TXX-6728, Forwards Revised Deviations to Branch Technical Position Apcsb 9.5-1,App a & 10CFR50 App R.Dispositions Listed for Plant Fire Areas Where Strict Compliance Not Achieved & Basis for Noncompliance Not Submitted to NRC or in FSAR
| ML20235Q614 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/02/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6728, NUDOCS 8710070640 | |
| Download: ML20235Q614 (83) | |
Text
.
. N-l
""lllll" ':lllllll" Log # TXX-6728 File # 909.5 E
E 10010 clo.
1UELECTRIC wmmm c. counsa October 2, 1987 Imutne We hvalent V. S. Nuclear Regulatory Commission 4
Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
J DOCKET NOS. 50-445 AND 50-446 1
TRANSMITTAL OF REVISED DEVIATIONS j
l Gentlemen:
Enclosed are copies of revised deviations to BTP APCSB 9.5-1 Appendix A and
)
10CFR50 Appendix R. provides a description of the changes made to the enclosed deviations.
The revised deviations to BTP APCSB 9.5-1 Appendix A and to 10CFR50 Appendix R l
supercede previously submitted deviations. These revised deviations have resulted from a comparison of Unit 1 and connon plant areas against the guidelines of 10CFR50 Appendix R and the requirements of BTP APCSB 9.5-1 Appendix A.
For plant fire areas where strict compliance was not achieved and l
a basis for the non-compliance was not submitted to the NRC nor contained in the FSAR, one of the following dispositions was implemented:
i l
- a modification was implemented,
- an engineering evaluation was performed justifying the non-compliance and placed on file, or
- a new deviation request was drafted providing a basis for the noncompliance.
These dispositions resulted in two additional non-compliances.
One was provided in deviation number 4a-1.
The other will be provided in an upcoming FSAR amendment.
The comparison also identified 52 existing deviations no longer required due to one or more of the following:
- The Fire Safe Shutdown Analysis revision has obviated the need for deviations.
- Upgrading the suppression systems has established compliance with NFPA code requirements and obviated the need for deviations.
(
8710070640 071002 PDR ADDCK 05000445 l
F PDR
\\ \\
i i
MM North Olac Street LII81 skilas, Tcuss 7$201 I
TXX-6728 l
October 2,1987 Page 2 of 2
- The fire hazards analysis evaluations as permitted by generic letter 86-10 has demonstrated the adequacy of fire suppression systems.
- The replacement of fire dampers with qualified damper assemblies has obviated the need for deviations. to this letter lists each deviation being deleted and the reason for deletion.
Where updates were necessary, some general changes to the existing deviations were implemented as follows:
Editorial:
Interactions were changed to deviations.
For consistency the term
" Deviation" has been used throughout as a title for each noncompliance justification.
Deviations are then broken into two categorins, deviations to 10CFR50 Appendix R and exceptions to BTP APCSB 9.G-1 Appendix A.
For the purpose of clarification, non-compliances to the requirements of Appendix A are distinguished q
from non-compliances to the guidance of Appendix R by the terms
" exceptions" and " deviations", respectively.
The technical content is not affected.
I l
Revision:
Since the original deviations were submitted, a revised method of addressing combustible (fire) loading has been implemented.
The revised method utilizes maximum permissible fire loading (MPFL) in conjunction with in-situ combustibles to establish margins for the addition of transient and in-situ combustibles. MPFL represents the maximum fire loading (BTV/sq ft) which can be expected to be contained within a fire area by the existing fire area boundaries without compromising safe shutdown capability.
Previous combustible loading values represented limits for combustibles both transient and in-situ based on anticipated usage.
Correction: Technical justifications have been deleted, changed to deviations or retained as necessary.
Very truly yours, j
W. G. Counsil JOS/gj Attachments Enclosure c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)
'l
_--__--__m
i to TXX-6728-I October 2, 1987 Page 1 Of 19 1
Deviation No./
Page No.
Change Description l
la/1 Clarification:
Adds the fire area designation WB to the location section.
This addition is made in order to provide a more complete description of the room under discussion. This addition does not have any technical impact upon the deviation.
la/1 Clarification: Adds ".b" to the deviation section. This addition is made to specify the section from which the 1
deviation is requested.
l la/1 Addition / Update:
Adds service water' isolation valves, service water recirculation valves, branch circuits, exhaust fans, and branch circuit MCC's to the description section.
This addition is made to reflect additional safe shutdown equipment found to be necessary in Fire Area WB.-
la/1 Addition / Update:
Adds the MCC's associated with the Service Water pumps to the description section.
la/1 Clarification / Update:
Adds "The pumps are 12'-0" high while the MCC's are less than 12' high".
This clarification to the justifications is made to describe more clearly, the relationship between the pumps, MCC's, and the walls.
la/1 Clarification / Update:
Adds, " Ceiling level...for the j
area." This addition tr the justifications is made to i
provide further clarification of the type of protection l
provided for the area.
j la/1 Addition / Update:
Adds to Item 3 in the Justification,
" Transient hazards...taken".
This addition is made to provide consistency with the u) dated. combustible loading calculation and the new MPFL plilosophy.
la/2 Addition / Update:
Adds Item 4, 5, 6, 7 and 8 to the justification list.
This addition is made to provide justification for the separation issues added in the l
updated Fire Hazards Analysis and Fire Safe Shutdown j
l Analysis.
J l
la/3 Addition / Update:
Adds item 9 to the Justification list.
I This addition is made to provide justification for the f
separation issues added in the updated Fire Hazards l
Analysis and Fire Safe Shutdown Analysis.
~
l l
]
-_ _ __._ to TXX-6728 I
October 2, 1987 i
Page 2 Of 19 j
Deviation No./
Page No.
Change Description Ib/1 Clarification:
Adds the Fire Area designation AA to the location section and drawing.
These additions are made in I
order to provide a more complete description of the area under discussion.
Ib/1 Editorial:
Deletes drawings SF-TFHA-0713-01 and -0714.
l Adds drawing 2323-El-0714-11. These changes are made in order to delete obsolete drawings and to provide a drawing j
pertinent to the deviation.
lb/1 Clarification: Adds the specific section of III.G.2.b to the deviation section.
This addition clarifies the specific section of III.G.2 for which the deviation is requested.
Ib/1 Update: Changes "less than 30" to "of 11". This change to f
the justifications is made to incorporate the fire l
severities resulting from the new combustible loading calculation and to establish uniformity of fire severities in all deviation requests.
lb/1 Addition: Adds "The ntaximum permissible fire loading is 60 minutes." This addition'to the justifications is made to incorporate the results of the MPFL calculation.
Ib/1 Update: Changes "will be" to "have been". This change to the justifications is made to reflect as-built conditions.
Sketch 1.b Clarification:
Deletes, from Sketch 1.b, "The fire duration will be less than 30 minutes."
C-_______m_______m.__.___________________________
1 to TXX-6728 October 2,1987 i
Page 3 Of 19 l
i Deviation No./
Page No.
Change Description i
3a/1 Correction: Changes the elevation from "790'" to 810'-6""
room from "201" to "200"; and Fire Area from "30" to l
"AC29".
The room in question for this deviation should be room only, since it is the east wall of this room which is i
fire rated.
The southern tip of the barrier is located in i
room 201, but it is not fire rated.
This change in the location description is made to provide the specific location of the non-rated feature.
t 3a/1 Editorial:
Adds drawing FHA-15.
This addition is made in order to provide additional information pertf a nt to the deviation.
l 3a/1 Clarification: Changes the exception section to read:
"BTP APCSB 9.5-1 Appendix A, Section D.1.j".
This change revises the specific section for which the exception is requested.
3a/1 Clarification:
Changes "all areas." to " Fire Zone AA21b."
