ML20234C781
| ML20234C781 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/18/1983 |
| From: | Howard J BOSTON EDISON CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20234C600 | List: |
| References | |
| FOIA-87-649 BECO-83-24, NUDOCS 8801060322 | |
| Download: ML20234C781 (1) | |
Text
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- (A, k, BOSTON EDISDN COMPANY S00 BOYLaTON STREET SDsTON, MASS ADMUBETTO D219 9 al. CDWARD HOWARD January 18, 1983
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BEco Letter No. 83-24 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA. 19406 License No. DPR-35 Docket No. 50-293
Subject:
Halon System Installation - Status
Reference:
(a) BECo letter # 82-11, dated January 8,1982, "Special Report -
CSR CO2 System Corrective Actions."
(b) BECo letter # 82-112, dated April 26,1982, " Completion Dates of Fire Protection Modifications."
(c) BECo letter # 82-249, dated September 20,1982,"Resgonseto Systematic Assessment of License Performance (SALP)
Dear Sir:
Reference (a) infonned your offices of alternatives under consideration for modi-
' fication to the existing CO2 system in the Cable Spreading Room..The; completion date was projected for late 1982. Subsequently, Reference (b) noted that' a total flooding Halon 1301 system was chosen and the schedule for installation would be factored into an integrated work plan under development at the time. Reference (c) later identified January 15, 1983 as our intended installation date.
Please be infonned that this modification has been re-scheduled.
Preliminary plans and schedules for installation are currently being reviewed with the vendor selected to install the system. We will notify your offices of our projected implementation date once the final plan is approved and will continue our compen-satory fire watch until the installation is completed.
The need to identify this schedular change to your office was not innediately recognized because our Cosnitment Control Tracking System contained the wrong completion date. We have corrected the error and are reviewing the other dates in the system for similar errors.
Should you have any questions or concerns relative to our commitment control tracking system or our intended modifications to the Cable Spreading Room Fire Protection System, please do not hesitate to contact us.
Very truly yours, k9 P R:'
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May 17, 19S3 BICo (tr. aB).13C Mr. Domenic B, Vassallo. Cnief I
Operating Reactors Branch #2 Divisiot. of Licensing g g*
Office of hsclear Reactor Regalation U.S. Nuclear Regulatory Concission (f.O Weshington. D. C.
20555 ECORD ht(-
i License he. OPR 35 e2 meO Docket he. 50-?93 A mene's
- Encartien Re:uests WEYWOR b
N Re'e<ences:. ( A) BEC: Letter dated June 25,196?. "Foston l' {+f
' YEA t#
y Edison Respoese t: Appendia R' i
(B) hR: Letter dated.?a%a y 17. 1983. " Review i
of Safe 5%tcc n tapab'lity Appendia R to WS D 'MO E 10 CTS. Part 50,1ters ))].G anc 1)).L" (C) V: Letter dated.'asary 31, 1983 denying MI@ f BEto's recsests for enen;tions to Appendia r, i
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(O' BICc Letter dated *.a ch 11,1983.."In omatdon r
on 10 CTR 53 sp:e <d:. R lie s Ill.G and III.L M4 (E) BE00 letter dated W4*ce 1}. ]983 reewesting l
4 a reco*sice*atior c# ese*;t*0e re0 wests to Appendia R (T) Bits Lette* dated is 11 1 A.19E3. *Long Tere g
Prograf ard $chedwle" i
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Dear Sir:
l rvutaA Dr A.b TiOav In Reference ( A) BECc subritted a fire ceotectice, analysis with plans. Schedules and enemetion reovests to fully meet the re diremer.ts of applicable sections of n,,g,q
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= s 10 CFR 50 Appendia R.
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~ _I Reference (B) approved our p*oposed methods ef comciiance regarding safe shutdown
/n capability with a few enceptions. We responced tc those exceptions in Re'erence
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e (D). Reference (C) denied all the Reference (A) technical and schedular esemption regwests, and as a result we reuvested re. consideration via Reference (E).
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There are no installed combustibles between the dif ferent ins t rument s tha t measure torus water level and torus water i
temperature and the redundant equipment ' exceeds the 20 foot i
minimum separation criteria of Appendix R.
The transient
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combustibles loading in the Torus Compartment creates a -
maximum theoretical fire exposure of less than 4.4 minutes.
These factors coupled with the proposed modification will i
insure that at least one train of instrumentation will remain l
free of fire damage in this area.
5.
The objectives for the protection of safe shutdown capability is to insure ' that at least one means of achieving and
.i maintaining safe shutdown conditions will remain available j
during and af ter any. postulated fire in the station.
j Modifications required to meet the requirements of sec tion l
1110.2 of Appendix R would not enhance the fire protection safety of Pilgrim Station any better than the modifications proposed by Boston Edison Company for this fire zone.
The proposed modifications to the torus temperature instruments j
v11.1 insure that one instrument channel will remain free of fire I
damage for any postulated fire in the area.
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(
EXEMPTION REQUEST # 7 Ezenption Request For Fire Zones 1.9 and 1.10 (EL 23'-0" 1x Building)
Per the provisions of IDCTR50.12, Boston Edison Company requesta" exemption from the requirements of section 111G 2 (b) of Appendix R f or
'the Pilgrim Nuclear Generating Station. Specifically, exemption is requested from the requirement to have an automatic fire suppression systee installed throughout fire zones 1.9 and 1.10 and from the requirements of having redundant trains of equipment required for safe shutdown separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.
Boston Edison is proposing, as part of the modifications for these fire zones, to install sprinkler protection in the boundary area separating these fire zones as shown on figure #1.
The' exemption reques t is necessary to exempt Boston Edison Company f rom ~ the requirements to provide tot (1 area sprinkler protection for both fire zones. The horizontal separation berveen redundant trains required for safe shutdown is much greater than the 20 feet required by section 111G.2 (b) of Appendix R.
However, there are cable trays in the separation area that are considered combustibles.
1he technical bases which justify the exemptions are summartred below and the supporting fire zone data is given in tables 7.1 and 7.2.
This inf ormation provides reasonable assurance that the.public health and safety will be protected in a fashion equivalent to that resulting f ree compliance with the specific requirements of Appendix R.
j 1.
Tire zones 1.9 and 1.10 are part of a fire area in the Rx Building, EL 23'-0".
Fire zones 1.9 contains "A" train components required j
for safe shutdown.
Fire zone 1.10 contains "B" train components i
required for safe shutdown.
These fire zones are separated by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> boundary along their common boundary except for an area approximately 30 feet vide on the North side of the building.
2.
Once modifications are implemented as described in tables 3.1 and 1.2, hot shutdown equipcent in fire zone 1.9 vill be separated from the redundant hot shutdown equipment in fire zone 1.10 by a horizontal distance of approximately 75 feet. Cold shut-down equipment in fire zone 1.9 will be seperated from the redundant cold shutdoen equipment in fire zone 1.10 by a horizontal distance of approximately 100 f eet.
These distances given are the closest dimensions between cables or conponents that are part of systems required for hot or cold shutdown.
3.
The combustible loading between Fire Zones 1.9 and 1.10 is extremely l ow.
These zones are separated by a volume that is essentially free of combustible materials.
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All trays are at least one foot apart in each direction. These factors will preclude a fire within any one of the five trays from interacting with the other trays and propagating across the separation volume.
The combustible loading in fire zones 1.11 or 1.12 creates a maximum theoretical fire exposure of only minutes. The nearest safe-shutdoci equipment is 70 feet apart and separated by a minimum 20 f t.
wide clear spa:e. These f actors coupled with the propo~ sed water spray system within the separation clear space will assure at least one train of safe sh,utdown equipment will remain free of fire damage in this area.
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4.
Automatic amoke detection exists in fire tones 1.11 and 1.12 which alarms in the continuously manned Control Room.
5.
Even though the ceilings of mones 1.11 and 1.12 do.not have rated three hour boundaries, this does eot present a safe shutdown problee because of the following axisting conditions:
a) All penetrations in the ceilings of the two areas are three hear rated except for'the hatchway and stairwells, b) The areas above these fire zones do not contein equipment or cables required for safe shutdown.
c) The areas above these fire zones are equipped with automatic amoke detection, hose stations and portable fire extingui=hers.
d) The combustible leading is low as shown in Table 2.1.
e) The hatchway and stairwell that forms the boundary violation, is separated by a horizontal distance of approximately 80 feet.
6.
The objectives for the protection of safe shutdown capability is to insure that at leest one means of achieving and maintaining safe shut-i down conditions will remain available during and after any postulated fire in the station. Modifications required to meet the requirements of Section 111 C.2 of Appendix 2 would not enhance the fire protection safety of Pilgrim Station any better than the modifications proposed by Boston Edison Company for these two fire tones.
The modifications proposed fer these two fire tones, as des.cribed in Table 2.1 and 2.2 vill insure that at least one train of safe shutdown equipment will remain free of fire damage for any postulated fire in the area.
7.
Modifications required to meet the requirements of Section III C.2 of Appendix R vould in fact be detrimental to overall facility safety.
These fire zones are too large and porus to permit the installation of an effective gaseous suppression system. The water damage to safety related equipment from real or inadvertent actuation of a sprinkler rysten represents an unacceptable risk to Boston Edison Company.
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capability for an area as opposed to using other options or settads given in section 111G of Appendix R.
The alternate shutdown system was installed for the Cable Spreading Room and Control Room and these areas are in full compliance with the r requirements of section 1110.3 of Appendix R.
A sev automatic Halon fire suppression system is being installed in the Cable Spreading Room to replace the' existing CO2 system and; therefore, this area vill be in compliance with section 111G.3 as soon as the Balon system is inst alled and
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declared operational. Boston Edison Company has an approved exemption request from the requirement to have a fixed suppression system in the Control Room and, therefore, is in compliance in this area.
I 2.
Even though certain features of the existing alternate shutdown systec are being utilized on a limited basis for the fire zones where exemption is requested, it is not the primary means of i
achieving safe shutdown capability for these fire zones.
3.
Once the af fected cable is isolated from the fire zone using the alternate shutdown panel, fire damage to that cable has no effect on safe shutdown capability.
4 Automatic smoke detection, which alarms in the continuously manned Control Room, exist s in all the fire zones where exe=ption f rom the requirements of section 111G.3 is requested.
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5.
The objective for the protection of safe shutdown capability is to insure that at least one means of achieving and maintaining saf e shutdown conditions will remain available during and af ter any postulated fire in the station.. Modifications to install j
fixed suppression in the fire zones where exemption is requested q
vould not enhance fire protection safety at Pilgrim Station.
Use of the alternate shutdown system for these fire zones will insure that at least one train of safe shutdown equipment will remain free of fire damage for any postulated fire in any of the above fire zones.
The addition of a fixed suppression system in these fire zones would not in any way improve the capability to achieve safe shutdown.
1 6.
The above fire zones are not conducive to the installation of a gaseous fire suppression system and the installation of a fixed water suppression systen would in fact be detrimental to overall facility safety because of water damage to safety related equipment f rom real or inadvertent actuation.
(Page 2 of 2)
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I EXEMPTION REQUEST #10 Bcston Edison Company herein reouests relief from the schedular requirements of a
10 CFR 50.08. which currently requires implementation of Aopendix R modifications before sta-tup ef ter the earliest of the following events comencing 180 days or more after NRC approval:
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- 1) The first refueling outage
- 2) Another planned outage that lasts for at least 60 days 1
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- 3) An unplanned outage that lasts for a least 120 days Our final completion date for all modifications would be prior to restart from Refuel Outage #7, tentatively scheduled to consnence in Nov9mber 1985.
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New Date:
Deceeer 1985 1
Justification:
Section 8.0 of our Reference ( A) submittal provided justification and compensatory measures to be taken when our modification schedules showed June 1987 as the final completion date. These measures, in turn will be provided to reflect the revised completion date of December 1985.
As depicted in our detailed Long Tern Program Schedule, work will proceed in an ongoing f ashion with measur-l able increments or milestones.
Prior to the issuance of Appendix R, Pilgrim Station had been reviewed against l
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the criteria of Appendix A to the Branch Technical Position (BTP) 9.5-1 and a i
l Fire Protection Safety Evaluation was issued on December 21, 1978 as Amendment (35 to the License.
The safety evaluation required that modifications be made to plant physical features and systems, and that administrative controls be estab-lished accordingly.
Further evaluation and information exchanges ensued on remaining open items which have since been resolved.
In addition, our instrumen-tation and procedures in effecting safe shutdown independent of the cable spread-ing and control rooms were found acceptable by your staff and put in place.
This capability will be available during the period of exemption.
We believe that with the compensatory measures referenced above and the ongoing incremental Fire Protection improvements depicted in our Long Term Program l
Schedule, Reference (F), there is no undue risk to the health and safety of the l
public involved with the granting of relief to the schedular requirements of 10 CFR 50.48 until prior to restart from refuel outage #7.
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TABLE 5.1 FIRE ZONE 1 : 30A: AEACTOR BU'LDING EL (-) 17'-6" TORUS COMDARTMEN-i i
AREA CONSTR"CTION-A.
1.
Wells
.5ee Tigure
- 4.
Valls are.'6" concrete with 3 hour-penet rations with the exception-of doorways into the quad-rants which are not fire doors and the penetrations into'ttc quadrants which have not been upgraded to a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.
2.
T1oor - 96" concrete slab on soil.
3.
Ceiling - 24" concrete slab; 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> penetration seals.-
1 4
Ceiling hei ght - 3 8 ' - 6".
5.
Area Yolume. The area vclume lesn the torur suppression chatsber is approxi ately 235.740 cubic f eet.
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6.
Congestion - Area is essentially fr ee of floor congestion.
General ac cess for canual suppression is adequate.
B.
SATE SHUTDOWN EQUIPMINT 1.
Af ter the proposed modifications are Implemented for this fire zone, only the "B" train cf systers required fer safe shutovn will remain in fire zone 1.30A.
All "A" train i
l cables and compenents that ate Twtuired to be operable for r af e shutdown vill not be located in this fire zone.
The exception to this is torus water level and torus temperature -
instrumentation which is the subject of cheeption request tS.
Tor a fire in fire zone 1.30A, safe shutdown vill be accer-p lis he d wi th t he " A" t rain o f sy s t ems.
Tigure #4 shows the location of instrumentation for torus watet level and torus vater temperature ~ in the Torus Compartment. As stated in
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exemption #f,, one instrument should be available to measure each varible in order to achieve safe shutdown.
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C.
COM3USTIBLES This item provides the technical justification for not;presic>nt any additional fire protection in the Torus Compartment.
l The combustible materials in the Torus Compartment fire zone-1.30A.
treated staging. The fire logdan; and is primarily fije retardantfire exposure are described in the table below:
the U.coretical (Page 1 of 3) l
Fira Quantity Continuity of Eq ai valen t Fi re Re t a rd ent Zone Combus tible s Combus ti bles Theo. et i c al Protection Typ eWei ght Through Tire Exposure Type 1bs.
Fire Minutes Zone Ito. 1. 30A Wood Staging /
No 4,4 Yes-Wood st aging y
. Reactor S200*3 has been painted vi.th fi re re t a r d an t I
coa ting
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51ds.
Ele'v. (-)17 ft Cable /24 Mo IEEE 383 - 1 tray Cable 1
There ar9 two approaches to analyze fire spread potentials.
The "theo-4 retical" method mathematically compares specific plant fire loads to a Standard Time-Temperature fire. The " realistic" I method evaluates the physical array of specific combustibles and the possibility of fire j
propaga tion within t he a rray.
THIDRETICAL ANALYSIS
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BECo used the theoretical approach to identify the Standard Fire Ex-posure for comparison purposes and general understanding on the " order of magnitude of the vorst case fire in this area ". Any fires with a j
Standard exposure undet 30 minutes are in the lowest severit,f ca tegerv.
j This fire zone has a Standard Fire Exposure of less than five minutes.
I BEco believes that any further use of the theoretical approach is un-I wa rrant ed since t his met hod is heavily d epended on defining a Design -
Basis Fire (DBT) and the correlation between a DBT and real fire has not. been satis fac torily established. Mor e importantly, BECo pos tulat es this is unnecessary because the realistic approach is adequate to obtain j
an appropriate level of fire protection.
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REALISTIC AFALYSIS The realistic approach identifies that all potential pathL for fire spread through this fire zone.
For this ares, there is only one path as it is one open area. These paths have been utilized in the completion of the realistic analysis below.
