of the cubicle into Fire Zone ll.3E-2, Unit 2 pipe chase. It will run i l west in Fire Zone ll.3E-2 until it is due north of the open stair / elevator. combination in Fire Zone 11.3-0, at which point it r will enter Fire Zone 11.3-0. The feed for pump 2B currently exits Fire Zone 11.3B-2 through its east wall and enters Fire i Page 7-37 L

Zone 11.3-0. The reroute of CCP 2A will assure that a distance well in excess of 20 ft free of intervening combustibles will exist between the power feed for CCP pumps 2A and 2B on the 579 ft elevation. The power feeds for both Unit 2 pumps will run in vertical metal-enclosed risers through Fire Zone 11.4-0 on the 592 ft 4 elevation with an excess of 60 ft free of intervening combustibles. On the 617 ft elevation, the feed for pump 2A is run horizontally in Fire Zones 11.5-0 and ll.5D-0 prior to entering Fire Area 18.6A-2. Fire Zones 11.5-0 and 11.5D-0 are totally enclosed rooms constructed of full-height unrated barriers. The feed for pump 2B is run vertically through Fire Zone ll.5A-0, which is totally enclosed by full-height unrated barriers, prior to entering Fire Area 3.1-2, the Unit 2 Outer Cable Spreading Room, on the 630 ft elevation. The routing of the power feeds for pumps 2A and 2B within separately enclosed fire zones on the 617 ft elevation results in separation by both full-height unrated partitions and a distance in excess of 20 ft free of intervening combustibles. Figures 7.4-3 through 7.4-5 identify the location of detection and manual suppression capabilities on these elevations. (B) AFW Pumps The Unit 1 AFW pumps are located side-by-side on a north-south orientation, with the two motor-driven pumps to the south l Page 7-38

and the turbine-driven pump to the north. The Unit 2 AFW pumps are in the same north-south orientation; however, the motor-driven pumps are to the north and the turbine-driven pump is to the south. The minimum separation distance between the southernmost motor-driven pump and turbine-driven pump for Unit 1 is approximately 23 ft. For Unit 2, the minimum separation between the northernmost motor-driven pump and the turbine-driven pump is approximately 16 ft. The minimum straight-line separation distance between Units 1 and 2 AFW pumps is in excess of 31 ft; however, this travel route requires passing through the Concentrates Holding Tank Room, which is enclosed by full-height concrete walls. Along the normal travel route down the 7-ft-wide and 21-ft-long corridor connecting the Unit 1 and Unit 2 portions of.this elevation, this separation distance is approximately 56 ft. The 21-ft-long corridor does not contain any exposed combustibles as all cable passing through the corridor is routed in conduit. This results in a distance of greater than 20 ft free of intervening combustibles, which provides reasonable assurance that a fire in the vicinity of one unit's AFW pumps will not adversely impact on the AFW pumps of the unaffected unit. The motor-driven pumps h~ ave their long dimension in an east-west orientation while the turbine-driven pumps have long dimensions running north-south. Located between the motor-driven and turbine-driven pumps of each unit is a 7-ft-high, 2-1 Page 7-39

ft-wide barrier of concrete construction that runs east-west and is 15 ft long. The motor-driven AFW pumps for each unit extend approximately 7 ft past the west end of the barriers. Each motor-driven pump is partially enclosed by a steel plate box. The plate encloses the

north, top, and west end of each individual motor-driven pump, with north and top dimensions of approximately 5

ft. The concrete barrier and steel plate enclosure combination effectively isolates the Unit 1 motor-and turbine-driven pumps from line-of-sight contact; however, with the enclosure only on the north, top, and west ends of the Unit 2 motor-driven AFW

pumps, there is direct line-of-sight contact between motor-and turbine-driven AFW pumps. This enclosure will be extended to the south side of the Unit 2 motor-driven AFW pumps to prevent direct line-of-site contact with the turbine-driven pump.

Each AFW pump is surrounded by a dike with an outside height of 3 in. The inside height of the dike varies from 2 in. on the west end to 3 in. on the east end, where a drain pipe is provided leading directly out of the 579 ft elevation for removal of lube oil spills from the base of each pump. The potential for a fire resulting from lube oil leaking from the pumps is low for three reasons: first, the provision of drain lines inside the dikes of each pump for removal of lube oil; second, the high flash point (approximately 450 F) of the lube oil; and finally, the lack of 0 sufficiently hot surfaces in Fire Zone 11.3-0 to cause ignition of the lube oil. Page 7-40

Each AFW pump is protected by a local application CO2 suppression system that is actuated by heat detectors located directly over each pump. The suppression system has two headers per unit, with one header providing coverage over both motor-driven pumps and the second header covering the turbine-driven pump (see Figure 7.4-3). The southernmost motor-driven and the turbine-driven AFW pumps for Unit 1 are separated by 22 ft 9 in. The minimum separation between the northernmost motor-driven and the turbine-driven AFW pumps for Unit 2 is 15 ft 9 in. Although less than 20 ft of separation exists between the northernmost motor-driven and turbine-driven pumps for Unit 2, the 7-ft-high, 2-ft-wide, and 15-ft-long concrete barrier provides adequate pump-to-pump separation when combined with the existing local application CO2 suppression system over each pump and the proposed extension of the steel plate enclosure to the south side of the motor-driven pumps where they extend beyond the barrier. To ensure that at least one pump remains operable following a fire

event, the power feeds for the southernmost and northernmost motor-driven pumps for Units 1 and 2, respectively, will be wrapped with one-hour-rated materials throughout their entire run on the 579 ft elevation.