This change in the justifications is made in order to provide the Fire Zone adjacent to Fire Area AC which
{
provides hose station and fire extinguisher protection.
j 3a/1 Editorial:
Replaces "with a...per" with "as shown in".
This change in the justifications is made in order to i
direct the reader to attachel Table 3.a where the results i
of the combustible loading and MPFL calculations for the l
Fire Zones under discussion are tabulated.
l 3a/1 Clarification:
Deletes rows 1 and 3 in Table 3.a.
This deletion is made because the non-rated features are located in fire barriers which sepsrate Fire Zones belonging to the same fire area.
3a/1 Update / Addition:
Changes the durations of "< 30 min" to "16 min" and "< 60 min" to "35 min" for Fire Zones AC29 and AA21b, respectively.
Adds "MPFL 120 min" and "MPFL 60 min" for Fire Zones AC29 and AA21b, respectively.
These changes are made in order to incorporate the results of the combustible loading and MPFL calculations and to establish uniformity of fire severities in all deviation requests dealing with these fire zones.
4 L---
to TXX-6728 October 2, 1987 Page 4 Of 19 Deviation No./
Page No.
Chance. Description 3a-1/1 Editorial:
Reference to revisions of drawings are eliminated.
The documentation of correct drawing revisions can be obtained from other documents.
3a-1/1 Editorial: Adds drawing FHA-3 to the reference section.
This addition is made in order to provide additional information pertinent to the deviation.
4 3a-1/1 Clarification:
Changes the exception section to read:
"BTP APCSB 9.5-1 Appendix A, Section D.I.j".
This change revises the specific section for which the exception is requested, l
3a-1/1 Editorial: Adds fire area designation SA.
This addition is made in order to provide the specific fire zone of concern.
3a-1/1 Clarification:
Replaces " Train Path A" with "One of the l
redundant trains".
This change is made in order to conform to convention of not specifying the redundant train.
3a-1/1 Editorial: Adds fire area designation SB.
This addition is made in order to provide the specific fire zone of concern.
3a-1/1 Clarification:
Replaces " Train Path B" with "One of the redundant trains".
This change is made in order to conform to convention of not specifying the redundant train.
3a-1/2 Addition:
Adds the fire area designations SA and SB.
This addition is made to provide the specific fire zones of concern.
3a-1/2 Editorial: Changes " areas" to " Fire Zones of concern".
This change is made in order to provide a more specific i
i description of the locati.on.
3a-1/2 Update / Addition:
Replaces phrase in description, " Fire loading... areas." with "The fire severities in Fire Zones SA142, SB143 and SB144 are 17, 8 and 10 minutes, respectively.
The maximum permissible fire loading in all fire zones of concern is 60 minutes." These additions are made to incorporate the results of the combustible loading and MPFL calculations and to establish uniformity of fire severities in all deviation requests jealing with these fire zones.
3a-1/2 Editorial:
Changes "142 or 143," to " Fire Zone SA142 or SB143,".
This change is made in order to provide a more specific description of the locations under discussion.
~ to TXX-6728 October 2, 1987 Page 5 Of 19 Deviation No./
Page No.
Change Description 3a-1/2 Editorial: Adds fire area designation SB. This addition is made in. order to provide the specific fire zone of l
concern.
3a-1/2 Editorial: Corrects " biased" to " based".
3a-1/2 Editorial: Corrects "ioization" to " ionization".
I 3a-1/2 Editorial: Changes "both areas" to " Fire Zones 58143 and SB144".
This change in the justifications is made in order to define the areas under discussion.
1 3a-1/2 Editorial: Adds fire area designation.SB.
This addition l
in the justifications is made in order to provide the specific fire zone of concern.
3a-1/2 Update / Addition:
Replaces " Fire loading... areas." with "The fire severities in Fire Zones SA142, SB143 and SB144 are 17, 8 and 10 minutes, respectively.
The maximum permissible fire loading in all fire zones of concern is I
60 minutes." These additions ar.e made to incorporate the l
results of the combustible loading and MPFL calculations i
and to establish uniformity of fire severities in all l
l deviation requests dealing with these fire zones.
3a-1/2 Editorial: Corrects "5A" to "SA".
3a-1/2 Editorial: Corrects " fire zone 144" to Fire Zone SB144".
i 3a-1/2 Editorial: Adds fire area designation SB.
This addition is made in order to provide the specific fire zone of concern.
I l
3a-1/2 Update / Addition:
Incorporates the values for fire severities and maximum pennissible fire loading to Table 3a-1.
3a-1/2 Update / Addition:
Includes fire zones SA142 and SB143 to I
incorporate the proper suppression information in the justifications.
1 O
i
_ _ _ _. to TXX-6728 October 2, 1987 Page 6 Of 19 Deviation No./
Page No.
Change Description 3b/1 Clarification: Directs reader to "see attached Table 3.b" for location information.
For addition and correction see this table.
3b/1 Editorial:
Deletes drawing Bunker Ramo 50019866 from the-reference list.
This deletion is made because it does not-apply.
3b/1 Editorial:
Adds drawings FHA-3 and FHA-4 to the reference section.
This addition is made in order to provide additional information pertinent to the deviation.
3b/1 Clarification: Changes the exception section to read,
'"BTP APCSB 9.5-1 Appendix A, Section 0.1.J."
This change revises the specific section for which the exception is requested.
3b/1 Editorial: Adds item 6 to justifications.
See Table 3.b i
for the fire severities and maximum pennissible fire I
loading in the fire zones of concern." This addition is l
made to direct the reader to Table 3.b where the results of the combustible loading and MPFL calculations are incccporated.
3b/2 Correction:
Changes room number in Table 3.b from "85" to "83".
This change is done to provide the correct room in Fire Zone SD9 influenced by the deviation.
i 3b/2 Clarification:
Adds the fire area designations to the already mentioned fire zones in Table 3.b.
This addition is incorporated in order to provide clarity.
3b/2 Update / Addition: Deletes stated fire durations and corrects several hazard classifications in Table 3.b.
Adds MPFL values.
These additions are made in order to incorporate the results of the combustible loading and MPFL calculations and to establish uniformity of fire severities in all deviation requests dealing with these fire zones.
3b/2 Addition:
Adds room number "272".
This addition in Table 3.b is made in order to provide the room in Fire Zone AA99e influenced by the deviation.
1 I to TXX-6728 October 2,1987 1
Page 7 Of 19 Deviation No./
Page No.
Change Description j
3c/1 Clarification:
Adds "810" to the elevation, "82" to the room, and "SB8" to the fire area sections of the location.
These additions are made to clarify _the specific room under discussion.
l 3c/1 Editorial:
Adds Fila-2 and Grinnell Drawing No.133 drawings to the reference section.
These drawings are added to provide further information pertinent to the deviation.
3c/1 Clarification:
Changes the exception section to read:
"BTP APCSB 9.5-1 Appendix A, Section D.1.j".
This change revises the specific section for which the exception is requested.
3c/l Clarification:
Replaces " fire" with "the".
This change j
in the justifications is made because the area of concern is Room 82.
3c/1 Editorial:
Adds item 5 to the justifications.
See Table 3.c for fire severity and maximum pennissible fire loading values.
This addition is made to refer the reader to Table 3.c where the values of the combustible loading and MPFL calculations are incorporated.
3c/2 Clarification:
Adds Fire Area "5B" under the column for Fire Zone in Table 3.c.
This addition is made in order to clarify the fire zone under discussion.
3c/2 Update / Addition:
Replaces "less than 90 min" with "33 min.
- MPFL 60 min." and adds, "*The fire loading calculations excludes all combustibles which are enveloped I
with a one hour fire barrier." These changes are made to Table 3.c in order to incorporate the values of the combustible loading and MPFL calculations and to establish uniformity of fire severities in all deviation requests dealing with Fire Zone SB8.
e e
_ _ _. to TXX-6728 October 2, 1987 Page 8 Of 19 Deviation No./
Page No.