Conductive heat transfer and direct flame impingement are not possible across these paths since there is no con:inuity of combustible materials in any of these paths (e.g. w rtical or horiz ontal).
Radiant heat transfer can only be a factor in fire spread when there is a st rai gh t, unobstruct ed, i.e. "line of sight", pat h between the fire and the expose d material. It is not possible to spread fire by radiant energy transfe r in this area. The Torus is in between the transient fire load (i.e. s ta gin g) and the redundant SSE.
1.
See Appendix A for a more detailed description of the theoretical and realistic analysis methods.
2.
Reprinted free Table 1-1, Fire Protection System Review APCSB9.5-1.
3.
This is fire retardant coated wood on te porary staging.
The staging encircles the exterior of the Torus. The wood staging is also encap-sulated with a material with fire retardant capabilities.
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Convective heat transfer is the one method of fire spread that is remotely realistic for Pilgrim Station.
If a fire in this area could produce enough heat to raise the sabient air temperature in the entire Torus Compartment to the auto-ignition point of " cable insula tion, redundant channels of instrumentation could be damaged.
Bowever, there~ is not a sufficient fire load in 'the Torus Compartment or any. adjacent fire zone (i.e. 1,1, 1.7, 1.5. or 1.6) to raise the ambient temperature in this area to the required temperature.
D.
FIRE PROTECTION EXISTING 1.
Fire detection systems: None 2.
Fire extinguishing systems: None 3.
Rose stations / extinguishers: There are no portable extinguishers i
or hose reels in the Torus Compart-ment, however there is one hose reel and portable extinguisher in each quadrant adjacent to the Torus Com-4 partment that vill reach all areas in the Torus Compartment.
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Radiant heatshield: None 5.
Propagation retardants: Cables are coated with flamemastic or qualified to IEEE-3B3.
E.
PROPOSED MODIFICATIONS
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Modifications proposed for. fire zone 1.30A will insure that one
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train of safe shutdown equipment vill remain free of fire damage f ar any post related fire in the area.
Modifications for the Torus Compartment (fire zone 1.30A) are as follows:
I (a) The torus water temperature instrumentation is being modified 1
as stated in Exemption Request #5 and as shown on Tigure v4.
(b) The power and control cable for the "A & B" diesel generator fuel oil transfer pumps are being re-routed out of the Torus Compartment.
(Page 3 of 3) l L
TABLE 7.1 FIRI ZONE 1.9: RIACTOR BUILDING ELEVATION 23'-0". EAST SIDE ARIA DATA a,
/
A.
ARIA CONSTRUCTION 1.
Walls See Figure il 27" concrete vall, plus 6" pre-cast panel; 3-hour North rated with 3-hour penetration seals.
(column Line-P) 42" concrete vall; 3-hour rated with 3-hour rated South penetration seals.
(column Line-H) 33" concrete vall; 3-hour rated with 3-hour rated East penetration seals.
(column Line-17)
West Bounded by (a) 42" concrete steam tunnel shield vall.
Three hour rating is not required because the Steac tunnel is not a redundant arena (b) 60" concrete, l
drywell shield va12.
(c) The unenclosed portion of l
the boundsry is shared with fire zones 1.10 at column -
line 11.
2.
Floor 24" concrete slab, three hour fire rated with three hour rated penetration seals with the exception of epen stairwells to fire zonn 1.8 and 1.1.
These two fire zones are not redundant to fire zone 1.9.
3.
Ceiling 12" concrete slab; three hour rated with three hour rated penetration seals with the exception of an epen stairwell to fire zone 1.11 which is not a redundant area to fire zone 1.9.
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4.
Ceiling height 27 feet.
5.
Area volume Approximately 220,000 cubic feet.,
6.
Ventilation See Figure il for directional arrows showing ventilation flow.
7.
Conge stion Area is essentially free of floor congestion.
General access for manual suppression is good.
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B.
SAFE SEUTDOWN EQUIPMENT Af ter the proposed modifications are implemented for this fire zone, only the "A" train of systems required for safe shutdown will rema',
l in fire sone 1.9.
All "B" train cables and components that are re-quired to be operable for safe shutdr7vn vill not be located in this fire zone.
For a fire in fire zone 1.9 all "A" train components are assumed lost, and safe shutdown will be accomplished with the "B" train of systems.
The opposite is true for fire zone 1.10 where all "B" train components are assumed lost, and safe shutdown will be accomplished with the "A"
train of systems.
Figure il shows the components and cables located in fire zone 1.9 that are required to be operable for a fire in fire zone 1.10.
Listed below are the systems that will be used for safe shut-I down if a fire occurs in fire zone 1.10.
The components or cables arc j
listed if they appear in fire zone 1.9.
Figure #1 shows the location i
of the components and/or cables that are listed.
COMPONENTS / CABLES LOCATED IN "A" TRAIN o
SYSTEMS TIRE ZONE 1.9.
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O Automatic Alternate shutdown panel and control Depressurization cables.
System Core Spray System MCC B17 which feeds power to core spray valves. Alternate shutdown. panel for core spray.
Power and contre) cables for j
the. core spray system.
RHR System in the MCC BIB and B20 which feeds power to the shutdown cooling mode RER valves. Alternate shutdovn panel for RHR. Power and control cablet fer RHK system.
Rx vater level and Rx None pressure Torus temperature Instrument cables for torus temperature.
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Torus water level.
Instrument cables for torus water level.
1 C.
COM3USTIBLES This iten provides the technical justification for considering the space between Tire Zones 1.9 and 1.10 " free of fixed combustible material."
(Pare 2 of 7)
l The 20 feet separation space berveen redundant safe shutdown equipmentL (SSE) contain six (6) horizontal cable trays.
(See Figure #1). The separation zone is described below:
l Separation Quantity Continuity Area of Equivalent Fire Eoor Combustibles of Separation Theoretical Retardant 5e tween Total Combustibles Lone Fire Exposure Protection I 3
Redundant lba/ft -lbs.
Through sq. ft.
Minutes Type SSE Separation Zone 1
Reactor Building 19.9 388 Yes 900 0.4 IEEE 363-3 trays /6 Elev. 23 ft.
non IEEE 383 Cable Coated with fire Between colunas Retardant 3 trays /l 9.1 to 11 Material and M.7 to P l
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l The the'oretical equivalent fire exposure of the cable within this Separation Zone is only 0.4 minutes. This is extremely lov.
l Realistica11y. the combination of fire retardant coating or the inherent fire retardant properties of IEEE 383 qualified cable and the large physical separation between the trays will prevent a fire that originates within one of these trays from generating sufficient heat to propagate a fire across the six trays in the prospective Separation Zone. An intense or large exposure fire might be able to propagate a fire across the prospective Separation Zone. Bovever, there are no other installed combustible materials in the zone to provide the exposure fire.
Moreover. Administrative Controls were designed to limit transient combustible material on Elev. 23 feet of the Reactor Building to a maximum of 10 gallons of Class 11 and 111 liquids (i.e each) and one gallon of Class I liquids.2 Combustible loading of this magnitude or even several orders of ma'gnitude larger. will not totally fill the 20 foot vide Separation Zone. Additionally, since the cable trays are 11 feet above the floor, the transient loads vill not be able to impinge on the entire length of the tray.
i 1 See Appendix A for a more detailed description of the theoretical and realistic analysis methods.
2 Flammable / combustible liquids are required to be in approved containers;
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s BEco concludes that neither the limited installed combustible '
l materials'or potential transient materials would propogate n fire across the 20 foot fire Separation. Zone. This zone can be considered-
" free of intervening combur.tibles as required in section II!G.2 (b).
C.2 This item provides the technical justification for the proposed fire
. protection modifications.
a The combustible materials installed in Fire Zone.l.9 and 1.10 a re primarily. cable insulation.
The itre. loading:and'the theoretical fire exposure are described in the. table 2 below:
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. Fire Quantity of Continuity of Equivalents Fire Retardant i
Zone Combustibles Combustibles Theoretical Protection Type-Weight through Fire Exposure Type
)
Fire Zone Minutes No. 1.9 Cable -16,731 No 29.5 IEEE 383 70 Reactor Building Non1EEE' 30'
.Elev. 23 ft.
383 Cable East Col.
Coated-with-No. 11 Fire Retar-
' dant 4
Material-1
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No. 1.10 Cable -14,078 No 22.8 1EEE 383 70%
i Reactor Trainsient Cable l'
Building Combustible -
Elev. 23 ft.
1036 Non1EEE 383 30 '
West of Col.
Cable Coated ~
No. 11 with Tire c3 Retardant
. Material l
There are two approaches to analyze fire spread potentials.
"he
" theoretical"I method mathematically compares specific plant fire.
loads to a Standard Time-Temperature fire. The " realistic" I.
1 method evaluates the physical-array:of. specific combustibles and i
the possibility of fire propagation within the. array.
11tEORETICAL ANA1.YSIS -
l 1
BEco used the theoretical approach to identify the Standard Fire 1
Exposure for comparison purposes-and general understanding of-'the
'" order of magnitude of the worst case fire in' this area..Any fires-r with a Standard exposure under'30 minutes'are in the lowest. severity l
category.. Tire Zone'1.9 and 1.10 have Standard Fire Exposures 29.5.
and 22.8 minutes respectively.
l (Page.4 of 7) 1 a
r BECo believer that any further use of the theoretical approach is unwarranted since this method is heavily depended on defining a Design Basis Fire (DBF), and the correlation between a DBF and real fire has not been satisfactorily established. More importantly, BECo postulates this is unnecessary because the realistic approach is adequate to obtain an appropriate level of fire protection.
REALISTIC ANALYSIS The realistic approach identifies that there are two potential paths for fire spread between zones 1.9 and 1.10.
F.irst, the fire could spread horizontally across the floor.. Secondly, the fire could spread to a higher or lower elevation (e.g. 23 ft.,
74 or 91) through a vertical opening and then back to the 23 f t.
elevation through another vertical opening. These paths have been utilized in the coupletion of the realistic analysis below.
Conductive heat transfer and direct flame impingement are not possible j
across these paths since there is no continuity combustible materials i
in any of these paths (e.g. vertical or horizontal).
Radiant heat transfer can only be a factor in fire spread when there is a straight, unobstructed, i.e. "line of eight", path between the fire and the exposed material. There is either a floor or the Primary Contain-ment between the combustible materials in fire zones 1.9 and 1.10.
This eliminates the "line of sight" and vill realistically prevent fire spread by radiant energy transfer.
Convective heat transfer is the one method of fire spread that is remotely realistic for Pilgrim Station.
If a fire in the fire zone 1.9 (or 1.10) produced enough heat to raise the ambient air temperature i
on the entire 23 foot elevation to the auto-ignition point of cable insulation, the fire could spread from fire zone 1.9 to 1.10.
BECo has conservatively assumed that there is a sufficient fire exposure in zone 1.9 (or 1.10) to accomplish the required ambient temperature.
BECo has proposed to prevent the horizontal migration of the ambient temperature profile by installing a Water Spray System within the 20 ft. Separation Zones (See Iter; C.1) between fire zone 1.9 and 1.10.
This is the only protective systen necessary.
BECo has not proposed any prctecti.on for the vertical openings in the Reactor Building floors.
This is not necessary since convective heat transfer cannot occur downvard until the entire volone at the higher elevation (s) has been heared. Hence, the exposure fire in fire zone -
1.9 (or 1.10) would have to heat the Ambient atmosphere in the Reactor Building from $1 ft. tc 134 ft. to the " higher" mbient temperature before it would migrate back down into fire zu, 1,9 (1,10).
The fire loads an elevation 51 ft. (or any higher elevation in the Reactor Building) are not capable of producing a fire of this magnitude.
Therefore, this is not realistic and special protection is not necessary for vertical penetration / (e.g. stairs or hatch).
(Page 5 of 7)
TABLE 7.2 FIRE ZONE 1.10:
REACTOR BUILDING D.EVAfl0N 23'-0". VEST SIDE AREA DATA i
A.
ARIA CONSTRUCTION i
1.
Walls - See Figure il North - 27" concrete vall, plus 6" pre-cast concrete panel; 3-hour rated. with 3-hour penetration seals. (column
.i Line-P)
South -
42" concrete vall; 3-hour rated with 3-hour rated penetration seals (column Line-H) f West 33" concrete vall; 3-hour rated with 3-hour rated penetration seals (coluan Line-5)
East Partial enclosure;' bounded by 42" concrete steam tunnel shield vall (coluan Line-10) 60" (circum-ferential, column Line-10 to, column Line-II) both 3-hour rated vs11s.
The uner. closed portion of the boundary is shared with fire zone 1.9 at column Line-11.
2.
Floor -
24" concrete slab; 3-hour rated with 3-hour rated penetration seals with the exception of open stairvells to fire zones ).7 and 1.2 which are not redundant areas to fire zone 1.10.
3.
Celling -
12" concrete slab; 3-hour rated with 3-hour rated penetration seals with the exception of an open stairvell, and hatchway to fire zone 1.12 which is not a redundant area to fire zone 1.10.
4 Ceiling Eeight 22 feet i
5.
Area Volume Approximately 195.500.eubic feet.
6.
Ventilation See Figure il for directional arrows showing ventilation flow.
7.
Congestion Area is essentially free of floor congestion.
General access for manual suppression is good.
B.
SAFE SHUTDOWN EQUIPMENT 1.
Af ter the proposed modifications are implemented for this fire rone, only the "B" train of systems required for safe shutdown vill remain in fire zone 1.10.
ALL "A" train cables and components that are required to be operable for safe shutdown vill not be located in this fire zone.
(Page 1 of 3)
i For a fire in fire zone 1.10, all "B" train components are i
assumed lost, and safe shutdown vill be accomplished with the "A" train of systems. The opposite is true for fire sone 1.9 where all "A" train components are assumed' lost, i
and safe shutdown will be accomplished with the "8 train i
of systems.
Figure il shows the components and cables located in fire zone 1.10 that are required to be operable-for a fire in fire zone 1.9.
Listed below are the systems that will be used for safe shutdown if a fire occurs in fire sone 1.9.
The components or cables are listed if they appear I
in fire zone 1.10.
Figure #1 show the location of the com-ponents and/or cables that are listed.
1 "B" TRAIN COMPONENTS / CABLES LOCATED IN SYSTEMS FIRE 2ONE 1.10 1
Automatic Alternate shutdown panel and control Depressurization cables. NCC D8 which feeds power to the i
System ADS system.
Core spray system MCC BIB which feeds power to core spray l
valves. Alternate shutdown pane) for
)
cere spray. Power and control cables for core spray system.
RHR system in the MCC PIB which feeds power'to RHR shutdown cooling, mode valves. Alternate shotdovn panel for EdiR.
Power and control cables for R*4R system.
I Rx water level and None Rx pressure Torus temperature Alternate shutdown panel for monitoring torus temperature.
Turus water LVL Alternate shutdown panel for monitoring torus water level.
l (Page 2 of 3)
j j
i
~
C.
COMBUSTIBLES
,.I See Section (c) of Table 7.1 1
D.
FIR.E PROTECTION EXISTING
'l 1.-
Fire detection-systems: 37 Photoelectric smoke detectors 7 Ionisation smoke detectors
-l 2.
Fire extinguishing systems:.None 3.
Bose stations / extinguishers: 2 Bose Reels i
1 Portable Extinguisher
.j l
l 4.
Radiant heat shield:
None 1
5.
Propagation retardants: Cables are coated with fla e as:1:
)
. or qualified to IEEE-383.
E.
PROPOSED MODIFICATIONS Modification proposed for fire zone 1.10 will insure that one train of safe shutdown equipment will remain free of. fire-damage for any postulated fire in the area. The proposed.
I modifications are of two types and together provide a defense in depth concept for fire protection as intended by the. require-ments of Section III G of Appendix R.
1 The first type of modification involves relocating, from fire
)
zone 1.10, cables and equipment for the "A" train of systems required for safe shutdown.,After_these modifications are~
complete, fire zone-1.10 will only contain cables and componen:.s for the'"B" train of systems required for. safe shutdown.
Some i
i "A" train cables will remain in the fire zone, however, the loss d
of these cables is. acceptable since operator action will provide.
i the same function that the cable' provided. The "A" train cables l
will be relocated from fire zone l.10 by rerouting them in a.
.)
ductline around the outside perimeter of the plant that leaves I
the control building and-enters the fire zone containing the components for the "A" train of systems required for shutdown.
This ductline is being.added as part of the modifications to meet the requirements of Appendix R.