Once the power feeds for the motor-driven pumps exit the 579 ft elevation, protection for the feeds is no longer required as a fire on the upper elevations will have no impact on the turbine-driven pump or the 579 f: elevation. Page 7-41

Figures 7.4-3 through 7.4-5 identify the location of detection and manual suppression capabilities on these elevations. (C) Remote Shutdown Panels Also of concern with respect to the operability of the AFW pumps are the remote shutdown panels (RSPs). There are four RSPs per unit, with three containing functions important for safe shutdown and the fourth containing balance-of-plant functions. The RSPs are adjacent to the T-shaped extension of the common wall separating redundant charging pump cubicles of each unit and are located west of the motor-driven AFW pumps. A minimum of 80 ft separates the Unit 1 and Unit 2 RSPs. This separation distance provides reasonable assurance that a fire in the vicinity of one unit's RSPs wil'1 not affect the RSPs of the other unit. The RSPs are unit-specific and are not redundant to each other. Alternate shutdown capability is provided should a fire occur in the vicinity of the RSPs;

however, the alternate shutdown capability is based on the operability of at least one AFW pump per unit.

The minimum separation between motor-driven AFW pumps and the RSPs is approximately 20 ft, while the distance to the turbine-driven pump is approximately 30 ft. The local application CO2 suppression system over the three ATW pumps of each unit and the provision of a one-hour wrap for the power feeds of motor-driven AFW pumps 1C and 2C on the 579 ft elevation provide reasonable assurance of the operability of one AFW pump given a fire in the vicinity of the RSPs. Page 7-42

d Figure 7.4-3 identifies the location of detection and manual suppression capabilities on this elevation. (D) Service Water Pumps Power Cables There are six service water pumps located in Fire Area 18.4B-0, any two of which are sufficient to achieve and maintain hot shutdown for both units simultaneously. Within the Auxiliary Building, the power feeds for these pumps enter on the 579 ft elevation and are routed in metal-enclosed risers along the Turbine / Auxiliary Building interface prior to entering the Cable Spreading Room fire areas on the 630 ft elevation. As stated in the previous Appendix R submittal, a minimum of 147 horizontal ft, of which at least 20 ft is free of intervening combustibles, separates the Unit 1 and Unit 2 service water power feeds on the 579 and 592 ft elevations. This minimum separation distance also exists on the 617 ft elevation prior to the power feeds entering their respective Cable Spreading Room fire areas on the 630 fr~ elevation. The 147 ft separation distance, at 1 least 20 ft of which is free of intervening combustibles, provides reasonable assurance that at least two service water pump power feeds will remain free of fire damage given a fire in the Auxiliary Suilding. (E) Steam Generator Pressure-Transmitters Caoling for redundant steam generator pressure transmitters is routed along the south wall of this elevation (from Fire Zones ? 18.5-1 and 18.5-2; see Subsection 7.7) up to the Cable Spreading Page 7-43 ) _ _ _ _. _ _ _. _ _ _ _.. _ _ _ _,.. _ _ _. ~ _ - -_,_.~..-.

Rooms on the 630 ft elevation. Alternate indication is available via a mechanical gauge that will be installed within Fire Zones 18.5-1 and 18.5-2. Figures 7.4-3 through 7.4-5 identify the location of detection and manual suppression capabilities on these elevations. 7.4.4.4 592 ft Elevation The 592 ft elevation, as shown in Figure 7.4-4, consists of the following fire zones having floor areas, clear floor-to-ceiling heights, and equivalent fire severities in minutes of burn time and combustible loading as indicated: Floor to Equivaltat Floor Ceiling Fire Combustible Areg Height Severity Loading Fire Zone (ft 1 (ft) (min.) Btu /ft ll.3D-1 1,369 - 24.5 <1 Negligible ll.3D-2 1,369 - 24.5 <l Negligible 4 11.4-0 19,945 ~ 21-24.5 14 1.82 x 10 4 11.4A-1 256 24.5 13 1.774 x 10 3 ll.4A-2 256 ~ 21-24.5 4 4.875 x 10 4 11.4B-1 276 ~ 21-24.5 12 1.645 x 10 3 11.4B-2 276 24.5 3 4.52 x 10 11.4C-1 375 - 24.5 <1 Negligible ll.4C-2 375 - 24.5 <1 Negligible 4 14.3A-0 1,987 - 23 12 1.615 x 10 14.3B-0 1,190 - 21.5-24.5 <1 Negligible 14.3C-0 1,879 - 15 <1 Negligible Page 7-44

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