Change Description 3c-1/1 Editorial:
Reference to revision of drawings are eliminated.
The documentation of correct drawing revisions can be obtcined from other documents.
j 1
3c-1/1 Clarification: Adds "This wall separates corridor room l
140 and the turbine deck." This addition to the description section is made to clarify the location of the non-rated feature.
I i
l j
I to TXX-6728 October 2, 1987 Page 9 Of 19 Deviation No./
_ Page No.
Change Description 3d/1 Editorial: Adds " Safeguard" to Bldg., and "See Table 3.d" to the remaining sections.
These additions are made to refer the reader to the mentioned table where the specific locations are provided.
3d/1 Editorial:
Adds FHA-2, FHA-4 and FHA-5 drawings to the reference section.
These additions are made to provide further information pertinent to the deviation.
3d/1 Clarification:
Changes the exception section to read:
"BTP APCSB 9.5-1 Appendix A, Section D.1.j".
This change revises the specific section for which the exception is i
requested.
3d/1 Editorial: Changes " area" to " zone".
This change is made to maintain consistency in the justifications with the f
information provided in Table 3.d.
3d/2 Clarification:
Adds the Fire Area designations to the Fire Zone columns in Table 3.d.
These additions are made to provide a more specific description of the location.
3d/2 Update / Addition:
Realaces all fire severities and eidds the maximum permissible fire loadings in Table 3.d.
It also corrects applicable combustible loading classifications.
These corrections are made to incorporate the values of the combustible loading and MPFL calculations and to establish uniformity of fire severities in all deviation requests dealing with these fire zones.
3d/2 Correction: Adds " Sprinkler / Detection" under the protection column for Fire Zone SK17a.
This addition to Table 3.d is made to reflect as-built configuration.
3d/2 Editorial: Changes " Area" to " Zone".
This change is made
{
to maintain consistency with the information given under J
these columns in Table 3.d.
i 3d/2 Correction:
Deletes the entire section from Table 3.d.
i since the barrier where the door is located is not fire j
rated.
3d/2 Correction:
Changes "C" to "B" for the door designation between Fire Zones SK17b and SF19 and "0" to !C" for door designation between Firo Zones SK17b and SN158.
These change; are made in Table 3.d to reflect as-built configuration.
I y
3d/2 Correction: Changes "108" to "110" and "108" to "109" for
{
the room designations. This change is made in Table 3.d I
to provide the correct rooms under discussion.
3d/2 Correction: Changes "b" to "c" in Table 3.d in order to
}
reflect Fire Zone SK17c.
j
- _ - _ _ to TXX-6728 October 2, 1987 i
Page 10 Of 19 i
Deviation No./
Page No.
Change Description l
3e/1 Correction:
Changes "SE" to "SB" in the location section.
4 This change is made in orcer to provide the correct fire area where the non-rated feature is located.
3e/1 Editorial:
Reference to revision of drawings are eliminated.
The documentation of correct drawing revisions can be obtained from other documents.
3e/1 Clarification: Changes the exception section to read:
"BTP APCSB 9.5-1 Appendix A, Section D.1.j".
This change revises the specific section for which the exception is requested.
3e/1 Clarification / Correction:
Replaces item 2 in the justification with " Detection is available in Fire Zones SB15 and SF20 in the Safeguards side.
In containment, area wide detection is provided in Fire Zone CA101d, and in Fire Zone CA101g which is adjacent to Fire Zone CA101h.
This change is made to clarify the detection coverage available in the fire zones under discussion.
1 3e/2 Clarification: Replaces item 4 in the justification to
" Hose coverage for Fire Zone SF20 is available by utilizing Station CP1-FPFESH-19, in Fire Zone SF19, and additional hose supplied by the Fire Brigade." This change is made to clarify the manual suppression available in each fire zone under discussion.
3e/2 Clarification / Correction:
Replaces " Appendix R III.G.2."
with, "BTP APCSB 9.5-1".
This change is made in the justifications to provide the correct document to which the construction is equivalent.
3e/2 Editorial: Adds item 6 in the justifications to read "See Table 3.e for fire severities and maximum permissible fire loadings." This addition is made to refer the reader to the aforementioned table where the values of the combustible loading and MPFL calculations were incorporated.
3e/3 Editorial:
Adds Fire Area designations to the Fire Zone columns in Table 3.e.
These additions are made to provide clarity in the definition of the fire zones.
3e/3 Update / Addition: Corrects the fire severity values and adds the maximum permissible fire loading for each Fire Zone under discussion with the exception of Fire Area CA.
These corrections and additions are made in ordei to incorporate the values of the combustible loading Tnd maximum permissible fire loading calculations.
i to TXX-6728 October 2, 1987 Page 11 Of 19 Deviation No./
Page No.
Change Description 3e/3 Correction:
Deletes " Hose Sta/".
Adds "HPK".
This change is made because the hose travel distance is exceeded for Fire Zone SF20. A purple K fire extinguisher j
is also located in the fire zone.
4 3e/3 Editorial: Adds "HPK - hand held purple K fire l
extinguisher".
This addition is made in order to define the type of fire extinguisher.
l l
l 1
l l
9
-_..______---- _----_-_- _ __ - _ ~
D to TXX-6728 October 2, 1987 Page 12 Of 19 Deviation No./
Page No.
Change Description 39/1 Editorial: Reference to revision of drawings are eliminated.
The documentation of correct drawing revisions can be obtained from other documents.
39/1 Clarification: Changes the exception to read Appendix A, Section D.1.j.
This change is made in order to specify the section for which the exception is requested.
39/1 Editorial:
Changes " areas" to " Fire Zones".
This change in the justifications is made to provide clarity.
l 39/2 Editorial: Adds item 7 in the justifications to read, "See Table 3.g for fire severities and maximum permissible fire loadings in the fire zones of concern." This addition is made to refer the reader to the aforementioned table where the values of the combustible loading and MPFL calculations were incorporated.
39/3,4 Editorial: Adds the Fire Area designation to the Fire Zone column in Table 3.g.
This addition is made to provide clarity and the specific location of concern.
39/3,4 Editorial:
Adds "/MPFL (MIN.)" to the fire duration column in Table 3.g.
This addition is made in order to incorporate the values of the MPFL calculation.
3 /3,4 Update / Addition:
Revises the fire severity values in 9
Table 3.g to incorporate the results of the combustible loading calculation. Adds the values of the MPFL J
calculation.
These changes are made in order to incorporate the values of the combustible loading and MPFL.
l l
3g/3,4 Update: Deletes from Table 3.g, "* Duration...
suppression." This deletion is made because the new combustible loading calculation was performed under a different method.
O
Attachment I to TXX-6728 October 2, 1987 Page 13 Of 19 Deviation No./
Page No.
Change Description i
3h/1 Clarification:
Adds room numbers "133, 25" to the l
location description.
This addition is made in order to j
specify the rooms under discussion.
3h/1 Editorial: Reference to revision of drawings are eliminated. The documentation of correct drawing revisions can be obtained from other documents.
3h/5 Editorial:
Changes " area" to " corridor" in item 4 in the justification.
This change clarifies that the area referred to as having ionization detection is the corridor.
)
3h/5 Update / Addition:
Replaces " burn time... minutes." with
" fire severity of 27 minutes and a maximum permissible fire loading of 60 minutes." This change is made to l
incorporate the results of the combustible loading and MPFL calculations and to establish uniformity of fire severities in all deviation requests' dealing with these i
Fire Zones.
l l
t i
1 4
1 1
l l
i 1
_]
l l -to TXX-6728 October 2, 1987 Page 14 Of 19 i
Deviation No./
j Page No.