The second type of modification. involves previding sprinkler.
protection in the boundary area that separates fire zone 1.10 from its redundant counter part. fire zone-1.9.. These.tvo fire zones are separated by'a three hour boundary along their common border except for an area approximately 50 feet'long on the north side of the area. The sprinkler protection is provided to prevent a fire from propagating across the. boundary area -
between redundant fire zones, j
(Page 3 of 3)
TABLE 8.1 FIRE ZONE 1.11: REACTOR Bull. DING ELEVATION 51'-0", EAST SIDE AREA DATA A.
AREA CONSTRUCTION 1.
Walls - See Figure #2 North - 24" concrete well, plus 6" pre-cast concrete panel; 3-hour rated with 3-hour penetration seals.
(column Line-P)
South - 21" concrete vall - plus 6" pre-cast concrete panel; 3-hour rated with 3-hour penetration seals.
(column Line-J) i East - 30" concrete vall, plus 6" pre-cast concrete panel; 3-hour rated with 3-hour penetration seals.
(column Line-17)
West - Partial enclosure bounded by the 60" concrete drywell shield vall (circumf erential); 3-hour rated with 3-hour penetration seals. The unenclosed portien of the boundary is shared with fire zone 1.12 at column Lin e-11.
2.
Floor - 12" concrete slab; 3-hour rated with 3-hour rated penetration seals with the exception of an open stairwell to fire zone 1.9 which is not a i
redundant area to fire zone 1.11.
t 3.
Ceiling - 12" concrete slab; 3-hour rated with 3-hour rated i
)
penetration seals with the exception of an open j
1 stairwell.to fire zone 1.14 which does not contain 1
l equipment required for safe shutdown.
l
.{
4 Ceiling height - 22'-0" l
i 5.
Ares volume - Approximately 135,950 cubic feet.
1 6.
Ventilation - See Figure #2 for directional arrows showing i
ventilation flow.
7.
Congestion - Area is essentially free of floor congestion.
General access for manual suppression is good.
B.
SAFE SHUTDOWN EQUIPMENT (1.11)
\\
1.
Af ter the proposed modifications are implemented for this
]
fire zone, only the "A" train of systems required for safe shutdown vill remain in fire tene 1.11.
All "B" train cables 1
1 l
l (Page 1 of 7) j
i i
and components that are required to be operable for safe shutdown vill not be located in this fire zone.
j
(
For a fire in fire sone 1.11, all "A" train component.s are i
i assumed lost, and safe shutdown vill be accomplished with th e "B" t ra in o f ey s t ems.
The opposite is true for fire sone 1.12 where all "B" train components are assumed lost, and safe shutdown will be cecomplished with the "A" train t
of systems.
Figure #2 shows the components and cablas located in fire tone 1.11 that are required to be operable for a fire -in fire zone 1.12.
Listed below are the systems z
that will be used for safe shutdown if a fire occurs in i
I fire zone 1.12.
Figure #2 shows the. location of the components and/or cables that are listed.
"A" N U 4
i C(MPONEh75/ CABLES LOCATFn S'fSTEMS IN TIRE ZONE 1.11 Aut oma tic Depressurization NONE systen RHR syste=
in the LPCI and Valve MD-1001-26A 6 Cables shutdown cooling Valve MD-1001-23A 6 Cables mode Ins truments for RX va ter level I ns t ru= en t Rack C2205 and Cables, i
and Rx vessel pressure l
l 6
(Page 2 of 7)
'1 C.
COMBUSTIBLES j
C.1 This item provides the technical justification for considering the space be tween fire zones 1.11 and 1.12 " free of fixed cor.-
bustible materia)".
The 20 ft. separation space on the north side of the Reactor Building between redundant Safe Shutdown Equipment (SSE)~contain five (5) horizontal cable trays and the south side contain three (see Figure #2).
The separation zones are described below:
,i Continuity j
Separation of-j Zone Quantity Combus tible Area of Equivalent Between Combus tible Through.
Separation Theoretical Redundant Total Separation Zone Fire Exposure Fire Retardant l
SSE lbs/ft 3-lbs.
Zo ne sq. ft.
Minutes Protection I
i Reactor 16.3 - 326 Yes 1.140 16 IEEE '38 3 - 2 t rays !
Building I
l Northside non-IEEE 383
- Elev. 51 ft.
Cable Costed with Fire l
Between Retardant;- 3 tray) l cc) umns Material l
9.1 to A1 and M,7 to P l
2 Reactor 6.6 - 133 Yes 260 2.0 IEEE 381 - 2 trays Building Cable U
Southsid e l
- Elev. 51. ft, non-IEEE 3B3 Cable Coa ted
- Between with Fire columns Retardant - I tray 10-13 and Material J to E l
l s
(Page 3 of 7)
l 1
)
The theoretical equivalent fire exposure of the cable with this Separation Zone is only 1.6 to 2.0 minutes.
This is extremely low.
Realis t ic ally,1 the combination of fire retardant coating or the inherent fire reta rdant properties of IEEE 383 qualified cable and the physical separation between the trays vill prevent a fire that originates within one of these trays from, generating sufficient heat to propagate a fire across the other trays in the respective Separation Zone. An intense or large exposure fire sight be able to propagate a fire ac ross the respective
- Sepa ration Zone. _Bowever..t;her e _are. no. _other ins tal, led l
conjiustible materia}s in either zone to pavide the exposure _ fire.,_ _
j Moreover, Administrative Controls were designed to limit transient combustible material on Elev. 51 f t. of the Reac tor Building to a naximum of 10 gallons of Class II and Ill Liquids (i.e. each) and one gallon of Class I Liquids 2, j
l Combustible loading of this magnitude, or even several orders of magnitude larger, vill not totally fill the 20 f t. vide Separation Zone. Additionally, since the cable trays are 11 ft. above the floor, the transient loads will not be able
}
to impinge on the entire length of the tray.
l l
BECo concludes that neither the limited installe6 combustible j
materials or potential transient materials wou)J propagate a 1
fire across either the north or south 20 ft, sire Separation Zone an elevation of 51 ft.
These zones cro be considered "f ree of intervening combustibles as requ2 red in Section Ill l
G.2 (b).
C.2 This item provides the technical jnerification for the proposed j
fire protection modifications.
The combustible materials 'in;<alled in fire ' zone 1.11 and 1.12 are primarily cable insulation. The f17e loading and the theoretical fire exposure are described in the table 2 below:
Continuity of Combustibles Equivalent Quantity of through Theoretical Fire Retardant Fire Combustibles Fire Fire Exposure Protection Zone Type --Weight Zone Minutes Type I
No. 1.12 Cable-1870 No 7.8 IEEE 383 701 Reactor Transient Cable Building Combus tibles --
El ev. 51 f t.
130 non-1EEE 30%
Wes t Col.
383 Cable No. 11 Coated with
~
Fire Retardant-material 1 See Appendix A for a more detailed description of the theoretical and realistic analysis methods.
2 Flammable / combustible liquids are required to be in approved containers.
Continuity of Combustibles Equivalent Quantity of through Theoretical Fire Retardant
, Fire Combustibles Fire Fire Exposure Protection Zone Typ e - Weight Zone Minutes Type No. 1.10 Cabl e -3065 No 11 IEEE,383 701 Reattor N
Cable Building,'
Elev. 51. ft.g y non-IEEE 383 30%
East of Col.
Cable Coated go.11 with Fire Retardant material There are two approaches to analyze fire spread potentials. The
" theoretical"I method mathematically compares specific plant fire loads to a Standard Time-Temperature fire. The "reakistic"I method evaluates the physical array of specific combustibles and the possibility of fire propagation within the array.
THEORETICAL ANALYSIS BECo used the theoretical approach to identify the Standard Fire Exposure for comparison purposes and general understanding on the " order of magnitude of the worst case fire in this area.
Any fires with a Standard exposure under 30 minutes are in the lowest severity category. Fire zone 1.11 and 1.12 have Standard Fire Exposures 11 and 8 mlnutes respectively."
BECo believes tha t any f urther use of the theoretical approach is unwarranted since this method is heavily deperded on defining a Design Basis Fire (DBF), and the correlation be tveen a DBF i
l and real fire has not been satisfactorily established. More l
importantly, BECo postulates this is unnecessary because the I s.
realistic approach is adequate to obtain an appropriate level of fire protection.
REALISTIC ANALYSIS l
The realistic approach identifies that there are tvo potential paths for fire spread between Zones 1.11 and 1.12.
First, the fire could spread horizontally across the floor. Secondly, the fire could spread to a higher or lower elevation (e.g. 23 f t.,
74 or 91) through a vertical opening and then back to the 1
51 ft. elevation through another vertical opening. These paths have been utilized in the completion of the realistic analysis below.
)
l Conductive heat transfer and direct flame impingement are not possible across these paths since there is no continuity combustible materials in any of these paths (e.g. vertical or horizontal).
(Page 5 of 7)
i Radiant heat transfer can only be s. f actor in fire spread when -
there is et'raist.t. unobs truc ted, i.e. "line of sight", path I
between the fire and the exposed material. There is-either a floor or the Primary Containment between the combustible materials in Fire Zones 1.11' and 1.12.
This eliminates the "line of sight" and will realistica11y ' prevent fire spread by radiant energy transfer.
~
Convective heat transf er. is the one method of fire spread.that
)
is remotely realistic for: Pilgrim Station. If a fire in the l
' Fire Zone 1.11 (or 1.12): produced enough' heat to ' raise ' the ambient 1
air temperature on the entire 51 ft. elevation to the auto-
]
ignition point of. cable insulation, - the fire could spread. f rom Tire Zone 1.12 to 1.11.
BEco has conservatively assumed that -
there is a sufficient fire. exposure in Zone 1.11 (or 1.12) to accomplish the required ambient temperature.. BECo has. proposed -
to prevent the horizontal migration of the ambient l temperature profile by installing a Water Spray System within the 20 f t..
Separation Zones (See Item C.1) between Fire Zone 1.11 and 1.12.
This is the only protective system necessary.
1 BECo has not proposed any protection-for the vertical ; openings in.the I
Reactor Building floors. This is not' necessary since convective l
heat transf er cannot occur downward until the entire volume at the higher elevation (s) has been heated. Hence..the exposure fire in j
~
Fire Zone 1.11 (or 1.12) would have to heat the ambient a tmosphere 1
in the Reactor Building from 74 ft. to~134 ft. to t he " higher"
.)
ambient temperature before it would migrate back down into
.c l
Fire Zone 1.12 (or 1.11).
'l 4
The fire loads on elevation.51 ft. (or on any higher elevation in the j
Reacto'r Building) are not capable of producing a~ fire; of this magnitude.
j Therefore, this is not realistic and special protection is not necessary for vertical penetrations (e.g. stairs or hatch).
f 1
1 See Appendix A for a more detailed description of the theoretical and realistic analysis methods.
i i
2 Reprinted from Table I-1. Fire Protection System Review APCSB9.5-1.
3 The equivalent Theoretical Fire Exposure for the Reactor Building elevationa 74 ft.
(Fire Zone 1.14), 91 f t.,(Fire Zone 1.16) and 117 ft. (Fire Zone 1.24) are 1.8, 7.8 and 12 minutes '
respec tively.
See Table I from BEco Fire' Protection System Review APCSB9. 5-1.
(Page 6 of 7) y
1 4
D.
FIRE PROTECTION EXISTING 1.
Fire Detection Systems:
14 Photoelectric Smoke Detectors 3 lonization Smoke Detectors -
2.
Fire Extinguishing Systems:' None
~
'l 3.
Bose Stations / Extinguishers:
1 Hose Reel o
2 Portable Extinguishers 4
Radiant Beat Shield: None I
\\
5.
Propagation Retardants: Cables are coated wi th ' flamemattic.
or qualifted.to IEEE-383.
l E.
PROPOSED MODIFICATIONS i
Modifications proposed for fire zone 1.!! will insure that one train
~
of saf e shutdown equipment will remain free of fire damage for any postulated fire in the area. The proposed modifications are of two types and together provide a defense in depth concept for fire
~
protection as intended by the requirements of section 111G of Appendix R.
j The first type of modification involves relocating from fire zone 1.11 cables for the "B" train of systems required for safe shutdown. After these modifications are complete, fire zone 1.!! will only contain cables and components for the "A" train of systems required for safe l
shutdown. A few "B" tr'ain cables vill remain' in the fire zone, however, ' the loss of these cables is acceptable since operator action will provide the same function that the' cable provided.
The "B"
)
train cables vill be relocated from fire zone 1.11 by rerouting them in a ductline around the outside perimeter of the Plant that'1 eaves the Control Building and enters the fire zone containing the components for the "B" train of systems required for shutdown. This ductline is being. added as part of the modifications to meet the requirements of Appendix R.
The second type of modification. involves providing sprinkler protection I
in the boundary area that separates-fire zone.l.ll from its redundant counterpart, fire zone 1.12 as shown on Tigure #2.
(Page 7 of 7)
9, 1
o X
-q r
'll l
^g i,
i
't TABLE S.7 FIRE ZONE 1.12: REACTOR BUILDING ELETATION 51'-0", VEST SIDE '
AREA DATA A.
AREA CONSTRUCTION 1.
Walls - See Figure f.i
\\d North-24"concretevall,plus6" PIE-cast concrete panel; 3-hour rated with 3-hour penetration seals.
(column Line-P)
South - 21" concrete vall, plus 6" pre-cast concrete panel; j
3-hour rate'd with 3-hour penetration seals.
]
(column LJae-J)
East Partial enclosure bounded by the 60" concrete dryvell shield vall; (circumferential) 3-hour rated x '(
vith 3-hour penetration seals. The unenclosed portion of the boundary is shared with fire zone 1.11 at column Line-II.
},
West Tilled masonary block wall 12" thick.
(at column Line-7, bounded by column Line P & K) 24" concrete vall, plus 6" pre-cast concrete panel.
1 (at column Line-5, bounded by column Lines-J &K)
}-hour rated with 3-hour rated penetration seals.
2.
T1oor - 12" concrete slabi 3-hour rated with 3-hour rated penetration seals with th>c exceptien of an open stairvell and hatchway to fire zone 1.10 which is not a redundant area to fire zone 1.12.
4 i
s 3.
Ceiling - 12" concrete slab; 3-hour rated with 3-hodd,tated penetration seals with the exceptidn of an. pot:n stairwell and hatchway to the 74'-0" elevdtlen i
which does not contain equipment required for t
4.
Ceiling height - 22'-3" (maximum) 5.
Area volume - Approximately 87,840 cubic feet.
6.
Ventilation - See Figure #2 for directional arrows showing ventilation flow.
7.
Congestion - Area is essentially free of floor congestion.
General access for manual suppression is good.
A s
C (Page 1 of 3) e L
f f
B.
SAFE SHUTDOW EQUIPMENT Af ter the proposed modifications are Luplemented for this fire zone, only the "B" train of systems required for safe shut-down will remain in fire zone 1.12.
All "A" train cab,les and components that are required to be operable for safe shutdown will not be located in this fire zone.
For a fire in fire zone 1.12, all "B" train components are as s umed los t, and safe shutdown will be accomplished with the "A" train of systems. The opposite is true for fire j
zone 1,,11 where all "A" train components are assumed lost :
)
and safe shutdown will be accomplished with the "B" tYain of syst ems.
Figure #2 shows the components and cables loctted in fire zone 1.12 that are required to be operable for a fire in fire zone 1.11.
Listed below are the systems'that will be used for safe shutdown if a fire occurs in fire tone 1.11.
The components or cables are listed if they appear in fire zone 1.12.
Tigure #2 shows the location of.
j the components and/or cables that are listed.
"B" TRAIN CCMPONENT5/ CABLES 1,0CATED SYSTEMS IN FIRE 201aE').12 i
t' Automatic Depressurization NONE System RHR syst em in the LPCI and NONE shutdown cooling mode Instrissents for Rx veter level Instrument Rack C2206 A & B and Cables.
{
and Rx vessel
(
1 pressure j
C.
COMBUSTIBLES i
See section (c) of 1.Sle 8.1.
D.
FIRE PROTECTION EX1TTING 1.
Fire Detection Systems :
10 Photoelectric Smoke Detectors 3 Ionization Smoke Detectors l
2.
Fire Extinguishing Systems:
None 3.
Rose Stations / Extinguishers:
2 Rose Reels 2 Portable Extinguishers 1
1 N,
c
,t
'4 Radiant Best Shield: None Cables are corted with flamemastic
~
5.
Propagation Retardants:
or qualif ted to IEEE-383.
E.
PROPOSED MODITICATICES
~
Modification proposed for fire zone 1.12 will insure that one l '
+
train of safe shutdown equipment vill remain free of fire damage for any postulated fire. in the area. - The proposed modifications are ef 4 two types and together provide a derettae in depth concept for file protection as intended by the requirements of section IIIC of Appendix R.
'The first type of modification involves rerouting cables that are i
~
Fire zone 1.12 contain shutdowri components in fire zone 1.12.
coe,'phnents for the "B" train of systers required for saf e shutdovn.
fort contain l
The cab?ies will be rerouted from fire tones that l
components for the "A" train of systems required for safe shutdown.
leaves the Control i
The cables vill be rerouted by a duct;.line that l
Building and entets the fire zone containing the components This duct line 1
for the "16" train of systems required for shutdawn.
l is being added as part cif the modifications to meet-the requirements l
of Appendix R.
The second type of modification involves providing sprinkler protection, as shown on Figure #2, sin the boundary area that count e rpa r t, fire separates fire tone 1.12 from its redundant
)
zone 1.11.
t.
I
'L l
l (Page 3 of 3')
a
~
., I.
APPENDIX A TKEORETICA1. AND REA1.ISTIC TIRE ANALYSIS There are two approaches to analyze fire and its development - the " theoretical" and " realistic" methods.
The theoretical methods models the chemistry and physics of fire. This method manifests itself through laboratory testing and identifies ~ standard or mini =um developmental parameters for fire. These parameters are useful for comparison purposes and selection of materials, components or plant configurations during-design. For example, the theoretical method converts all combustible material -
within a specific volume of the plant to its " equivalent" calorimetric heating value. The heat loads are totaled for all materials in that plant volume.
Finally, the theoretical. method assumes all the heat is released in a duration of time equivalent to the Standard ASTM E-119 Fire Test. The resultant is a theoretical maximum equivalent Standard Fire Severity.
(The Tables in the exemption requests illustrate that the Standard 'f re Severity is extrernely low for each of the applicable fire zones. This analogy defines;a specific air temperature profile over a standard time duration. This is very conservative because it does not consider the differences in the rate of combustion of the various materials. However, by comparing these factors for specific materials, an order of magnitude on fire severities can be estimated. The longer the
" equivalent standard fire" the higher the expected severity for that combustible load. This information is also used in the realistic method where equivalent fire severity is used to determine the required fire resistance rating of building materials.
The realistic method evaluates the actual physical configuration between combustible material, non-combustible materials and building construction while applying the guidance gained from the theoretical method.
(Page 1 of 2)
~-_.
r 4J from plant inspection and fire In this method, the experience obtained T'he basic i s and estimates.
investigation temper the theoretical predict ont and spread from the found for the.
thermodynamics for fire developmencan spread by one of the mechanisms.
Fire realistic approach.
they are:
Conductive heat transfer Radiant heat energy transfer 1
2.
Convective heat transfer only after they absorb a specific 3.
i the burning Realistically, combustible materials ign teThe required energy c j
l amount of heat energy.
l directly, i.e. f tens 1 and 2, or indirect y Fire material to the adjacent materia terial), i.e.' item 3.
(e.g. burning material to air to adjacent maf aster than through the convectiv i
h d makes an even simpler, spread involving direct contact is much f
From this simple knowledge, the realistic met oW i
process.
one of the heat transfer mechanis=s, conservative presumption.
physical configuration appear conducive to t be provided.
some fire prevention or extinguishment mus tection is an emerging ac'ience loth methods have many limitations as fire proHowever, proper application o with many ansvers yet to be reached.
i n for fire risk.
BEco has will lead to solid treatment and protect otion of these methods to pr h
methods and vill continue to update their applica and property conservation.
i ft highest level of fire protection for life sa e y 9
(Page 2 of 2)
7 j
j coevou coisou ca,aur ace e sus.o= sv.cce so..o.w....c-w.
.,.ozie,
..w.
o.......s,o-CONTROL COPY M
b-November 16. 19P3 RECORD TYPEt BECc, 83 281 b
r Mr. Domenic B. Vassallo. Chief
(
Operating teactors Branch 82 KEYWOR f
f i
..3 -
D vision of Licensing
//
Of fice of Nuclear Reactor Regulation M( l U.S. t:uclear Regulatory Comission ONTROU.'E ISI IBJ1 E
Washington, D.C.
20555 License $10. 00R 35 Docket No. 50 293 YE.5 O NO Q 10CFR50, Appendix R Exemption Requests COMPONENT f.-_
Dear Sir:
b Per the provisions of 10CFR50.12 the Boston toison Company requests th RMG CONTR*d W ~
Exemption Requests all and #12 deal with for the Pilgrim Nuclear Power station.
tne requirement to have redu dant trains of equipment separated by a three hourExemption Request's n
boundary at the boundary of specific fire zones.to provide fire resistance protection to structural deal with the requirement steel members supporting fire barriers that. are separating redundant trains of safe shutdown equipment.
al through 10 were previously submitted by letter from A.V.
Exemption Reauests Merisi to 0.B. Vassallo, dated June 25, 1982 (BEC0 2.8?.180). Exempt ion Requests s5. 7
- 8. 9 and 10 were resubmitted by letter from W.O. Harr'ngton to D.B.
Vassallo, dated May 17, 1983 (BECo 2.82.130).
information or clarification Please do not hesitate to contact us if additional
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7 is needed to complete. your review.
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Very truly yours.
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Attachments: Exemption Requests all.12,13. and 14
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EXEMPTION RE00EST *11_
' 0" reactor This exemption request is f or Fire Zones 1.30A and ).6/1.8 (EL (-) 17 -
building).
i Per the provisions of 10CFR50.12, the 80ston Edison Company requerts exe l
f rom the requirements of Section III.G.2(a) of Appendix d
redundant trains of equipment separated by a 3-hour boundary at the boun ary Power Station.
between Fire Zones 1.6/1.8 and 1.30A, as shown on Figure 3.
The technical bases that justify the exemption are summarized below and the This information supporting fire zone data is given in Tables 11.1 and 11.2.
t ted
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provides reasonable assurance that the public health and safety will be pro{
in a f ashion equivalent to that resulting f rom compliance with' the specific requirements of Appendix R.
Once the proposed modifications listed in Table 11.1 are implemented for
/
Fire Zone 1.30A, the "A" and "B" trains of the residual heat removal 1.
(RHR), core spray, and automatic depressurization (ADS) systems wi be affected by a fire in this fire zone.
separated by a 3-hour fire boundary f rom Fire Zones 1.2 and 1.10 that Fire Zone 1.2 contain "B" train components required for safe shutdown.
contains components required for the "R" train of the RHR and core sprayFire Zone 1.10 conta "B" train of sy st ems.
Fire Zone 1.2 is shown on Figure 3 the RHP., core spray, and A05 systems.
and is exposed to Fire Zone 1.30A through a door opening and non-fireFire Zo rated penetration seals in a common fire wall.
to Fire Zone 1.30A through a door opening and non-fire rated penetration seals that are both in a common wall between Fire Zones 1.30A and 1.5/1.7, and then through an open stairwell up f rom Fire Zone 1.5/1.7 to Fire Zone Because of the lack of a 3-hour rated fire boundary between Fire l
Zone 1.30A and Fire Zones 1.2 and 1.10, Fire Zone 1.30A is considered to 1.10.
be a "B" train area even though neither tr'ain of the above safe shutdown systems would be af fected by a fire in this fire zone, I
j Fire Zone 1.6/1.8 does not contain any components required for safe shut-However, Fire Zone 1.6/1.8 is common to Fire Zone 1.9 by an open stairwell and Fire Zone 1.9 contains "A" train components required forBecause Fire Zon down.
zone is considered to be an "A" train area even though this zone does not safe shutdown.
contain any components required for safe shutdown.
The lack of a 3-hour rated fire boundary between Fire Zones 1.30A and 1.1 is the subject of Exemption Request #12.
The common boundary between Fire Zones 1.6/1.8 and 1.30A is a 36" thick concrete wall, which is 3-hour fire rated with the exception of the door 2.
opening and penetration seals between the two areas.
The closest redundant "B" train components are located in Fire Zone 1.2 The closest approximately 100 feet horizontally f rom the common boundary.
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redundant "A" train component is located in fire Zone 1.0 approximately 20 feet horizontally and 20 feet vertically f rom the common boundary.
The two redundant fire zones,1.0 and 1.2, are separated by fire Zones Fire Zones 1.30A and 1.6/1.8 are 3.
1.30A and 1.6/1.8 as shown or, figure 3.
on Tables 11.1 almost totally free of intervening combustibles as showreThese tab and 11.2.
dant trains of safe shutdown components.
These fire zones are not likely to be exposed to additional fire loading These areas are not used as access 4
in the form of transient combustibles.
to other plant areas and are not normally occupied because of. ALARA con-cerns.
The objective for the protection of safe shutd?wn capability is to ensure that at least one means of achieving and maintaining safe shutdown con-5.
ditions will remain available during and af ter ny postulated fire in the Modifications that would be required to meet the requirements of Section Ill.G.2(a) of Appendix R would not enhance the fire protection station.
The existing safety of Pilgrim over and above the existing conditions. conditi down equipment will remain f ree of fire damage f ar any postulated fire in the area.
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y EXEMPTION REQUEST #12 This exemption request is for Fire Zones 1.30A and 1.1 (El (-) 17'-0" reactor building).
Per the provisions of 10CFR50.12, the Boston Edison Company requests exemption from the requirements of Section III.G.2(a) of Appendix R for the Pilgrim Nuclear Specifically, exemption is requested from the requirement to have Power Station.
redundant trains of equipment separated by a 3-hour boundary at the boundary between Fire Zones 1.1 and 1.30A, as shown on Figure 3.
The technical bases that justify the exemption are summarized below and the This information supporting fire zone data is given in Tables 11.1 and 12.1.
provides reasonable assurance that the public health and safety will be protected in a fashion equivalent to that resulting from compliance with the specific requirements of Appendix R.
Once the proposed modifications listed in Table 11.1 are implemented for 1.
Fire Zone 1.30A, the " A" and "B" trains of the RHR, core spray, and ADS However, Fire systems will not be affected by a fire in this fire zone.
Zone 1.30A is not separated by a 3-hour fire boundary from Fire Zones 1.2 and 1.10 that contain "B" train components required for safe shutdown.
Fire Zone 1.2 contains corr.ponents required for the "B" train of the 4HR Fire Zone 1.10 contains components required for and core spray systems.
Fire Zone 1.2 is the "B" train of the RHR, core spray, and ADS systems.
shown on Figure 3 and is exposed to Fire Zona 1.30A through a door opening and non-fire rated penetration seals in a co.nmon fire wall.
Fire Zone 1.10 is exposed to Fire Zone 1.30A through a door opening and non-fire
[
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rated penetration seals that are both in a common wall between Fire Zones 1.30A and.1.5/1.7, and then through an open stairwell up from Fire Zone 1.5/1.7 to Fire Zone 1.10.
Because of the lack of a 3-hour *ated fire boundary between Fire Zone 1.30A and Fire Zones 1.2 and 1.10, Fire Zone 1.30A is considered to be a "B" train area even though neither train of the above safe shutdown systems would be affected by a fire in this fire 5
zone.
Fire Zone 1.1 contains components required for the "A" train of the RHR 4
and core spray systems.
The lack of a 3-hour rated fire boundary between Fire Zones 1.30A and
)
1.6/1.8 is the subject of Exemption Request #11.
The common boundary between Fire Zones 1.1 and 1.30A is a 36" thick con-2.
crete wall, which is 3-hour fire rated with the exca.ption of the door opening and penetration seals between the two areas.
The closest redundant "B" train components are located in Fire Zone 1.2 The closest approximately 150 feet horizontally f rom the. common boundary.
redundant "A" train component is located approximately 5 feet from the common boundary.
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EXEMPTION REQUEST al3 This exemption request is for Fire Zone 1.30A (EL (-) 17'-O reactor building, torus compartment).
Per the provisions of 10CFR50.12, the Boston Edison Compa J
Specifically, exemption is requested from the requirement to provide fire resistance protection to structural steel members supporting fire Power Station.
barriers that are separating redundant trains of safe shutdown equipment.
The technical bases that justify the exemption are summarized below and the This information provides supporting fire zone data is given in Table 11.1. reasonable assurance f ashion eauivalent to that resulting f rom compliance with the specific require-ments of Appendix R.
Fire Zone 1.30A (torus compartment) is located below two redundant fire zones in the reactor building that contain components required for safe 1.
Therefore, the failure of the structural steel in the torus shutdown.
compartment ceiling could adversely affect the fire boundary between the A fire two redundant fire zones located above the torus compartment.
would have to spread to both sides of the torus compartment before redun-dant components could be affected.
In cases where the structural steel is not protected and has a lower fire rating than that required of the fire barrier, an exemption must be justi-2.
fied by a fire hazard analysis which shows the temperature the steel will reach durirg a fire and the ability of the steel to carry the required loads at that temperature.
Boston Edison has evaluated the effects of elevated temperatures on exposed structural steel and has determined that structural steel will withstand a maximum temperature of 650 F without seriously impairing its ability to sustain loads at the unit stresses permitted by the Pilgrim Final Safety Analysis Report (FSAR). The combustible loading in Fire Zone 1.30A has been evaluated to determine what temperature change would occur in the The combustible loading in this fire zone structural steel due to a fire.
is approximately 65';960j000,4TUs and is almost equally distributed through-There exists approximately 2483@@tstn of structural out the fire zone.
steel in the ceiling that supports the floor for the' two redundant fire A heat transfer calculation was performed to determine the zones above.
change in temperature of the steel due to the combustible loading using
,the following assumptions:
The structural steel will f ail at 650'F.
a.
The initial steel temperature is 70*F.
b.
f The total heat load is released by the combustible loading instan-j c.
taneously, I
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e All of the heat load released by the combustible loading is absorbed None of the heat loaa is spent in heating d.
by the structural steel.
the air, walls, etc.
The structural steel heats uniformly, e.
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The change in temperature of the structural steel due to th loading is 256*F.
This temperature is well below steel temperature would be only 326 F.
the 650*F assaned to fail the structural steel.
Fire Zone 1.30A is not likely to be exposed to additional fire loading in-This fire zone is not used as access 3.
the farm of transient combustibles.
to other plant areas and is not normally occupied because of ALARA con-cerns.
Modifications that would be required to provide a fire resistive coating to the structural steel supporting the ceiling of Fire 7one 1.30A would 4
not enhance the fire protection safety of Pilgrim over and abon be The existing conditions are sufficient to ensure existing conditions.
that neither train of safe shutdown equipment will be damaged by a postu-lated fire affecting the structural steel in Fire Zone 1.30A.
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e EXEMPTION RE00EST el4 This exemption request is for Fire Zone 1.32 (EL 23'-0" reactor building - steam tunnel).
Per the provisions of 10CFR50.12, the Boston Edison Company requests exemption f rom the requirements of Section III.G.2(a) of Appendix R for the Pilgrim Nuclear Specifically, exemption is requested f rom the requirement to pro-Power Station.
vide fire resistance protection to structural steel members supporting fire barriers that are separating redundant trains of safe shutdown equipment.
The technical bases that justify the exemption are suonarized below and the This information provides supporting fire zone data is given in Table 14.1. reasonable assurance th f ashion equivalent to that resulting f rom compliance with the specific require-ments of Appendix R.
Fire Zone 1.32 (steam tunnel) is located below two redundant fire zones in 1.
the reactor building that contain components required for safe shutdown.
Therefore, the failure of the structural steel in the steam tunnel ceiling could adversely af fect the fire boundary between the two redundant fire zones located above the steam tunnel.
Only a small section of the steam tunnel ceiling is part of the fire boundary for the redundant areas above.
This small section of ceiling is being supported by one structural steel member that is partially enclosed in concrete and would not be affected The unenclosed portion of the beam is the subject of this by a fire.
In cases where the structural steel is not protected and has a lower fire 2.
rating than that required of the fire barrier, an exemption must be justi-fied by a fire hazard analysis which shows the temperature the steel will reach during a fire and the ability of the steel to carry the required loads at that temperature.