Change Description
]
4a/1 Clarification: Adds Fire Area designation "CA" to the location description.
This addition is made in order to further specify the location under discussion.
4a/1 Correction: Deletes the phrase "(And heaters on both)".
This deletion is made because these heaters are not considered essential to safe shutdown, per supporting evaluations to the FSSA Calculation #152, 4a/l Clarification: Adds the specific section III.G.2."d" to 3
the deviation section.
This addition clarifies the specific section of III.G.2 for which the deviation is i
requested, j
l 4a/1 Correction:
Deletes the phrase "and heaters" from the description section.
This deletion is made because the 1
pressurizer heaters are not considered essential to fire l
safe shutdown, EPM FSSA Calculation #152.
4a/1 Correction:
Replaces item 1 in the justification to read "a negligible amount of combustible material exists in the room." This change is made to reflect as-built conditions.
1 I
l l
l l
l l
l
1 Attachment I to TXX-6728
' October 2, 1987 Page 15 Of 19 Deviation No./
Page No.
Change Description Sa/1 Clarification: Adds Fire Area designations "EN and E0" to the location section.
This addition is made in order to specify the location under discussion.
Sa/1 Editorial: Corrects "AS8" to "APCSB".
This correction in the exception section is made to reflect the proper document.
i Sa/1 Clarification: Adds ", Section 0.3.f".
This addition is' made to provide the specific section for which the exception is requested.
b l
l l
l, 1
l 1
3 a
k
I to TXX-6728 October 2, 1987 i
Page 16 Of 19 Deviation No./
Page No.
Change Description 8b/1 Editorial:
Reference to revision of drawings are eliminated.
The documentation of correct drawing revisions can be obtained from other documents.
8b/1 Editorial:
Deletes drawings FHA-14 and Grinnell Drawing No. 99 and 2323-Al-0507.
These changes are made in order to delete drawings which are not pertinent and to add drawings which provide additional information.
8b/l Clarification:
Adds ".b" to the deviation section.
This addition is made to specify the section in III.G.2 for which the deviation is requested.
i 8b/1 Clarification: Adds the Fire Area designation "AA".
This addition is made to provide a more thorough description of i
the area.
8b/1 Addition / Update:
Change description "One hour wraps are provided on each tray that traverses the space between the MCC's at elevations 830' and 852'." to read "One hour wraps are provided on one train of combustibles and fire breaks are provided in the associated train of combustibles." This addition is made to reflect an updated protection scheme for this area.
8b/l Addition / Update:
Adds "are wrapped".
This addition to the justifications is made to reflect an updated protection scheme for this area.
8b/1 Addition / Update:
Adds " Redundant essential raceways in the protection area are wrapped." This addition is made to reflect the updated protection scheme for this area.
_---_----__.-.-___--.)
Attachment I to TXX-6728 October 2, 1987 Page 17 Of 19 Deviation No./
Page No.
Change Description 10/1 Editorial:
Reference to revision of drawings are eliminated.
The correct revisions of drawings are located in other documents.
l 10/1,2 Clarification / Correction:
Deletes items 1 and 2 in the justifications.
Adds Items 1, a, b, c, d, and 2 in revised form.
These revisions are made to provide a more thorough description of the situation and to reflect the updated Fire Hazards Analysis in which design changes have been made.
l l
l 1
i 4
- _ _ _ _ - to TXX-6728 October 2, 1987 Page 18 Of 19 Deviation No./
Page No.
Change Description 14/1 Editorial:
References to revision of drawings are eliminated.
The documentation of correct drawing revisions can be obtained from other documents.
14/1 Clarification: Adds ",Section D.1.j" to the exception.
This addition is made to specify the section for which the-exception is requested.
14/1 Update / Addition: Adds the MPFL philosophy to item 2 for clarity and consistency.
_ to TXX-6728 October 2, 1987 1
Page 19 Of 19 Deviation No./
)
Page No.
Change Description j
}
TJI/1 Editorial:
References to revision of drawings are j
eliminated.
lhe docummi?ation of correct drawing revisions can be obtaineG from other documents.
l TJI/l Clarification Adds Deviation: Appendix R to 10CFR50, i
Section III.G.2.f".
This addition is made in order to specify the section for which the technical justification is provided.
TJ1/1, 2 Clarific6 tion:
Rewrites the 2nd paragraph in the description to provide a more accurate description of the l
B & B tested configuration vs. untested configuration.
l
]
I I
I 1
\\
4 l
1 I
1
' to TXX-6728 October 2, 1987 j
Page 1 of 2 "N0NCOMPL1ANCE JUSTIFICATIONS NO LONGER REQUIRED" DEVIATION SUBJECT REASON FOR DELETION Ic Boric Acid Pump TSSA Revision 2a Auxiliary 852'-6" Chiller Trans.
NFPA 13 Upgrade 2b Switchgear Room Train A 86-10 2c Switchgear Room Train B 86-10 2d Alternate Shutdown Panel-Area 86-10 2e Boric Acid Storage Tank Area FSSA Revision 2f Valve Isolation Tank Room Fire Area 2c NFPA 13 Upgrade 2g Corrider Room 71 Fire Area 4 NFPA 13 Upgrade 2g-1 Auxiliary 822'-0" Fire Area AA21c 86-10 2h Valve Isolation Tank Room Fire Area Ic NFPA 13 Upgrade l
21 Radiation Pen. Area Room 77S 86-10 21-1 Radiation Pen. Area Room 77N 86-10 2j Condensate Tank Level Ind.
86-10 3
2k Safeguard 852'-0" NFPA 13 Upgrade 21 Control Room HVAC Equipment Room 86-10 l
2m Train A UPS and Battery Room 86-10 2n Train B UPS and Battery Room 86-10 l
4b CCW Heat Exchanger FSSA Revision l
Sb Partial Sprinkler Coverage in SG 86-10 l
Valve Room 8a-1 20' Vector Separation
'FSSA Revision I
9a Control Room Suppression 86-10 9b Control Room Complex Suppression 86-10 11a Damper Deviations Damper Replacement 11b Damper Deviations Damper Replacement 11c Damper Deviations Damper Replacement 11d Damper Deviations Damper Replacement i
11e Damper Deviations Damper Replacement 12a HVAC Penetration Deviations Damper Replacement 12b HVAC Penetration Deviations Damper Replacement 12c HVAC Penetration Deviations Damper Replacement 12d HVAC Penetration Deviations Damper Replacement 12e HVAC Penetration Deviations Damper Replacement 12f IIVAC Penetration Deviations Damper Replacement 12g HVAC Penetration Deviations Damper Replacement 12h HVAC Penetration Deviations Damper Replacement l
12i HVAC Penetration Deviations Damper Replacement l
12j HVAC Penetration Deviations Damper Replacement 1
12k HVAC Penetration Deviations Damper Replacement 121 HVAC Penetration Deviations Damper Replacement 12m HVAC Penetration Deviations Damper Replacement l
13 NFPA 13 Nonconformances NFPA 13 Upgrade 13a Auxiliary Fire Area AA 86-10 l
l to TXX-6728 October 2, 1987
)
Page 2 of 2
- a 1
" NONCOMPLIANCE JUSTIFICATIONS NO LONGER REQUIRED"(Continued)
DEVIATION SUBJECT REASON FOR DELETION 13a-1 Auxiliary 790'-0" 86-10 I
13a-2 Auxiliary 810'-0" 86-10 13a-3 Auxiliary 830'-0" 86-10 13a-4 Auxiliary 852'-0" 86-10 Q
13b E & C Fire Area EA 86-10 13b-1 E & C 778'-0" NFPA 13 Upgrade 13c Safeguard Fire Area SA 86-10 1
13d Safeguard Fire Area SB 86-10 13d-1 Safeguard 810'-0" 86-10 l
13d-2 Safeguard 831'-0" 86-10 TJIII Technical Justification III 86-10 1
FSSA Revision - The revision of the Fire Safe Shutdown Analysis has obviated the need for this deviation.