Boston Edison has evaluated the effects of elevated temperatures on exposed structural steel and has determined that structural steel will withstand a maximum temperature of 650*F without seriously impairing its ability to There sustain loads at the unit stresses permitted by the Pilgrim FSAR.
exists approximately *Jp0%1bs of exposed structural steel in the ceiling The combustible-loading in the steam tunnel is almost of the steam tunnel.
Therefore, it is not possible to determine the change in non-exi stent.
temperature of the steel due to a fire.
Instead, calculations were per-formed to determine what combustibles would be required to raise the The calculation was based
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temperature of the steel to the failure point.
on the following assumptions:
The structural steel will f ail at 650 F.
a.
The initial steel temperature is 70*F.
b.
The total heat load is released by the combustible loading instan-c.
t aneously.
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All of the heat load released by the combustible loading is absorbed by the structural steel.
None of the heat load is spent in heating d.
the ai r, walls, etc.
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The structural steel heats uniformly.
e.
18,025,327 BTUs to The calculations show that it would take approximatelyWith approximately raise 29,045 lbs of steel to a temperature of 650 F.
840 square f eet of floor area, 21,500 BTUs per square foot wo required.
loading in this fire zone would have 2.69.lbs of wood per square footBecau before steel f ailure would occur.
in the steam tunnel is negligible, steel failure cannot occur due to an exposure fire in this fire zone.
Fire Zone 1.32 is not likely to be exposed to additional fire loading in 1
3.
This fire zone is not used as access the form of transient combustibles.
to other plant areas and is not normally occupied because of ALARA con-cerns.
l Modifications that would be required to provide a fire resistive coating 4
to the structural steel supporting the ceiling of Fire Zone 1.32 would not enhance the f're protection safety of Pilgrim over and above the existing l
The existing conditions are sufficient to ensure that neither j
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train of safe shutdown equipment will be damaged by a postulated fire affecting the structural steel in Fire Zone 1.32.
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TABLE 11.1 AREA DATA FOR FIRE ZONE 1.30A:
REACTOR BUILDING EL (-)
17'-6",
TORUS COMPARTMENT A.
AREA CONSTRUCTION Walls are 36" thick concrete with 3-hour penetra-1.
Walls - See Figure 3.
tions with the exception of:
l Doorways into the quadrants, which are not fire doors, and a.
Penetrations into the quadrants which have not been upgraded to a b.
3-hour fire rating.
Floor - 96" thick concrete slab on soil.
2.
Ceiling - 24" thick concrete slab; 3-hour rated with 3-hour penetration 3.
seals.
4 Ceiling height - 38'-6".
Area Volume - The area volume less the torus (pressure suppression chamber) 5.
is approximately 235,740 cubic feet.
General access j
Congestion - Area is essentially free of floor congestion.
6.
for manual fire suppression is adequate.
B.
SAFE SHUTDOWN EOUIPMENT Af ter the proposed modifications are implemented for tnis fire zone, only components for the reactor core isolation cooling (RCIC) and high pressure l
coolant injection (HPCI) systems would be affected by a fire in this fire I
Safe shutdown could be achieved using the " A" and/or "B" trains of The exception to this is torus water zone.
the RHR, core spray, and ADS systems.
level and torus temperature instrumentation which is the subject of Exemption Even though this fire zone does not contain'"B" train components
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Regpest M5,
of the'RHR, core spray, and ADS systems, this fire zone is not separated from the "B" train RHR, core spray, and ADS systems by a 3-hour fire houndary.
Therefore, Fire Zone 1.30A is part of a fire area that contains "R" train components required for safe shutdown.
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C.
COMBUSTIBLES The combustible materials in Fire Zone 1.30A (torus compartment) are pri-The fire loading and the theoretical marily fire retardant treated stagin.
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2 below:
fire exposure are described ~Tii the table See the letter from W.D. Harrington to 0.B. Vassallo, dated May 17, 1983 1
(BEco 2.83.130).
Reprinted from Table 1-1, Fire Protection System Review APCS 8 9.5-1.
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h~,FIrdRotardant b! Y
.E u ae Quantity Co ui c
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Combustible
--Gomhnti hi m Theoretical Type / Weight, Through Fire Fife'Yxposur~6,
-Protection Minutes Type Fire Zone lbs Zone 2
4.4 Yes-Wood Stag-No. 1.30A Wood Staging A No ing has been (reactor 8200 painted with b1dg. elev.
fire retardant
(-l 17 ft) coating.
1 IEEE 3R3_ Cable -
No No. 1.30A Cable /24 1 tray.
(reactor i
bldg. elev.
(-) 17 ft)
The theoreti-There are two approaches to. analyzing fire spread potentials.
cal method mathematically compares specific plant fire loads to time-temperature fire.
specific combustibles and the possibility of fire propagation within the l
array.
Theoretical inalysis Boston Edison used the theoretical approach to identify the standard fire exposure for comparison purposes and general understanding of the order of Any fire with a standard magnitude of the worst case fire in this area.
This fire exposure under 30 minutes is in the lowest severity category.
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zone has a standard fire exposure of less than five minutes.
Boston Edison believes that any further use of the theoretical approach is unwarranted since this method is heavily dependent on defining a design basis fire (DBF) and the correlation between a D8F and a real fire has not been i
More importantly, Boston Edison postulates that satisfactorily established.
this is unnecessary because the realistic approach is adequate to obtain an appropriate level of fire protection.
Realistic __ Analysis The realistic approach identifies the potential methods for fire spread from Fire Zone 1.30A to Fire Zones 1.6/1.8 or 1.1.
Conductive heat transfer and direct flame impingement are not poss ble acrws d
f these paths because there is no continuity of combustible materials in any of these paths.
See Appendix A for a more detailed description of the theoretical and realistic 1
analysis methods.
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2 This is fire retardant coated wood on temporary staging. The staging encircles The wood staging is also encapsulated with a mate-the exterior of the torus.
rial with fire retardant capabilities.
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Radiant heat transfer can only be a factor in fire spread when there is a straight, unobstructed (i.e., line of sight) path between the fire exposed material.
f rom Fire Zone 1.30A to Fire Zones 1.6/1.8 or 1.1.
In order to have convective heat transfer, a fire in the torus compartment would have to produce enough heat to raise the am ble torus compartment and adjacent quadrants to the auto-ign in the torus compartraent or adjacent quadrants to raise the ambient tempera-insulation.
ture in this area to the required temperature.
D.
EXISTING FIRE PROTECTION None 1.
Fire detection systems:
None 2.
Fire extinguishing systems:
There are no portable extinguishers or 3.
Hose stations / extinguishers:
However, there is one hose reel and hose reels in the torus compartment.
one portable extinguisher in each quadrant adjacent to the torus compart-ment that will reach all areas in the torus compartment.
4 Radiant heatshield:
None Cables are coated with Flamemastic or qualified 5.
Propagation retardants:
to IEEE-383.
E.
PROPOSED MODIFICATIONS The following modifications proposed for Fire Zone 1.30A will ensure that one train of safe shutdown equipment will remain free of fire damage for any postulated fire in the area, The torus water temperature instrumentation is being modified as pre-viously described in Exemption Request #5.
a.
The power and control cable for the "A & B" diesel generator fuel oil transfer pumps are being rerouted out of the torus compartment as pre-b.
viously described in Boston Edison's response to Appendix R, submitted by letter dated June 25, 1982.
The power cables feeding Motor Control Center (MCC) B18 will be rerouted MCC B18 feeds components required for the c.
out of tha torus compartment.
"B" train of the RHR and core spray systems.
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> s TABLE 11.2 AREA DATA FOR FIRE ZONE 1.8/1.6:
REACTOR BUILDING EL (-) 17'-6",
CONTROL ROD DRIVE QUADRANT A.
AREA CONSTRUCTION 1.
Walls - See Figure 3.
North 48" thick concrete wall, 3-hour rated.
(Column Line-P)
East - 36" thick concrete wall, 3-hour rated.
(Column Line-17) l Southwest - 36" thick concrete wall, 3-hour rated with the exception of a door opening and penetration seals into the torus compartment.
Floor - 96" thick concrete slab on soil.
2.
Ceiling - 15" thick concrete slab, 3-hour rated with 3-hour penetration seals, with the exception of an open stairwell to Fire Zone 1.9 which 3.
is not a redundant area to Fire Zones 1.8 and 1.6 l
4 Ceiling height - 39'-3" Area Volume - Approximately 25,000 cubic feet.
5.
General access for manual 6.
Congestion - Area is free of floor congestion.
fire suppression is good.
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SAFE SHUTDOWN EOUIPMENT No cables or components that are required to be operable for safe shutdown
~
i However, since this fire zone is open to are located in this fire zone.
Fire Zone 1.4 by an open stairwell, this fire zone is part of a fire area J
that contains " A" train components required for safe shutdown.
C.
COMBUSTIBLES The combustible material installed in Fire Zone 1.6 and Mezzanine 18 is pri-The fire loading is described in the tablel elow:
b narily lubrication oil.
Quantity Continuity of Equivalent Combustible Combustibles Theoretical Fire Retardant Type / Weight, Through Fire Fire Exposure, Protection i
Fire Zone lbs Zone Minutes Type No. 1.6 &
Lubrication No 3.6 N/A 1.8 (reactor Oil / Minimal bldg. el ev.
(-) 17'-6")
1 Reprinted from Table 1-1, Fire Protection System Review APCSB 9.5-1.
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The theoreti-There are two approaches to analyzing fire spread potentials.
cal method mathematically compares specific plant fire loads to a standard The realistic method evaluates the physical array time-temperature fire.
of specific combustibles and the possibility of fire propagation within the 1
l array.
Theoretical Analysis
_ Boston Edison used the theoretical approach to identify the standard fire exposure for comparison purposes and general understanding of the order of Any fire with a standard magnitude of the worst case fire in this area.
Fire Zone exposure under 30 minutes is in the lowest severity category.
1.8/1.6 has a standard fire exposure of 3.6 minutes.
Boston Edison believes that any further use of the theoretical approach is unwarranted since this method is heavily dependent on defining a design basis fire (DBF), and the correlation between a DBF and real fire has not been More importantly, Boston Edison postulates that satisfactorily established.
this is unnecessary because the realistic approach is adequate to obtain an appropriate level of fire protection.
Realistic Analysis The realistic approach identifies the potentiel methods for fire spread from Fire Zone 1.6/1.8 to Fire Zone 1.30A.
Conductive heat transfer and direct flame impingement are not possible across this path because there is no continuity of combustible materials.
Radiant heat transfer can only be a factor in fire spread when the e is a The all line of sight path between the fire and the exposed material.
between Fire' Zones 1.6/1.8 and 1.30A effectively eliminates the line of sight and will realistically prevent fire spread by radiant energy transfer.
Convective 5 eat transfer could only occur after the fire produced enough hest to raise the ambient temperature in Fire Zone 1.30A to the auto-ignition This cannot occur because there is not a suffi-point of cable insulation.
cient combustible loading in Fire Zone 1.6/1.8 to raise the ambient tempera-ture to the auto-ignition point of cable insulation.
0.
EXISTING FIRE PROTECTION 1.
Fire Detection Syste'ns:
None 2.
Fire Extinguishing Systems:
None Hose Stations /Extingtiishers:
1 Hose Reel 3.
1 Portable Extinguisher See Appendix A for a nore detailed description of the theoretical and realistic i
1 f
analysis methods.
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4 Radiant Heat Shield:
None 5.
Propagation Retardants:
None 1
E.
PRODOSED MODIFICATIONS I
No modifications are' proposed for Fire Zone 1.6/1.8.
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The theoreti-There are two approaches to analyzing fire spread potentials.
tal method mathematically compares specific plant fire loads to a standard The realistic method evaluates the physical array time-temperature fire.
of specific combustibles and the possibility of fire propagation within the l
array.
Theoretical Analysis Boston Edison used the theoretical approach to identify the standard fire exposure for comparison purposes and general understanding of the order of Any fire with a standard magnitude of the worst case fire in this area.
Fire Zone 1.1 exposure under 30 minutes is in the lowest severity category.
has a standard fire exposure of 9 minutes.
Boston Edison believes that any further use of the theoretical approacn is unwarranted since this method is heavily dependent on defining a desi<jn. basis fire (DBF), and the correlation between a DBF and real fire has not been More importantly, Boston Edison postulates that satisf actorily established.
this is unnecessary because the realistic approach is adequate to obtain an appropriate level of fire protection.
Realistic Analysis The realistic approach identifies the potential methods for fire. spread from Fire Zone 1.1 to Fire Zone 1.30A.
Conductive heat transfer and direct flame impingement are not possible across this path because there is no continuity of combustible materials.
Radiant heat. transfer can only be a factor in fire spread when there is a The wall line of sight path between the fire and the exposed materir.l.
between Fire Zones 1.1 and 1.30A ef fectively eliminates the line of sight and will realistically prevent fire spread by radiant energy transfer.
Convective heat transfer could only occur after the fire produced enough neat to raise the ambient temperature in Fire Zone 1.30A to the auto-ignition This cannot occur because there is not a suffi-point of cable insulation.
cient combustible loading in Fire Zone 1.1 to raise the ambient temperature to the auto-ignition point of cable insulation.
D.. EXISTING FIRE PROTECTION 1.
Fire Detection Systems:
3 Photoelectric Smoke Detectors 2.
Fire Extinguishing Systems: hone 3.
Hose Station / Extinguishers:
1 Hose Reel See Appendix A for a more detailed description of the theoretical and realistic 1
analysis methods.
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4.
Radiant Heat Shields:
None Cables are coated with Flamemastic or qualified
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5.
Propagation Retardants:
to IEEE-383.
E.
PROPOSED MODIFICATIONS 4
No modifications are proposed for Fire Zone 1.1.
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TABLE 14.1 REACTOR RUILDING EL 23'-0", STEAM TUNNEL AREA DATA FOR FIRE ZONE 1.32:
A.
AREA CONSTRUCTION 1.
Walls:
North - 60" thick drywell shield wall.
West 42" thick concrete wall, 3-hour fire rated with 3-hour rated penetration seals.
East 42" thick concrete wall, 3-hour rating is not required because adjacent area is not a redundant area.
South - A partition wall, 2-hour fire rated.
Flocr - 12" thick concrete slab, 3-hour fire rated with 3-hour rated 2.
penetration seals.
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Ceiling - 24" thick concrete slab, 3-hour fire rated with 3-hour rated 3.
penetration seals.
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Ceiling height - 27 feet.
Area volume - Approximately 22,032 cubic feet.
5.
Congestion - Generai access for manual fire suppression is good.
6.
B.
SAFE SHUTDOWN EQUIPMENT The only shutdown systems potentially lost to fire in the steam tunnel are The loss of these systems does not prevent safe the RCIC and HPCI systems.
shutdown.
C.
COMBUSTIBLES I
l The combustible loading in the steam tunnel is almost nonexistent.
l 0.
EXISTING FIRE PROTECTION I
f 1.
Fire Detection Systems:
None 2.
Fire Extinguishing Systems:
None 3.
Hose Stations / Extinguishers:
Hose reel and portable extinguisher located in adjacent area.
E, PROPOSED MODIFICATIONS j
No modi fications are proposed for Fire Zone 1.32.
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APPENDIX A THEORETICAL AND REALISTIC FIRE ANALYSES There are two approaches to analyzing fire and its development - the theoreti-cal and realistic methods.
This method The theoretical method models the chemistry and physics of fire.
manifests itself through laboratory testing and identifies standard or minimum These parameters are useful for comparison developmental parameters for fire.
purposes and selection of materials, components, or plant configurations during For example, the theoretical method cowerts all combustible material l
within a specific volume of the plant to its " equivalent" calorimetric heating design.
l The heat loads are totaled for all materials in that plant volume.
Finally, the theoretical method assumes that all the heat is released in a dura--
value.
The result is a tion of time equivalent to the Standard ASTM E-119 Fire Test.(The tables in the theoretical maximum equivalent standard fire severity.
exemption requests illustrate that the standard fire severity is extremely low This analogy defines a specific air for each of the applicable fire zones.
This is very conservative 1
temperature profile over a standard time duration.
because it does not consider the dif ferences in the rate of combustion of the However, by comparing these factors for specific materials, various materials.
The longer the an order of magnitude on fire severities can be estimated.d fire" the higher the
'I
" equivalent sta,This information is also used in the realistic method where equivalent fire severity is used to determine the required fire resistance rating of building load.
materials.
The realistic method evaluates the actual physical configuration between combus-tible material, non-combustible materials, and building construction while apply-ing the guidance gained from the theoretical method.
In this method, the experience obtained from plant inspection and fire investiga-The basic thermodynamics tion temper the theoretical predictions and estimates.
for fire development and spread form the foundation for the realistic approach.
Fire can spread by one of the following mechanisms.
1.
Conductive heat transfer 2.
Radiant heat energy transfer 3.
Convective heat transfer Realistically, combustible materials ignite only after they absorb a specific The required energy can be transferred from the burning amount of heat energy.
material to the adjacent material directly (i.e., Mechanisms 1 and 2) or indirectly Fire (e.g., burning material to air to adjacent material; i.e., Mechanism 3).
spread involving direct contact is much faster than through the convective pro-From this simple knowledge, the realistic method makes an even simpler, When combustible c.aterials are present, and their cess.
conservative presumption.
physical configuration appear conducive to one of the heat transfer mechanisms, some fire prevention or extinguishment must be provided.
19
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SeWTWM E98 SON cStefBAftY see sevtavam eyeser
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February 3.1986
, 3 gy SECo 86-009
- - lTy,E.g d df
r Mr. John A. Zwolinskt. Olrector E,
E @ O',
INR Project Directorate #1 1
I Ff 8 34g
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l Division of Licensing Office of Nuclear Reactor Regulation FOR USE
.;C e s M /' $
A U.S. Nuclear Regulatory Commission d _g/;;
'2 %
Nashington D. C.
20555
- MC'!(( D.'?1?'[L 'h :
License DPR-35
'I Docket 50-2g3
Subject:
Pilgele Nuclear Power Station Appendia R Esseption Request b D b'
References:
- 1) Neeting between the NRC (R. Ferguson. 5. Nest and
%. #..'i #
i M. Thadant) and SEco (T. A. Venkataraman. R. Ve!sr and M. J. 01Neo) on October 17 at the Philips Building dEOddl8 2)
Co e te 83-130 dated 5/17/83
- 3) INtc Safety Evaluation dated 12/18/84
Dear Str:
This letter is a followup to the meeting Soston Edison Company (SEco) had with your staff on October 17. Igel at the Philips Building in tethesda (Reference i
1). During the meeting SEco presented to your Staff a modified design to the water curtain which was initially recosmonded by SECo in Reference 2 and approved by your Staff in Reference 3.
The modified design consists of Insta111ng a two branchline wet pipe spridler systee over the 20 ft. separation anae between fire zones 1.11 and 1.12 at elevation 51'-0* and between fire zones 1.g and 1.10 at elevation 23'-0" in huCLiAR Ott.1Ris.;ic the heactor Building. As part of the discussion, the Staff recommended that
,e "E
i the proposed modified design would be acceptable if supplemented by a draft curtain between the two branchez sprinkler systes along with metal shleids for j
lower level sprinkler heads to shleid thee fras water sprays from the ceiling level sprinkler heads.
.ls o )
Boston Edison presented to your Staff a marked up version of our Initial esemption request (Reference 2) including the layout plan and elevation drawings for the sprinkler system. The attachments to this letter are SECo's gg, formal submittal of the revised esemption request e41th is resubmitted pursuant to 10CFR50.12. Changes to the esemption roguest are indicuted by n.
vertical bars.
1 I
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9
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4
1
. BOSTON EDlSON COMPANY Mr, John A. Zwolinski, Director
(
February 3, 1986 4
Page 2 l
Should you have any questions or concerns as a result of your review, please do not hesitate to contact us.
80ston Edison is, however, proceeding ahead with the implementation of the modified design to be in compliance with the Appendix R for this area by the RF0 #7.
Very truly yours, W
TAV/ns t
4
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4 4
,1 I
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k ct1MPTION REQUEST #7 Esemption Request For Fire Zonais 1.9 and 1.10 (E1, 23'-0" Ra Building),
per the provisions of 10CFR50.12. Boston Edison Company requests
~
eamsption free the requirements of section 111G.2 (b) of. Appendia R for
'the pilgris Nuclear Generating Station.
g ecifically, esemption is p
requested free the requirement.to have an automatic fire suppression system installed throughout fire sones 1.9 and 1.10 and free the requirements of having redundant trains of equipment required for safe shutdown separated by a horisontal distance of more than 20 feet with no intervening combustibles. or' fire hasards.
Boston Edison is proposing, as part of the modifications for these fire sones, to install sprinkler protection in the boundary ares separating these fire sones as shown on figure #1. The esanption request is necessary to emespt Boston Edison Company from the reevirements to provide total area sprinkler protection for both fire zones.
The horisontal separation between redundant trains required for safe shutdown is such greater than the 20 feet required by section 111G.2 (b) of Appendix R.
Bowever, there are cable trays in the separation area that are considered combustibles.
The technical bases which justify the exemptions are sumnarised below and the supporting fire sone data is given in' tables 7.1 and 7.2.
This
(
information provides reasonable assurance that-the public health and safety will be protected in a fashion equivalent to that resulting from coupliance with the specific requirements of Appendix R..
i 1.
ytre sones 1.9 and 1.10 are part of a fire area in the Rm Building.
E1 23'-0".
Fire sones 1.9 contains "A" train components required for safe shutdown.
i Fire sone 1.10 contains "B" train components required for safe shutdown. These fire sones are separated by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> boundary along their common boundary encept for an ares approximately 30 feet wide on the North side of the building.
2.
Once modifications are implemented as described in tables 1.1 and 1.2, not shutdown equipment in fire mene 1.9 will be separated from the redundant hot shutdown equipment la fire some 1.10 by a horisontal distance of approminately 75 feet.
Cold shut-down equipment in fire sone 1.9 will be esperated from the redundant cold shutdown equipment in fire some 1.10 by a horizontal distance of approximately 100 feet.. These distances given
'are the closest dimensions between cables or conposents that'are part of systems required for hot or cold shutdown.
3.
The combustible leading between Fire zones 2.9 and 1.10 is autremely.
Iow. These sones are separated by a volme that is essentially free of combustible asterials.
1 (page 1 of 2)'
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The only fixed' combustible material in the separating volume is cable insulation.
The insulation is either IEEE Std. 383 qua11 fled cable or the.
4 cables have.been coated with an approved fire retardant material.
There are only six trays within the separation volume.
These trays are at least i
one foot apart.
These factors will preclude a fire within any one of the six. trays from interacting with the other trays and propagating across the separation volume.
Total automatic fire suppression would not enhance the protection of safe.
shutdown functions provided by the present configuration and proposed modifications.
1 The combustible. loading in fire zones 1.9 and'1.10 creates a maximum theoretical fire exposure of only minutes..The nearest safe shutdown equipment is 75 feet apart and separated by a minimum 20 feet. wide clear space. These factors coupled with the proposed sprinkler system within
.the separation clear space will assure at least one train of safe shutdown equipment will remain free of fire damage in this area.
4.
Automatic smoke detection exists in both fire zones which alarms in the continuously manned Control Room.
5.
The objectives for the protection of safe shutdown capability is-to insure that at least one means of achieving ard maintaining safe shutdown-conditions will remain available.during and after any postulated fire in y
the station-Modifications required to meet the requirements of Section
(
III G. 2 of Appendix.R would not enhalce the fire protection safety of Pilgrim Station any better than the modifications proposed by 80ston Edison Company for these two fire zones.
The modification proposed for these two fire zones, as described in Table 1.1 and 1.2, will insure that at least one train of safe shutdown equipment will remain free of fire damage for.any postulated fire in the area.
6.
Modifications required to meet the requirements of Section III G. 2 of Appendix R would in fact be detrimental to overall facility safety. These fire zones are too large and porous to peralt the installation of-an effective gaseous suppression system. Additionally it is not possible to
.J install a total area sprinkler system in either of the fire zones.
There 1
are many wide obstructions (i.e. cable trays, HVAC ducts, pipes, etc.)
between the floor and ceiling such that colling level sprinklers would not be able to protect anything over several feet below the ceiling. Many additional levels of sprinklers would be needed. -With-the additional sprinkler pipes and sprinklers the probability of accidental discharge is substantially-increased. The water damage to safety related equipment-from real or inadvertent actuation represents an unacceptable risk to Boston Edison Company.
H l
q (Page 2 of 2) i
j s
EXIMpTION REQUEST #8,
{
- s 1
I Esemption Request for Fire Zoos 1.11 asc 1.12 (EL 51'-0" 21 Su11 ding).
1 per the provisions of 10CF150.12. Boston Edison Company requests assumption from i
the requirements of Section 111 C.2'(b) of Appendix R for the Pilgrim Wuclear Gamerettag Station. Specifically, esemption is requested fras the requirements to have as antamatic fire suppression system installed throughout fire sones 1.11 and 1.12.and from the requirements 6f having redundant trains of equipment require est safe shutdown separated by a horisontal distance of more than 20 feet with no intervening combustibles or fire hasards.
t Boston Edison is propostag, as part of the modifications for these fire zones.
to install sprinkler protection in the boundary area separating these fire zones as shown in Figure #2. N exemption request is necessary to exempt Boston. Edison Campany from the requirements to prov14 total area sprinkler protection for both fire sones. The horisontal separatt u between redundant traias required fer safe shutdown is much greater than the.20 feet required by Section'111 C.2,(b) of Appendix R.
Bowever. there are estble trays in the separation area that are con-sidered combustibles.
{
l h technical bases which justify the exemptions are sumsarised below and the supporting: fire zone date is given 13 Tables.8.1 and 8.2.
2his information pro-vides reasonable assurance that the p,4 11e health and safety will he protected in a fashion equivalent to that resultin's from compliance with the specific require-ments of Appendix R.
j 1.
Fire sones 1.11 and 1.12 are' part of a fire area in the RX Suilding.
EL 51'-0".
Fire zone d.11 contains "A" trata components required for
(
safe shutdown. Fire some 1.12 contains "B" train camponents required for safe shutdown. N fire saaes are separated by a three hour fire l
bondary except in the following areas:
(s) An area approximately 40 feet wide sloog the crammon boundary on the north side of the building,i (b) As area approximately 11 feat wide along the common boundar> on the
, south side of the building, and (c) through an open hatchway and stair j
}
well to the elevation above these fire sones.
\\
q 2.
Once modiff. cations are implemented. as described ta Tables 2.1 and 2.2 bot shutdown equipment ta fire some 1.11 will be separated from the redundant hot shutdown aquipment in fire some 1.12 by a horizontal distance of approminately 70 fee:. Cold shutdown equipment in fire' same 1.11 will be separated fram the co34 shutdown equipment in fire some 1.12 by a borisontal distance of M feet. h oe distances given are the closest dimenstaus between cables of camponents that are part of systeens requir*J for het or cold shutdowns.
3.
h combustible loading between fire scoes 1.11 and 1.12 of elevation 51 ft. is estramely law.-
N only fixed combustible ma?.orial in the north and south separation sones of elevation of 51 ft. is cable insulation. h insulation is either>
IEEE std. 383 qualified cable or the cables have been casted with an approved fire retardant esterial. bre are saly five cable trays in I
the sorth separaties vol me and there are three nrays in the south separation voluse.
k i
Page I of 2
sc 1
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i All trays are at least one foot apart in each direction. These factors will preclude a fire within any.one of the five trays from interacting.
with the other trays and propagating.across the separation volume.
The combustible loading in fire zone 1.11 car 1.12 creates a maximum theoretical fire exposure of only minutes.. The nearest safe-shutdown equipment is 70 feet apart.and separated by a minimum 20 ft. wide clear' space. These factors. coupled with the proposed sprinkler system with1' -
n the separation clear space will assure at-least one train,of. safe shutdown-equipment will remain free of fire damage in this area.
4.
Automatic smoke detection. exists in fire zones 1.11 and 1.12 which alams in the continuously manned Control Room.
5.
Even though the ceilings of zones 1.11 and 1.12 do not have rated three hour boundaries, this does not present a safe shutdown problem because of the following existing conditions:
a) 411 penetrations in the ceilings of the two areas are three hour -
rated expect for the hatchway and stairwells.
b) The areas above these fire zones do not contain equipment:or "
cables required for safe shutdown.
~
c) The areas above these fire zones are equipped with automatic smoke detection, hose stations;and portable fire extinguishers.
(
d) The combustible loading is low as shown in Table 2.1 e) The hatchway and stairwell that forms the boundary violation, is separated by a horizontal distance of approximately 80 feet.
j 6.
The objectives for the protection of safe shutdown'is to insure that at least one means of achieving and maintaining safe shutdown conditions will-remain available during and after'any postu ated fire in the station.
Modifications required to meet the requirements of Section III G.2'of 4
Appendix R would not enhance the fire protection safety of Pilgrim Station e
any better than the modifications proposed by Boston Edison Company for these two fire zones.
The modifications proposed for these two fire zones, as described in Table 2.1 and-2.2, will. insure that at least one train of safe shutdown equipment will remain free of fire damage for any.
postulated fire in the area.
7.
Modifications required to meet the requirements of Section-III G.2 of' Appendix R would in fact be detrimental to overall facility safety. These fire zones are too large and porous to permit'the installation of an
- effective gaseous suppression system.- The wLter damage to safety related 1
equipment from real or inadvertent actuation of a sprinkler system j'
represents an unacceptable risk to Boston Edison' Company.
.i i
(Page:2 of 2)
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'I TABLE 7.1 FIRE ZONE 1.9: REACTOR BUILDING ELEVATION 23'-0", EAST SIDE AAEA DATA A.
AREA CONSTRUCTION 1.
Walls s
See Figure #1 North 27" concrete wall plus 6* pre-cast panel; 3-hour rated with 3-hour penetration seals.
(column Line-P) j South 42" concrete wall; 3-hour rated with 3-hour rated penetration seals.
(column Line-H)
East 33" concrete wall; 3-hour rated with 3-hour rated penetration seals.
(col'Am Line-17)
West Bounded by (a) 42" concrete steam tunnel shield wall.
Three hour rating is not required because the Steac tunnel is not a redundant area.
(b) 60" concrete drywell shield wall.
(c) The unenclosed portion of the boundary is shared with fire sones 1.10 at column line 11.
(
2.
Floor 24" concrete slab, three hour fire rated with three hour rated penetration asals with the exception of opgn stairvells to fire sone 1.3 and 1.1.
These twe fire zones are not redundant to fire sone 1.9.
1 j
3.
Ceiling 12" concrete slab; three hout rated with three hour rated penetration seals with the esteption of an epen
{
stairwell to fire some 1.11 which is not a redundant area to fire sone 1.9.
I 4.
Ceiling height 27 feet.
5.
Area volume i
Approximately 220.000 cubic feet.
l l
6.
Ventilation See Figure #1 for directional arrows showing ventilation flow.
7.
Congestion Area is essentially free of floor congestion.
Cuwral access for manual suppression is good, i
i (Page 1 of 7) i
3.
SAFE E TfDOWN SQUIPMENT After the proposed mod!facstions are taplemented for this fire zone, saly the "A" trois of systems required for safe shutdawn will remain
$a fire some 1.9.
All "B" train cables and camposants that are re-guired to be operable for safe shutdown will set be located in this fire sons..
For a fire in fire some 1.9. all "A" train components are assumed lost.'
and safe shutdown will be accomplished with the "B" train of systess.
The opposite is true for fire some 1.10 where all "B" train camponents are assumed lost. and safe shutdown will be accomplished with the "A" train of systems. Figure #1 shows the camponents and cables located in fire sone 1.9 that are required to be operable for a fire in fire some 1.10.
Listed below are the systems that will.be used for safe shut-down if a fire occurs in fire sone 1.10.. De components or cables ere listed. if they appear in fire sone 1.9. - Figure #1 shows the locatier.
of the components and/or cables that are listed.
COMPONENTS / CABLES LOCATED IN "A" TRAIN i
SYSTEMS FIRE EONE 1.9.
Automatic Alternate shutdown panel and control Depressurization cables.
(
System Core Sprey System MCC 317 which feeds power to cere spray valves. Alternate shutdown panel ior core spray.. Power sad control cables for the core spray system.
j RRR System in tho' MCC 318 and 320 which feeds power to the shutdown cooling mode.
RER valves. Alternate shutdown panel for RMR. Power and' control cables ' for RMF.
system.
Ra water level sad Rx Rose pressure l
TorustempErature lastrament cables for torus temperature.
Torna water level.
Instrument cables for torus water: level.
C.
CCBIBUSTISLES Dis item provides the technical justification for seasidering the space betwe,en Fire Zones 1.9 and 1.10 " free 'ef fixed combustible-material."