NFPA 13 Upgrado - An u) grade of the existing automatic sprinkler systems in the plant has established NFPA 13 standard sprinkler systems.
86 A Fire Hazards Analysis of the area has established that less than area wide sprinkler protection is adequate for the hazards and obviated the l
need for the deviation.
l Damper Replacement - The Damper Replacement Program analysis has obviated the need for this deviation.
1 5
1 l
i l
I TABLE OF CONTENTS Deviations Subject of Deviation la Service Water Pumps l
lb Chiller Units & Pumps l
3a Removable Concrete Block 3a-1 Removable Concrete Block 3b Containment Penetration Seals 3c Missile Resistant Door 3c-1 Control Room Missile Door
)
l 3d Watertight Doors 1
3e Containment Airlock I
39 Containment Mech. Penetration Seals 3h Cable Spread Room 4a Pressure Relief Valve 4a-1 Containment Building-RHR Valves (Rm. 154)
Sa Non-lEEE 383 Cable 8b 20' Separation Criteria j
10 Emergency Lighting 14 2 Hour Rated Penetration Seals Technical Radiant Energy Shields a
Justification 1 l
l 1
1 e
i
--- - _ - - - - - ~ - _ _ - - - - - - - - - _ - _ - - -
__--------_u--
DEVIATIONS ENCLOSURE TO TXX-6728 OCTOBER 2, 1987
Deviation la Slides View Location la-1 Looking North Bldg.
SWIS Elev.
796 Room 275 F.A.
WB104b l
Col. N-S Systems Path A Service Water t
E-W Path B Service Water l
k Reference Drawings:
Grinnell Fire Protection 7 i
FHA-40
[
2323-EI-1103 2323-EI-1104 I
I 2323-EI-2025
'k Deviation:
Appendix R of 10CFR50 Section III.G.2,b l
I J
==
Description:==
Redundant Service Water Pumps and raceways, service l
water exhaust fans and their associated raceways, I
J service water recirculation valves and their associated l
raceways, service water isolation valves and their l
associated raceways, branch circuits from redundant l
1 MCC's 1EB4-3 and 1EB3-3 to XEB4-3 and XEB3-3 l
respectively are located in the same fire area.
l 1
Justification:
1.
Partial barriers with A label doors and curbs i
separate Train A and Train B pumps and MCCs.
l The barriers are 14'-6" high, 2'-6" thick rein-forced concrete. The pumps are 12'-0" high while l
the MCCs are less than 12' high.
l 2.
Area detection and automatic sprinkler l
coverage is provided.
Ceiling level ionization l
detection and spot-type thermal detectors provide l
carly warning in the event of a fire. An auto-l matic wet-pipe sprinkler system provides automatic l
fire suppression for the area.
[
3.
There is a negligible amount of exposed l
cabling and the fire loading is low.
hazards are controlled by MPFL and designating the l
I PAGE 1 0F 5
area as no storage, which provides that transients {
will not be left unattended without compensatory l
measures being taken.
l 4
Cables supplying each pump and associated l
MCC enter the pump bay from the underground l
through the north wall.
l 5.
Raceways supplying exhaust fans are embedded in j
the north wall of the structure until they l
I penetrate through the wall and join the l
fans. The fans are qualified with Class H l
insulation which allows the fans to operate l
at an ambient room temperature of 2620F for a l
period of 750 hours0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br />. These operating conditions I
are more extreme than the conditions produced by l
the postulated fire in this area.
The fans are l
also totally enclosed and have a TENV NEMA l
(totally enclosed non-ventilated classification l
which provides that the fans are not adversely I
affected by water spray from an automatic fire l
suppression system.
Therefore, the' fans l
lack of twenty foot separation does not cause l
the loss of both trains of fans in the postulated i
fire.
l 6.
Service water recirculation valves and raceways l
suppling each service water recirculation valve l
are separated by approximately 15' with no l
i l
intervening combustibles.
Cold water piping provides a physical separation between the valves and acts as a heat sink to disperse and dispose of radiant heat produced by a fire.
7.
A fire caused by transient combustibles is miti-l gated because the area is a designated "No l
Storage" area. This ensures that the credible l
postulated fire would be a fire involving ser-l vice water pump lube oil.
However, a service l
l water pump lube oil fire is highly unlikely be-l cause the oil is enclosed in the pump and if the.
]
oil did spill, the spill would be contained by l
l curbs and drained.
l l
8.
The branch circuits which feed XEB4-3 and I
XEB3-3 are associated circuits which could l
disable the service water MCCs 1EB4-3 and l
1EB3-3 respectively.
These MCCs also power the exhaust fans and the service water isolation valves. The MCCs are separated and protected by the same method as the service water pumps.
PACE 2 0F 5
9.
A fire at the ceiling level involving one of the l-fan units will not adversely affect the redundant l counterpart which is separated by 2'-6" thick con-'.{
crete bearn providing a physical barrier between thel redundant essential fans.
l l
l l
FAGE 3 0F 5
r
't
+
+
+
a
- 6. >
+
+
+
t s
s r
e-A' a na a
e+
s
+ r.
+
+
- r n no o oo mc m'c_
,r i
cd a
,u t
t r
a dl h r
eet e
a rbi r
p uaw i
+m e
ol
+
X++
a st s
p w
o "A l 1
+,
s f
o"
+ "C J-u
+
r t hii t
st y+"A i i gd t t G
r s wnni o
n i
e f
o
,d
+- +aI+
l
/s u
c h a
+
e r
s god c e
w u
r s il enr h
Y' z
e ed e
r I
7 r i" r el
+q 4
6 r
r6ib p.
E
. Wr.
ar f m 5
.b la' C
3 A_
f 4 e d
8 t
l 1 h
% c
\\
/
_ d n.
d/,
,y~/+
R4, c
a t
E j/
i i
,i 5s S_
+<d A_ la '. 4 u 3
r r
i
.d t
s f
t s nd e e t
t\\
/
e r p a nt hb i
+
s d
v r a m a
\\
I P
e pu
+<z
+e l
3 t
p gsid r el 1
v, x er ch n e m ut r ol z
r
/o ri el b0 f,__i n
r,l_
t wt a1 A
+zd
+
^S a
c w '1 k
d mr
+e e e 2 d a r
,T)1 k d e eh s
c
/ +
aic, st t ii
<z I
t t vik o i
a 3M '
- /
1 v
novcp s1 e o
/
~, v 1_ +
b i
I r ri x s -
1 e
peh e et i p f
1 r
st i
0
'I r-e s o
4~aL^+'
4 t i h" nf t
2 a
g6
+ 4_r. &+N c
'w ai - e eh' r
s
'~
er 2 aoe
+~4n+c,,.
- C a.
c a' i
2 e et e 3'
+
v s1 t r af 5
N.
ri e e ehf rh ui eo L-
+
~
S T ocTdd t o
e d
e a,e 6
&~'
L
^
+
ro O
c e,~ Qo &z * }
1 nr
+ _. a +
a
~+
u eo d
ss
^
am;,-
^
r e
.~
1 u *l s.
r e
a wre r z s
l4
~
1-s i
A
/
e a. W, 5
+
+
4
+
}
e c
hS t r r s
i tae s Z z e
c s
d s
r r e oM
- e e
r 5
e /
4@+
fE a
f t:
o',
1 l
1 l
i
-I f
Deviation Ib 6.