(Pase 2 of.7).
o i
I The 20 feet separation space between rsdundant safe shutdown equipment ($$t) contain six (6) horisontal cable trays.
Figure #1). The separation some is described below (see Separation Quantity Continuity Area of Equivalent Fire i
Esar Combustibles of Separatica Theoretical Retardant Between Total Combustibles Esse Fire Erposure protectiot 3
Redundant 1bs/ft -1bs.
Through sq. ft.
Minutes Type
, Est separation
~
Kone Reacter Building 19.9 333 Yes 900 0.4 IEEE 3E3-3 trays Elev. 23 f t.
non ITEI 323 Cable Coated Between with fire colunas Retardant 3 tray 9.1 to 11 Material and M.7 to P
(
The theoretica1I equivalent fire esposure of the. cable within this Separation Zone is only 0.4 minutes. This is extremely low.
l Realistica11y. the combination of fira retardant coating or the inherent fire retardant properties of IEEE 383 qualified cable and
}
the large physical wparation between the trays will prevent a fire
. that originates within one of these trays from generating sufficient i
heat to propagate a fire across the six trays in the prospective j
Separation Ecoe. An intense or large esposure fire might be able to propagate a fire across the prospective Separattom Ecos.
Bowever.
l there are no other lastalled combustible materials in the sone to provide the exposure fire.
Moreover. Administrative Controls were designed to limit transient combustible material on Elev. 23 feet of the Reactor Building to a j
maximas of 10 gallons of Cgass 11 and III liquids (i.e each) and one gallon of Class 1 liquids. Combustible loading,of this magnitude, or even several orders of ma'anitude larger, will not totally fill the 20 foot wide Separation Zone. Additionally since the cable trays i
are 11 feet above the floor, the transient Icads will mot be able to impinge on the entire length of the tray.
1 1 See Appendix A for a more detailed description of the theoretical and realistic analysis methods.
{
2 Timmsable/ combustible liquids are required to be in approvsd container i
Page 3 of 7 I
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REco concludes that neither the limited installed combustible materials or potential' transient materials would proposste a fire across the 20 foot fire $2paration Zone. This some can be considered
" free of intervening combustibles as required La section IIIC.2 (b).
C.2 This item provides the technical justification for the proposed fire protection modifications.
The combustible materials installed in Tire Tone 1.9 and 1.10 are primarily cable insulation. The fire loading and ths. theoretical fire exposure are described in the table 2 below:
Tire Quantity of Continuity of Equivalent!
Tire Retardant Zone Combustibles Combustibles Theoretical Protection Type-Weight through Tire Exposure Type Tire Zone Minute s No. 1.9 Cable -16,731 No 29.5 1EEE 383 70%
Raaetor Building Elev. 23 ft.
Non1EEE 30 *.
i East Col.
383 Cable No. 11 Coated with Tire Retar-dant Material No. 1.10 Cable -10,078 No 22.8 IEEE 383 70:
Essetor Trainsient Cable Suilding Combustible -
Elev. 23 ft.
1036 West of Col.
Non1EEE'383 30:
No. 11 Cable Coated with Fire 3
Retardant Material There are two approaches to analyse fire spread potentials. The
" theoretical"I method mathematically comparea specific plant fire loads to a Standerd Time-Temperature fire. The "raalistic" I method evaluates the physical array of specific combustibles and the possibility of fire propagation within the array.
TEFOt2TICAL AMAlf ESS 38Ce used the theoretical approach to identify the Standard Fire E.:posure for comparison purpcses and general understanding of the
' order of magnitude of the worst case fire in this area. Any fires with a Standard espsvre under 30 minutes are in the lowest severity category. tire Ecne 1.9 end 1.10 have Standard Tire Imposures 29.5 and 22.8 minutee respectively.
(Page 4 of 7)
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BEco believes that any further use of the theoretical approach is unwarranted since this method is heavily depended on defining _a Design Basis Fire (DBF),
and the correlation between a DBF and real fire has not been utisfactorily established. More importantly, BECo postulates this is unnecessary because the realistic approach is adequate to obtain an appropriate level of fire protection.
REALISTIC ANALYSIS The realistic approach identifies that there are two potential paths t'or fire spread between zones 1.9 and 1.10.
First, the fire could spread horizontally
'1' across the floor. Secondly, the fire could spread to a higher or lower elevation (e.g. 23 ft., 74 or 91) through a vertical opening and then back to the 23 ft. elevation through another vertical opening.
These paths have been i
utilized in the completion of the realistic analysis below.
Conductive heat transfer and direct flame impingement are not possible across these paths since there is no continuity combustible materials in any of these paths (e.g. vertical or horizontal).
Radiant heat transfer can only be a factor in fire spread when there is a straight, unobstructed, i.e., "line of sight," path between the fire and the exposed material.
There is either a floor or the Primary Containment between the combustible materials in fire zones 1.9 and 1.10. This eliminates the "line of sight" and will realistically prevent fire spread by radiant energy transfer.
I Convective heat transfer is the one method of fire spread that is remotely realistic for Pilgrim Station.
If a fire in the fire zone 1.9 (or 1.10) produced enough heat to raise the ambient air temperature on the entire 23 foot elevation to the auto-ignition point of cable insulation, the fire could spread from fire zone 1.9 to 1.10.
BEco has conservatively assumed that there is a sufficient fire exposure in zone 1.9 (or 1.10). to accomplish the required ambient temperature. BEco has proposed to prevent the horizontal migration of the ambicist temperature profile by installing two branchlines on a wet pipe sprinkist system over the 20 ft. Separation Zones (See Item C.1) between fire zone 1.9 and 1.10.
This is the only protective system necessary.
BECo has not proposed any protection for the vertical openings in the Reactor Building floors. This is not necessary since convective heat transfer cannot occur downward untti the entire volume at the higher elevation (s) has been heated. Hence, the exposure fire in the fire zone 1.9 (or 1.10) would have to heat the ambient atmosphere in the Reactor Building from 51'ft. to 134 ft. to the " higher" ambient temperature before it would migrate back down into fire zone 1.9 (1.10).
The fire loads on elevation 51 ft. (or any higher elevation in the Reactor Building ) are not capable of producing a fire of this magnitude. Therefore, this is not realistic and special protection is not necessary for vertical penetration /(e.g. stairs or hatch).
l (Page 5 of 7)
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1.
See Appcodia A for a more detailed description of the theoretical and realistic analysis methods.
2.
Reprinted from Table 1-1. Fire Protection System' Review APCSB 9.5-1.
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3.
The equivalent Theoretical Fire Exposure for the Reactor Building elevations 74 ft. (fire some 1.14). 91 ft. (Fire Zone 1.16) and 117'ft. (Fire Zone 1.24) are 11.1.5. 7.8 and 12 minutes respect-ively.
See Table 1-1' free BEco Fire Protection Systes Review APCES 9.5-1.
D.
FIRE PROTECTION EKISTING 1.
Fire Detection systems: 32 Photoelectric smoke detectors 11 fonization smoke detectors 2.
Fire extinguishing systems: None 3.
Rose stations / extinguishers: 2 hose reels 1 portable extinguisher 4.
Radiant heat shield: None f
5.
Propagation retardants:
Cables are coared with flamezas:ic or qualified to IEEE-383.
E.
PROPOSED MODIFICATIONS 4
Modification proposed for fire some 1.9 will insure that one train of safe shutdown equipment will remain free of fire damage for any postulated fire in the area.
The proposed modifications are of two types and together provide a defense in depth concept ferr fire protection as intended by the requirements of Section 111C cf j
Appendix 1.
The first type of modification involves relocating. from fire zone 1.9. cables and equipment for the "B" train of systems required for safe shutdown. After these modifications are complete, fire sone 1.9 vill only contain cables and components for the "A" train of
)
systema required for safe shutdown. Soem "B" train cables will re-sain in the fire zone. however, the loss of these cables is acceptable since operator action will provide the same functies that the cable provided. The "B" train cables will be relocated from fire some 1.9 by rerouting them in a ductline around the outside Mrimeter of i
the plant that leaves the control building and enters ti.ine fire sone containing the components for the "B" train of systems required for shutdown. This ductline is being added as part of the modifications to meet the requirements of Appendix R.
One component for the "B" tr.:.in of systems le currently located in firs some 1.9 and will be relocated to the area where the "B" train components are located.
(Page 6 of 7)
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N escend type of modificatico. involves pr widing sprinkler 1
protectica la the boundary area that separates fire some 1.9 fras
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its redustant counterpart, fire some 1.10.. has two' fire zones are j esparated by a three hour boundary along their casson border except.
for an area epproxiastely 30 feet long on the north side of the area.
N sprinkler protection is provided to prwent a firm from propagating; across the boundary area between redundant fire sones.
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(page 7 of 7)
b TABLE 7.2 FIRE 20NE 1.10: REACTOR SUILDING ELEVATION 23'-0". WEST SIDE
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AREA DATA A.
AREA CONSTRUCTION 1.
Wells - See Figure il North - 27" concrete wall, plus 6" pre-cast concrete panel; 3-hour rated, with 3-hour penetration seals. _ (column Line-?)
South - 42" concrete wall; 3-hour rated with 3-hour rated penetration skals (column Line-R)
West 33" concrete wall; 3-hour rated with 3-hour rated penetration seals (column Line-5)
East Partial enclosure; bounded by 42" concrete steam tunnel shield wall (column Line-10), 60" (circum-ferential. column Lina-10 to column Line-11) both 3-hour rated walls. The unenclosed portion of the boundary is shared with fire zone 1.9 at column Line-11.
2.
T1oor - 24" concrete slab; 3-hour rated with 3-hour rated penetration seals with the exception of open stairvells I
to fire a:nes 1.7 and 1.2 which are not redundant areas to fire zone 1.10.
3.
Ceiling - 12" concrete slab; 3-hour rated with 3-hour rated penetration seals with the exception of an open stairvell, and hatchway to fire zone 1.12 which is not a redundant area to fire zone 1.10.
4.
Ceiling Height 22 feet 5.
Area Volume Approximately 195.500 cubic feett.
6.
Ventilation See Figure il for directional arrows showing f
ventilation flow.
l 7.
Congestion Area is essentially free of floor congestion.
General access for manual suppreruton is good.
l 1
8.
SAFE,53UTDOWN EQUIPMENT j
1.
After the proposed modifications are implemented for this fire zone.
only the "B" train of systems required for safe shutdown will remain in fire zone 1.10. ALL "A" train cables and couponents that are l
~
required to be operable for safe shutdown will act be located in this -
i fire mone.
-l (Page 1 cf 3) i
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i For a fire in fire sone 1.10, all "B" train composants are f
eeeuned lost, and safe shutdown will be' accomplished with i
the "A" trein of systate. The opposite is true for fire some 1.9 where all "A" train components are assumed
- lost, and safe shutdown will be accesplished with the 3 " train of systems. Figure il shows the components and cables located in fire some 1.10 that are required to be operable.
j for a fire in fire sone 1.9.
1
. Listed below are the systems that will be used for safe uhutdown if a fire occurs in fire sone 1.9.
The components or cables are listed if they appear in fire some 1.10.-
Figure #1 ehows the location of the come ponents and/or cables that are listed.
"S" TRAIN COMPONENTS / CABLES LOCATED 1N SYSTEMS FIRE ZONE 1.10 Automatic Alternate shutdown panel and control Depressurinstion cables. MCC D8 which feeds power to the Systen ADS system.
Core spray systen I
MCC BIS which feeds power to core spray valves. Alternate shutdown panel for core spray. Power end control cables g
for core spray system.
BJR system in the MCC 318 which feeds power to RNR shutdown cooling mode valves.
Alternate shotd:'wn panel fer RER.
Power and control cables for RNR systet.
Ra water level and None Ra pressure i
Torus temperature Alternate shutdown panel for mor.itoring torus temperature.
Torus we er LYL Alternate shutdown panel for monitoring torus water level.
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C.
COMBUSTIBLES See Section (c) of Table 7.1 t
\\
D.
FIRE PROTICTION EXISTING 1.
Fire detection ef. L~ss: 37 Aotoelectric.amoke detectors 7 Irmisation smoke detectors 2.
Fire extinguishing systems: Fame
'3.
Rose stations / extinguishers: 2 Bose Reels 1 portable Extinguisher i
4.
Radiant heat shield:
None 5.
Propagation retardants: Cables are coated with fla
- as:::
or qualified to.1EEE-383.
l E.
PROPOSED MODIFICATIONS I
Modification proposed for fire zone 1.10 will insure that one train of safe shutdown equipment will remain free of fire g
damage for any postulated' fire in the area. The proposed.
modifications are of two types and together provide a defense in depth concept for fire protection as intended by the rec;uire-ments c.f Section III C of Appendia R.
The first type of modificatt.vn involves relecating, from fire some 1.10, cables and equipment for the "A" train of systems required for safe shutdown. After these modifications-are complete, fire some 1.10 will only cantain cables and components for the "B" train of oystems required for aafe shutdown. Some "A" train cables will rar,ain in the fire some, bewever, the loss of these cables is acceptable ainee operator action will provide the same function that ne cable provided. The "A". train cables will be relocated free' fire some 1.10 by rerouting them in a.
ductline around the outside perimeter of the plant that leaves the control building'and omters the fire zone containing the couposamts for the "A* train of oystems required for~ahutdown.
This ductline is being added as part of the modifications to meet tho' requirements of Appendix R.
The second type of modification involves providing oprinkler protectico la the besundary area that esparates fire sone l.10 from its redundant counter part. fire same 1.9.. These two fire saaes are seynrated by a three hour boup4ary along their cammon' border escept for as area approximately 30 feet long oc the morth side of the area. The oprinkler protection is previded to prevent a fire frun propagating across the ' boundary area between redundant, fire sones.
(page 3 of 3) j
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TABLE 8.1 FIRI 20ert 1.11: REACTOR SUILDING ELEVATION 51'-0", EAST SIDE AREA DATA A.
AREA CGtSTRUCTIODI 1.
Walls - See Figure #2 North - 24" concrete well, plus 6" pre-cast concrete panel; 3-hour rated with 3-hour penetration seals.
(column Line-p)
South - 21" concrete wall, ~plus 6" pre-cast concrete panel; 3-hour rated with 3-hour penetration seals.
(column Line-J)
East
- 30" concrete well. plus 6" pre-cast concrete panel; 3-hour rated with "r hour penetration seals.
(column Line-17)
West - partial en:Ic sure bour.ded by the 60"' concrete 5
drywell shield wall (cirenferential); 3-hour rated with 3-hour penetration seals. The unenclosed portien of the boundary is aihared with fire zone 1.12 at colon Line-11.
f 2.
Floor - 12" concrete slab; 3-hour rated with 3-hour rated penetratica seals with the exception of an open stairwell te fire sone -1.9 which is not a redundsut area to fire sone 1.11.
3.
Ceiling - 12" concrete' slab; 3-Mur rated with 3-hour rated penetration seals with the exception of an open stairwell to fire sone 1.14 which does not contain equipment required for safe shutdown.
4.
Ceiling height - 21'-0" 5.
Ares volme - Approximstaly 135.950 cubic feet.
6.
Ventilation - See figure #2 for directional arrows showing vent,ilation flow.
V.
Congestion - Area is essentially free of. floor congestion.
General access for manual suppression is good.
5.
5AFE SWUTDonal EQUIpNIET U.11)
~
1.
After the proposed modifications are implemented for this fire sone, only the "A" train of systes required 'for safe shutdown will remain in fire some 1.11. All "B" train cables (Fase 1 of 7)
k and components that are required to be operable for safe obutdown will act be located la this fire some.
For a fire in fire some 'I.11. all "A" train components are acamed lost, and safe shutdown will be accesplished with the "A" train of systems.
The opposite is true for fire end safe shutdown will be accomplished with the 'A "B" train components are asemed last, of systana.
Yigure #2 shows the components and cables located in fire some 3.11 that are required to be operable for a fire to fire some 1.12.
that will be used for safe shutdown if a fire occurs inListed below are fire some 1.17t.
and/or cables that are listed. Figure #2 shows the location of the compone A" N CCMPONENT5/ Call.ES LOCATTD SYSTEMS IN TIRE ZONE 1.11 Autonstic Depreseurisation MONE system RMR systen in the LPCI and Valve MO-1001-26A & Cables shutdown cooling Valve MO-1001-23A & Cables mode i
Instruments for RX veter level and Ax vessel Instrument Rack C2205 and Cables.
1 pressure s
4 1
/
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(Page 2 of 7)
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- c. CasusT1st.Es C.1 This item providas the technical justification for considering 1
the space between fire sones 1.11 and 1.12 " free of fixed com-bustible material".
The 20 ft. separation space on the north side of the Reactor Building between redundant Safe Shutdown Equipment (SSE) contain five (5) borisontal cable trays and the south. side contain three (see Figure #2). The separation zones are described below:
s Continuity Separation of Zone Quantity Combus tible Area of Equivalent Between Combus tible Through Separation Theoretical Redundant Total Separation Zone Fire Exposure Fire Retardant-3
$$E lbs/f t -lbs.
Zone sq. ft.
Minutes Prete: tion Rsactor 16.3 - 326 Tes 1.140 1.6 IEEE 32 3 - 2 trays Building Northside non-1EEE 363
- Elev. 51 ft.
Cable coated
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with Tire Betwe en Retardant - 3 trays
[
columns Material.
9.1 to 11 and M.7 to P Reactor 6.6 - 133 Tas 260 2.0 IEEE 383 '- 2 trays Building Cable Southside
- El ev. 51. f t.
~
mon-IEEE 383 Cable Coated
- Between vita Fire solumna.
Retardant - 1 tray.
10-13 and Material J to E F
(Page 3 of 7)
m The theoroticc13 equivalent fire exposure of the esble with this.
S::p:rction Zo:>s is enly 1.6 to 2.0 cinutcs. This is extraaely
~
low. Realistically 1 the combination of fire retardant coating or the taherent fire retardant properties of IEEE 383 qualified cable and the physical separation between the trays will prevent a fire that originates within one of these trays frea sufficient heat to propagate a fire across the other.. generating trays in the respective Separation tone. An intense or large esposure fire might be able to propasste a fire across the respective i
Separation Zone. 51 wever, there are no other installed
]
combustible materials in either zone to provide the esposure fire.
i Moreover. Administrative Controls were designed to limit transient combustible material-on Elev. 51 f t. of the Reactor Building to a maataus of 10 gallons of Class II and III.
Liquids (i.e. each) and one_sallon of Class.1 Liquids,
2 Combustible loading of this magnitude, or even several orders
)
of magattudtlarger, will not totally fill the 20 f t. wide l
Separation Zone. Addhionally, since the cable trays are
!! ft. above the f.toor, the transient loads will not be able i
to impinge on the entire length of the tray.
3Eco concludes that neither the limited installed combustible materials or potential transient estarials would propagate a, fire across either the north or south' 20 f t. fire Separation..
Zone an elevation of 51 ft.
These zones can be considered
" free of intervening combustibles as required in Section III C.2 (b).
C.2
,f This item provides the technical justifie.ation for the proposed fire protection modifications.
The combustible asterials installed in fire sone 1.11 and 1.12 are primarily' cable insulation. The fire loading and the theoretical fire exposure are described in-the table 2 below:
Continuity of Combustibles Equivalent Quantity of threush Theoretical Fire Retardant o
Fire Combustibles Fire Fire Exposure
-Proteetion Ione' Type - Waight Zone Minutes Type 1
No. 1.12 Cable =IS70 No 7.8 IEEE 383 701' itaatter Transiest Cable Building Combus tibles-Elev. 51 ft.
130 asa-IEEE 301 wast Col.
383 Cable No. 11 Caste' with d
Fire Retardant mar.orial t
1 See Appendia A for a more detailed description of the theoretical and realistic analysis methods.
2 Flammable / combustible liquids are required to be in approved containers.
Page 4 of 7 A-
,y Continuity of
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Combustibles Equivalent Qusatity of through Theoretical Fire Retardant Fire Combustibles Fire Fire Exposure
.Protoction Zone Type - Weight Zone Minutes Type y,,
Co. 1.11 cable-3065 No 11 IEEL 383 Reac tar yor Cable Suilding 'st.
Elev. 51.
Fast of Col.
non-IEEE 383
'30%
No.11, Cable coated with Fire Retardant asterial There are two approaches to analyse fire spread potentials. The
" theoretical" method mathematically compares specific plant fire loads to a Standard Time-Temperature fire. The " realistic"I method. evaluetes the physical array of specific combustibles and the possibility of fire propagation within the array.
THEORETICAL ANALYSIS BECo used the theoretical approach to identify the Standard Fire Exposure for comparison purposes and general understanding on the " order of magnitude of the worst case fire in' this area.
4 Any fires with a Standerd exposure under 30 minutes are in the lowest severity category. Fire sone 1.11 and 1.12 have Standard Fire Exposures 11 and 8 minutes respectively."
BEco believes that any further use of ~ the theoretical approach is unwarranted since this method is heavily depended on defining a Design Basis Fire (DSF), and the correlation between a DSF and real fire has not been satisfactorily established. More importantly BEco postulates this is unnecessary because the realistic approach is adequate to obtain an appropriate ' level of fire protection.
REA1.ISTIC ANA1.YS15 d
The realistic approach identifies that there are two potential paths for fire spread between Zones 3.11 and 1.12.
First, the fire could spread horizontally across the floor. Secondly, the fire could spread to a higher or lower elevation (e.g. 23 f t.,
74 or 91) through a vertical opening and then back to the 51 f t. elevation through another vertieel opentag. These i
paths have been utilised in the completion of the realistic
{
analysis below.
Conductive heat transfer and direct flame impingement.are act possible across these paths since there is se continuity combustible materials in any of these paths (e.g. vertical or horisontal).
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(Fase 5 of 7)
-_x x_-__ _-
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Radiant heat transfer can only be a factor in fire spread when there is straight, unobstructed, t.e. "line of sight," path between the fire and the exposed material.
There is either a floor or the Primary Containment between the combustible materials in Fire Zones 1.11 and 1.12.
This eliminates the "line of sight" and will realistically prevent fire spread by radiant energy transfer.
- Convective heat transfer is the one method of fire spread that is remotely realistic for Pilgrim Station.
If a fire in the Fire Zone 1.11 (or 1.12) producted enough heat to raise the ambient air temperature on the entire 51 ft. elevation to the auto ignition point of cable insulation, the fire could spread from Fire Zone 1.12 to 1.11.
BEco has conservatively assumed that there is a sufficient fire exposure in Zone 1.11 (or 1.12) to accomplish the required ambient temperature.
BECo has proposed to prevent the horizontal migration of the ambient temperature profile by installing two branchlines on a wet pipe sprinkler system within the 20 ft.
Separation Zones (See Item C.1) between Fire Zone 1.11 and 1.12 This is the only protective system necessary.
BECo has not proposed any protection for the vertical openings in the Reactor Building floors. This is not necessary since convective heat transfer cannot occur downward until the entire volume at the higher elevation (s) has been heated.
Hence, the exposure fire in Fire Zone 1.11 (or 1.12) would % ve to heat the ambient atmosphere in the Reactor Building from 74 ft. to 134 ft. to the " higher" ambient temperature before it would migrate back down into Fire Zone 1.12 (or 1.11).
The fire loads on elevation 51 ft. (or on any higher elevation in the Reactor Building) are not capable of producing a fire of this magnitude.
Therefore, this 13 not realistic and special protection is not necessary for vertical penetrations (e.g. stairs or hatch.
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See Appendix A for a more detailed description of the theoretical and l
)
realistic analysis methods.
2 Reprinted from Table I-1, Fire Protection System Review APCSB 9.5-1.
- The equivalent Theoretical Fire Exposure for the Reactor Building elevations 74 ft.
(Fire Zone 1.14), 91 ft. (Fire Zone 1.16) and 117 ft. (Fire Zone 1.24) are 1.8, 7.8 and 12 minutes respectively.
See Table I-1 from BECo Fire Protection System Review APCSB9.5-1.
t (Page 6 of 7)
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D.
FIRE PROTECTI W IIISTING i
1.
Fire Detection Systems:, 14 Photoelectric Smoke Detectors i
3 fonisation smoke Detectors -
2.
Fire Extinguishing Systems: None 3.
Rose Stations / Extinguishers:
1 Bose Reel 2 Portable Extinguishers 4
Radiant Esat Shield: None j
5.
Propagation Rstardants: Cab 2es are coated with flamemastic or qualified to IEEE-383.
E.
PROPOSED MODIFICATIONS Modifications proposed for fire zone 3.11 will insure that one train of safe shutdown equipment will remain free of fire damage for any postulated fire in the area.
The proposed modifications are of two types and together provide a defense in depth concept for fire protection as intended by the requirements of section 111G of Appendix R.
I The first type of modification involves relocating from fire zone 1.11 cables for the "B" train of systems required fot safe shutdown.
After these modifications are complete, fire sone 1.!! rJ11 only contain cables and components for the "A" train of systems roquired.for safe shutdown.
A few "S" train cables will renais in the fire sone, however, the loss of these cables is acceptablu since operator action will provide the same function that the cable provided. The "B" train cables will be relocated free fire some 1.11 by rerouting ther.
in a ductline tround the outside perimeter of the Plant that leaves j
the Control Building and enters the fire some containing the components for the "B" train of systems required fer shutdown.
This ductline is being added as part of the modifications to meet the requirements of Appendix R.
The second type of modification involves providing sprinkler protection in the boundary area that separates fire sone 11.11 free ite redundant counterpart, fire sone 1.12 as shown on Figure #2.
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(Page 7 of 7) i 1
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TABLE 8.2 FIRE ZONE 1.12: REACTOR SU1121NC ELEVATION 51'-0", WEST SIDE AREA DATA A.
ARIA CONSTRUCTION 1.
Walls - See Figure #2 North - 24" concrete wall, plus 6" pre-cast concrete panel; 3-hour rated with 3-hour penetration seals.
(column Line-P) i South - 21" concrete wall. plus 6" pre-cast concrete panel; j
3-hour rated with 3-hour penetration seals.
(column Line-J) i East - Partial enclosure bounded by the 60" concrete drywell shield wall; (circusferential) 3-hour rated with 3-hour penetration seals. The unenclosed portion of the boundary is shared with fire zone
)
1.11 at column Line-11.
l j
West - Filled masonary block wall 12" thick.
(at j
column Line-7, bounded by column Line P & K) 1 24" concrete wall, plus 6" pre-cast concrete panel.
(
(at column Line-5, bounded by' column Lines-J &E) 3-hour rated with 3-hour roted penetration seals.
2.
Floor - 12" concrete slab; 3-hour rated with bhour rated
{
penetration seals with the exceptien of an open stairwell and hatchwsy to fire sone 1.10 which is not a redundant area to fire sone 3.12.
)
3.
Ceiling - 12" concrete slab; Fhour rated with 3-hour rated penetration seals with the exception of an ooen stairvell and hatchway to the 74'-0" elevation which does not contain equipment required for aafe shutdown.
i 4
Ceiling beight - 22'-3" (aazimus) 5.
Area volume - Approximately 87,840 cubic feet.
6.
Ventilation - See Figure #2 for directional arrows showing I
ventilation flow.
7.
Congestion - Ares is essentially free of floor esagestion.
General access for manual suppression is good.
1 (Page' 1 of 3) i
F 5.
SATE $NUTDOWN EQU1FMDff Aftet the proposed modifiestions are impleented for this fire
(.
down will resin in fire cone 1.12. ' All "A" train caldes anne, only the "B" train of systems required for safe shut--
1 and components that are required to be operable for safe shutdown will act be located in this fire some.
~
For a fire in fire some' 1.12 all "B" train' conFonsats are-assmed lost, and safe shutdown will be accomplished with the "A" train of systems. The opposite is true for fire some 1.11 where all "A" train components are assmed lost, and safe shutdown will be accomplished with the "B" train of systems. Figure #2 shows the components and cables located in fire sone 1.12 that are required to be operable for a fire in fire sone 1.11.
Listed below are the systems that will be used for safe shutdown if a fire occurs in fire sone 1.11.
The components or cables are listed-if they appear in fire sone 1.12.
Figure #2 shows the location of the components and/or esbles that are listed.
1 "B" TRAIN CCMPONENTS/ CABLES LOCATED SYSTEMS IN FIRE ZONE 1.12 k
Automatic Depressurisa tion MONE i
System t
-I RNR system in the LpC1 and NONE shutdown cooling mode l
4 Instruments for j
Ex water level Instruent Rack C2206 A & 3 and cables and ta vessel pressure C.
CCBSUSTIBLES 4
See section (c) of Table 8.1.
3.
FIRE PROTECTItal EXISTING j
j 3.
Fire Detection Systema :
10 Photoelectric Smoke Detectors 3 Ioniastion Smoke Detectors 2.
Fire Eatiaguishing Systma: Rome 3.
Rose Stations / Extinguishers: 2 Rose Reals 2 Portable Extinguishers j
Page 2 of 3
4.
Radiant 5est Shicid: None
(
5.
Propagation Retardants: Cables are coated with flammastic or qualified to IEEE-383.
E.
FROPOSED MODIFICATIONS 1
Modifications proposed for fire sone 1.12 will insure that one train of safe shutdown equipment will remain free of fire damage for any postulated fire in the area. The proposed modifications -
are of r.vo types and together provide a defense in depth concept for fire protection as intended by the requirements of section IIIC'of Appendix R.
He first type of modification involves rerouting cables that are for shutdown components in fire sone 1.12.
Fire sone 1.12 contain components for the "B" train of systass required for safe shutdown.
The cables will be rerouted from fire sones that contain components for the "A" train of systass required for safe shutdown.
The cables will be rerouted by a duct line that leaves the Control Building and enters the fire sone containing the components for the "B" train of systee,s required for shutdown. This duct line is being added as part of the modifications to meet the requirements of Appendix R.
I The second type of modification involves providing sprinkler-l protection. as shown on Figure #2. in the boundary area that separates fire sone 1.12 f rom its redundant counterpart, fire sone 1.11.
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AFPINDIX A l
Tg10RETICAL AND REALISTIC TIRE AMA1.Y515 m re are two approaches to analyze fire and its development - the " theoretical" and " realistic" methods.
l The theoretical methods models the t.hemistry and physics of fire. This method manifests itself through laboratory testing and identifies standard or minimum developmental parameters for fire. These parameters are useful for comparison purposes and selection of materials, components or plant configurations during design. For example. the theoretical method converts all combustible material within a specific volume of the plant to its " equivalent" calorimetric heating value. The heat loads are totaled for all materials in that plant volume.
Finally, the theoretical method assumes all the heat is released in a duration i
of tine equivalent to the Standard ASTN E-119 Fire Test. The resultant is a theoretical maximum equivalent Standard Fire Severity.
(The Tables in the esemption requests illustrate that the Standard 'f re Severity is extremely low for each of the applicable fire sones. This analogy defines a specific air temperature profile over a standard time duration. This is very conservative because it does not consider the differences in the rate of combustion of the various materials.
Bowever, by comparing these factors for specific materials, as order of magnitude on fire severities can be estimated. The langer the
" equivalent standard fire" the higher the espected severity for that combustible load.
This information is also used in the realistic method where equivalent fire sevarity is used to detetuine the required fire resistance rating of building materials.
The vaalistic method evaluates the actual physical configuration between essbestible material. mon-combustible materials and building construction while applying the guidance sained from the theoretical metised.
(Page 1 of 1)
1 k
in this method, the experience obtained from plant inspection and fire investigation tamper the theoretical predictions and estimates. T'he basic i
thermodyn mics for fire development and spread from the foundatidh for the realistic approach.
Fire can spread by one of the mechanisms.
They are:
1.
Conductive heat transfer 2.
Radiant heat energy transfer 3.
Convective heat transfer j
Realistically, combustible materials ignite only after they absorb a specific l
amount of heat energy. The required amargy can be transferred from the burning material to the adjacent material directly, i.e. items 1 and 2. or fadirectly (e.g. burning material to air to adjacent asterial) i.e. item 3.
Fire spread involving direct contact is much faster than through the convective process. From this simple knowledge. the realistic method makes an even simpler.
conservative presumption. When combustible asterials are present. and their physical configuration appear conducive to one of the heat transfer mechanisms, 4
same fire prevention or extinguishment must be provided.
Both methods hcvs many limitations as fire protection is an amargias science with many answers yet to be reached. Bowever proper applicatica of these methods will lead to solid treatment and protection for fire risk. BEco has and will continue to update their application of these methods to provide the highest level of fire protection for life safety and property conservation.
l (Page 2 of 2) i
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