Spray shields have been added to electrical j
equipment to protect against water damage from
~
sprinkler actuation.
i f
I 1
l l
PAGE 2 OF 3
)A N
/
[N p
'* @ I m
g
)
A w
d g, 2
2, K}/-
e c
rxy
$r '
Y d
1Qe i
- c. (/c e
)
o r
rJ {#
a fe g i
t.
0
/
/
Mf aL go
/-
V E
4 #
rd L
A
^
o
/o t
ol
[c
/
gm"%
o 7
e J N e
t a
a, D's"ca s
w LM 3
D E
Ae
/
g S
/.
g r e D
A z c g
- Y
/
d' 4
t 6 A S u Oo#
o G-
@3k
[o e
A s
j Z
l O
f E O @
5
~
u L
Z G V [-
o ff a
A D
ER_
u T
a r
dz f
e A
Md J~
L P
"e l
L r
1
- s 1
O A
Mr%
J,
- V e2 I
O s c y si e a o
ci n e n t r a
f d ohi set e 9
eiT a pd pa 7
t t t m l oe o
o 1
aa n uel l r 2
M$ rya o p p ae a r r.
5 as c y
v
[
e p p ot f ne t
g
/
r e md w oeh sunt n t
pa ogd L
s
- n eine n ws
/{L p
ri nhh t i t i GP t
F m
uaogt at a
~_9(
~
u orii z ar g
)
h t t h nio n
~
[
a e nC ei
~
erl e o rd n
~
n o u '5 wi i a A g$ @_' o~
o i
of c1 t
.f o
t
(
r eh m l
a sisb t er
[
l l r ci i t u e
/
u a e r ws ol c
i i e se yh b r
t r vrid s i
i r ri e r e et d
eib vl b
C a at l rd r ns pb cl ai eo u l
n h) ph ok a m 4
a t ns ce r n o
a i oe h pih c s
wir oT rt J+ o 2
L r
t w
spi e L
e d c rt i s wh 1
A t
l e ui
/ 'o l
d r eesae s L
i i t hh r e pye h
vst t ori ac rw
[
~
. (
i C
on oapt u r
i r od nd
- ed o
d p cne et c e "r e, ' ^
a e
ael h e a r t
sd wet wr 7.
a i r st b l
@j
!a l
a r e a aEl f-I i e
aoebl R
ebl hd w
l r gnl m i e "B i r
al m y
a t
uhi" h
a e s
,e
- e ss c r s
t e
rd s o '2 f
i p r
w on y a
h yf a S
T gob t 1 t a s e
d,c ~
d.
j 1
,E" m ?
l 2
to m
s
~
i
$s b
gj 3
E!
a m
id 9)
I 5 l1) 7u
, w32 1
d4 symuumuuuuuK:.
]
W1 b
+h 3f i1 w
1
=
m-d
'i I
4 s======r y>
4 3
2
.1
'd ed a
lNd ll z
e e N
T PAGE 5 0F 5
Deviation Ib Slides View id-1 Location Id Bld6-E&C 1d-3 Elev.
778
.jld-4_
Room-115a id-5 F.A.
AA153 Id-6 l
Col. N S E-W Systems Path A Safety Chilled Water Systems Path B Safety Chilled Water Reference Drawings:
Grinnell Fire Protection 99 FHA-14 2323-El-2012 j
2323-S-0795 j
2323-S-0797 2323-E1 0714-11 l
Deviation:
Appendix R of 10CFR50 Section III.G 2.b.
l 1
==
Description:==
Redundant safety related chiller units and their respective circulation pumps are located in a common fire area.
Justification:
1.
One hour rated gypsum on steel stud partial barrier is provided between redundant equipment.
Curbs are provided to contain flammable liquids.
i 2.
General area ionization detection and automatic sprinkler coverage is provided.
Sprinkler locations are positioned to provide coverage of transient and in situ combustible hazards in accordance with NFPA.
3.
The combustible loading is light hazard with a fire duration of 11 minutes.
The maximum l
l permissible fire loading is 60 minutes.
l j
4.
All exposed cables have been enveloped in a one l
{
hour rated barrier system.
Raceways essential for l
equipment operation have been coated to within 3 l
feet of the equipment with a one hoar rated barrier system.
5.
Eight 6" diameter steel pipe drain lines with check valves have been installed in the fire l
barrier between fire area AA153 and fire area EA43 l
to remove fire suppression water.
Four drains l
have been installed on either side of the partial barrier separating the redundant chiller units.
PAGE 1 0F 3
l i
Deviation 3a Slides View l
Location 3a-1 Looking South-West f
Bldg., Auxiliarv l
Elev.
810'-6" l
Room 200 l
F.A.
AC29
[
Col. N-S KA Systems Path A E-W 2A Path B l
l Reference Drawings:
2323-S-0711 2323-5-0786 2323-5-0787 FHA-15 l
ATTACHMENT Exception:
BTP APCSB 9.5-1 Appendix A Section D.l.j l
l r
==
Description:==
A removable solid concrete block wall used to seal equipment access hatches through fire rated barriers.
Justification:
1.
Construction of removable solid block walls is substantial in nature. Walls are 2 feet thick I
composed of two layers keyed into the opening.
(See analysis Attachment 3a.)
2.
General area ionization detection is provided in all areas. Automatic sprinkler coverage is provided in corridors.
Hose stations and portable hand held extinguishers are available in Fire Zone l
AA21b.
l 3.
Fire loading is light to medium as shown in the 1
attached table.
4.
Primary design considerations are seismic requirements, radiation shielding, and maintenance.
l PAGE 1 0F 3
1 l
l l
Deviation 3a a l
l ANALYSIS OF FIRE RATING OF REMOVABLE SOLID CONCRETE BLOCK ACCESS HATCH SEALS The removable concreto block walls are composed of a minimum of two.
(2) vertical layers of blocks placed in series with staggered block joints.
The block walls are a minimum of one foot to a maximum' of four feet in depth as dictated by the depth of the adjoining poured concr'ete walls.
Blocks are field constructed of concrete having a minimum density of 141 j
pcf using Type II Portland cement with individual block dimension tolerance j
of plus or minus 1/8 inch. All surfaces of each block are* painted to facilitate decontamination.
The configuration of the block walls would allow them to be free standing, however, exposed structural steel supports are provided to contain the block calls during a seismic event. Concrete
)
I block walls that are designated as watertight are covered with a 1/4 inch thick steel plate.
i The type of concrete used for the blocks is the same. type used in construction of the poured reinforced concrete fire barriers throughout the plant. The type of concrete used for the blocks along with the relative thickness of the block walls gives a general correlation to listed fire j
rated construction.
However, due to the installation of the concrete l
blocks (absence of mortared joints) no direct comparison to UL or other standards of approved construction can be made, j
A fire would not create major pressure differential loading on the l
concrete block walls to the extent of jeopardizing structural integrity, Steel supports would aid in maintaining the block walls integrity in the event of an explosion, j
l close concrete block fabrication tolerances along with staggering of block joints, including the keying of the block walls into the interfacing wall, eliminates direct hot gas propagation paths.
The increased surface contact area and the heat-sink characteristics of concrete will combine to reduce the temperature of any gases which might reach the unexposed surface of the wall.
A primary consideration in the evaluation of the adequacy of the block walls is fire exposure hazard on a case by-case basis, per table 3a.
l l
r PAGE 2 0F 3 L--__-_____-__-__-_________
e 1
i MVIATION h IABLE3.a IG!TE E!4CE kA!LS j
i FM P.30M FIRE AREA IE!7.!Fil0N ECAPI IORA!!'/N PPtTECTION WALL *ilCFJE!! RXH FIRE AREA MSCEIFTION I!CAF2 T/2ATION PROTE:"i10N i
i
- X 29 Centriftgil
,;gt: 16 sit. :etectier.
2'-F 207 21b c:trir sed;a !! sir. sprir.kler/ '
Chargtr.gPu; MPFL120 sin.
MFFL 0 detection l sin.
l i
i I
)
PAGE 3 OF 3
.a 1
.i
.1
]
Deviation 3a-1
Subject:
Removable Block Walls I
Location:
)
Building:
Safecuards Elevation:
831-6 Room:
Fire Zones: 142. 143. 144 Col. N-S:
D-D i
E-W:
7.5-S Reference Drawings:
2323-S-0787 l
l 2323-S-0788 l
l FHA-3 1
'l Exception:
BTP APCSB Appendix A, Section D.l.j l
==
Description:==
Fire Zone SA142 contains cabling related to the following l
Systems: Residual Heat Removal, AC Distribution, Chemical
)
Volume and Control, Safety Injection, Component Cooling, Main
)
S te.am, Sampling, Safety Chilled Water, Reactor Coolant and i
I Heating, Ventilating and Air Conditioning. One of thea l
I redundant trains is protected in this area.
l Fire Zone SB143 contains cabling associated with the fcllowing l
systems:
Safety Injection, Chemical Volume and Control, Main Steam, Residual Heat Removal, Sampling, Auxiliary Feed, j
Containment Spray, AC Distribution, Heating, Ventilating and Air Conditioning, and Safety Chilled Water. One of the redun-l ant trains is protected in this area.
l Fire Zone SB144 contains cabling associated with the following l systems: Main Steam, Chemical and Volume Control, Containment Air Monitoring, Residual Heat Removal, AC Distribution, Heating, Ventilating and Air Conditioning, Component Cooling, Auxiliary.
Feed, Safety Inj ection, Safety Chilled Water, Nuclear Instrumentation, and N-16 Detection. One of the redundant l
trains is protected in this area.
l Fire Zone SB144 contains no redundant equipment to either Fire l
Zone SA142 or Fire Zone SB143.
l The interaction path between Fire Zone SA142 and SB143 is j
through the pipe chases that are contained in Fire Zone SB144.
PACE 1 0F 5 L
r i
i
)
l
[
I I
Deviation 3a-1 I
The only non-rated openings in the pipe chase in Fire Zone l
SB144 are 5 solid concrete block wall access hatches.
These l
access hatches are of similar design to those access hatches l
already accepted.
Fire Zone SB144 has already been combined l
with Fire Zone SB143 in the Fire Area SB and Fire Zone SA142 l
will be maintained separate in Fire Area SA by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barrier l
l except for these 5 hatches.
l There is ionization detection in the fire zones of concern and i
automatic sprinkler coverage in Fire Zone SB144. 'The fire l
l severities in Fire Zones SA142, SB143 and SS144 are 17, 8 and l
1 10 minutes, respectively. The maximum permissible fire l
)
i loading in all Fire Zones of concern is 60 minutes.
For a
{
j fire to affect equipment in either Fire Zone SA142 or SB143, l
]
it must travel up one pipe chase across Fire Zone SB144 and
]
then down the other chase into the opposite train Fire Area.
.]
Based on the fire loading in these fire zones this occurrence l
{
would be highly unlikely.
l l
Justification:
1.
Construction of removable solid block walls is
]
substantial in nature.
Walls are 2 feet thick, j
composed of 2 layers keyed into the opening.
)
l 2.
General area ionization detection is provided in l
Fire Zones SB143 and SB144.
Automatic sprinkler l
coverage is provided in F.A. SB144 and partial l
automatic sprinkler coverage in Fire Zones SA142 l
j and SB143.
l
{
)
3.
The fire severities in Fire Zones SA142, SB143 and l
SB144 are 17, 8 and 10 minutes, respectively.
The i
maximum permissible fire loading in all Fire Zones l
of concern is 60 minutes.
l 4.
Primary design considerations are seismic requirements, radiation shielding, and maintenance.
5.
Rapid response is provided by early detection of fires with ionization detection throughout the I
area. Manual suppression response is available i
using hose stations and portabic extinguishers.
l l
PAGE 2 0F 5
i Deviation 3a-1 j
6.
A fire in Fire Area SA must travel up a pipe l
l chase, breach the block closures, across Fire Zone i
SB144 which contains automatic sprinkler suppression l l
and then travel down another pipe chase into Fire I
Zone SB143 before any redundant components are j
j affected.
7.
Fire testing of the removable block closures would l
I not significantly enhance the fire safety at CPSES.
I 1
l l
l 1
1 1
l l
I l
PAGE 3 0F 5 E - -
T Deviation 3a-1 ANALYSIS OF FIRE RATING OF REMOVABLE SOLID CONCRETE BLOCK ACCESS HATCH SEALS The removable concrete block walls are composed of a minimum of two (2) vertical layers of blocks placed in series with staggered block joints.
The block walls are a minimum of one foot to a maximum of four feet in depth as dictated by the depth of the adjoining poured concrete walls.
Blocks are field constructed of concrete having a minimum density of 141 pcf using Type II Portland cement with individual block dimension tolerance of plus or
'nus 1/8 inch.
All surfaces of each block are painted to facilitate decontamination. The configuration of the block walls would allow them to be free standing; however, exposed structural steel supports are provided to contain the block walls during a seismic event.
Concrete block walls that are designated as watertight are covered with a 1/4 inch thick steel plate.
The type of concrete used for the block is the same type used in construction of the poured reinforced concrete fire barriers throughout the plant. The type of concrete used for the blocks along with the relative thickness of the block walls gives a general correlation to listed fire rated construction.
However, due to the installation of the concrete I
blocks (absence of mortared joints) no direct comparison to UL or other j
4 standards of approved construction can be made.
A fire would not create major pressure differential loading on the concrete block walls to the extent of jeopardizing structural integrity.
Steel supports would aid in maintaining the block walls integrity in the event of an explosion.
Close concrete block fabrication tolerances along with staggering of block joints, including the keying of the block walls into the interfacing wall, eliminates direct hot gas propagation paths.
The increased surface contact area and the heat-sink characteristics of concrete will combine to reduce the temperature of any gases which might reach the unexposed surface of the wall.
A primary consideration in the evaluation of the adequacy of the block walls is fire exposure hazard on a case by-case basis, per table 3a.
PAGE 4 0F 5
n-_-_-_--__________-______-_____
DEVIATIONks1 TABLE 3a-1 l
I l
DL'EA!!0W WALL F.A.
DlEATION FHA ROCM F.Z.
DESCRIPTION HAZAD (K!W.) PR0"TCil0N TH!CE ET! F.Z.
DESCRIPTION HAZAE (KIN.) FECTECTION 3
88 SB Penetration Area Light 10 Sprinkler /
1'0' Carr SA PipeChase Light 17 Sprinkler / l 144 MPFL lanization 142 MPFL Ionization ;
60 sin. Detection /
60 sin. Detection / j j
HKP l
l l
l 1
't l
l
\\
I I
l l
l l
l i
PAGE 5 OF 5
Deviation 3b Slides View Location 3b-1 3b-2 Bldg.
See attached Table 3b 3b-3
(
1
- Elev, See attached Table 3b 3b-4 l
Room See attached Table 3b
.[-
F.A.
See attached Table 3b l
Col. N-S Systems Path A E-W Path B Reference Drawings:
Bun ~ker Ramo 50021526, Sheets 1 and 2; 50020445; l
50021765; 50021690; and 50021914; FSE-00182; Conax-7060-1001; FHA-3; FHA-4.
l Exception:
BTP APCSB Appendix A, Section D.1.j l
==
Description:==
Penetrations for electrical conductors through the containment walls have not been tested as fire seals.
Justification:
1.
All penetration assembly non-metallic materials (excluding cables) have been classified by testing l
I to be "non-burning" or "self-extinguishing" by test in accordance with ASTM D635.
2.
Ionization, thermistor strip or UV fire detection is provided in all areas on both sides of the seal l
l (see Table 3b).
l l
3.
Penetration assemblies provide a means for continuity of power, control. and signal circuits through the containment structure pressure barrier while maintaining the integrity of the barrier.
4.
Penetration assemblies are normally pressurized i
from outside containment with dry nitrogen at I
between 60 to 100 psig.
5.
Penetration assemblies are designed to remain intact following a DBA and prevent leakage to the atmosphere.
6.
See Table 3.b for fire severities and maximum l
permissible fire loading in the fire zones of l
concern.
l 1
PAGE 1 0F 2 l
l
5 1
l l
f;EVIATION3t ATTACHMENT I
I fli! DIEATION (MIN)/
K':Lt!O RTM FIRE 20NE l!A2ARD MFFL! MIN)
SYSTEMS NO.CFFEKETEATIONS l
l Safegard 83 S09 Medica
- l60 TrainASwitchgear 27 l
Cottainnr.:
154 CAlcib Light til RCP, PJiR l
l l
Safeguard 96 SE16 Light 23/f0 Alternate Shutdown Panel 19 l
2ttaitsent 15!a CA10ld "ehus 26/8 ReacterTrip l
l l
l Safeguard 103 SBl8 Light 16/E0 TrainBSwitchgear 28 l
l I
Contattaent
!!!a CA10lf Ligst 26/t l
l l
i l
Fuel
!?!
AA99e (cw 3/50 FuelStcragePaol l
l "T.airaer.:
.!!!a CA10lf Low
- f 1 Fuel !!ard!!tt Area l
- ?te MFFL for Ccetauntt is the ecstunible leading durir.g cperati:t ed 180 sinutes daring outages.
l l
t t
PAGE 2 OF 2 t
V
^ '
'1 1
Deviation 3e Slides View Location Bldg.
See Attached Table 3c.
Elev.
810 l
Room 82 l
F.A.
SB8 l
Col. N-S Systems Path A E-U Path B Reference Drawings: Overly Drawing Q8104, S *ets 1-17 1323-Al-0540 FHA-2 l
]
Attachment 1
i Grinnell Drawing 133 1
]
Exception:
BTP APCSB 9.5-1 Appendix A, Section D.l.j l
==
Description:==
Missile Resisting Doors are installed.in fire barriers but are l
not of a fire rated construction.
Justification:
1.
Door is constructed of solid 2 1/2" thick steel j
plate (see sketch 3c-2) and will not degrade the
{
integrity of the fire barrier.
Door latching j
assembly is comprised of 2 dead bolt locks (see
-l sketch 3c-3).
j 2.
Automatic sprinkler suppression is provided where potential for exposure of safety-related systems exists.
Ionization detection is provided throughout the area.
l 3.
Primary design criteria is resistance to externally generated missiles.
4.
Primary Exposure hazard is 138KV startup transformer (see sketch 3c-1).
Tts missile resistant door is shielded from direct exposure of a transformer fire by three hour rated walls on the switchgear and safeguard building exteriors.
5.
See Table 3.c for fire severity and maximum l
permissible fire loading values.
I PAGE 1 0F 5
r j
l l
l TABLE 3.e MISSILEEESISTINGD002!
OTHER SIDE OLD00R FH 200MthSCRIPTION 200MNO. FIEFZONE FIR! RAZARD FIRB DSTION 000R 1 FIs3 ZOVE RT# # FIRE H2O I DSTION SFCD B14. !!0' 6* Corr.
82 SB8 Mdia 33sinutes8 S-27 fad MFFL60sintes l
l l
1
- The firc loading calculations excludes all combustibles which are enveloped with one hour barrier.
l 1
l I
l l
l i
i l
PAGE 2 OF 5 lL ----------
- W p.SO O
Gg g
a %.
a
.cf.9
-L& m-.'-
o W [ Y 2..\\
- 1. ci
's, Y
~
w W.s
. e,
- v.,..
r-g
,g b '(
'g
[b
- g;W-ml-&- 1:n;1 ~ 5.':' g] ) ~ $l ~_*,?,.L h,
%,\\,
l
- ~g,.
f.
l
,.. =.., a, a; l
m g
fi W.A 1
i $so'
)
_g_.
_,t.
hc.~,- U g
/,..a % [ p___.
N4s"s9gG g6. 3, _sA,,el._5;psrj u%p 1.
-~
j i
s s
q q ja...
p:i
- 3.,
< w-s
.f:.-w_
j_"-r i
.c-r%
.N g
\\ '.e.
< ;ae.:.>.. 5 i?
.3,.
v=r
- ;- y? p' ' y C /
-- / r ' B D R
_. D I ' ".h:^4 ll
^
/ Ap,~
hq
's A,Q.,%. %e.,. :4,.,. D' sh f
=-= ! r a n-r.v, O. y' N\\ '. Mi, h[
T-h...g-
% )~
i m,. w,,, --,3. y k v.w.,'>,4.:
G
- w ----
- .s&. Ta~ "%"{ 'p cr.-
p.i u
,4 gC m-
~
3 n.y - Q.,r;f y 0.
. /'
.zg/ }'s,g%
/
e
_w
- di h
b l,i o
' !,l x b..y e 7:susN+@
~
e.e w
.. sSW ff
~.% Wg,a$$
ga E R.,c 3 h,
~ MME
-2,,.
,.. i::
in we i
J med
-v
' Ia'l ii y ;,I.sj p f e 9 N ha m -
1 14l p
@z..w?'=.g w-lQ'M
)
t 1
> a w m~g
,e
-@JE~
A 4, K
mer-g*.. " =
n i
i
, e -
b'.; w M n'Q'&c=.:.@f ', .d.iSN,g.d' ff; <ti'M1"% 4f; {~
- .,i
. E. __-<k 5 l u ? c'*' - NL ik 8 m me -e .; m it. e c v.@ _ildeturf ne 1 ry d p 3. ffg..p%g "I %,~W agh ~.[,g!'p,x j L' tt . - - -y l gp h]ejl'pd W h-Il 0-h d /a:.o 4 11hl. i 4l %): + Lu;, 13Mp.. .l;$p]h}lg I e i ,v 1 ,c< 'y s
- llhnf, (
- u].
.f N '. > j ),' E t ,k - A f -l (D l{ N I lh j .a x \\v@ ' .b M,. t p .-+- I, [T.i]E.+i o 3 Y; in FFU] '38 " ' d.. . 35m., . sac,.s a .., 41s Q:-- 1 __-.h
- N..
g y ...lh.,..... k . a g i. e_ r,, L l e. r- - q, t D iib 'C /c3rifiunw se W/iwi.s thsis.r,ux, 8serie:e .b$c72N $ PAGE 3 0F 5 fgg ,e g 3
F 16 0 6*/ Al g 144' (tt'.o) JAub 4%9'n _._d I 191 Y 66"Ik) Oot OMP3d 5 2 l J 'f '.v _ _[ ; i ,.____.____.__-----_.____..._._____..______.3 ml" t. I T l l1 q._ 4_ y-.g. A.T 2 o 4 I f.'._#4.:...i. 4 ep .. m._ e 4-l l I ll . b-9 C l i s l h b o I l ;, 2 4 3 v I i W I l 3 i 7 $ f i l l i Y n Iu e <4 s 1 n < -1 I i e i rs 9 h l i f o. i 1 n i = -0.e I N 1 .1 i 8 9 i w j o l1 G I z I i l i i
- e. % _ L _.
l i L 'l i i ,l g 0 l )., N 0 -O_p i ,i .= o di f 0 ) a I I l ________J ,of(_,;_;---.jL- ___ ____.o__ l 1, Wbopn.i Eau M1ar Daaz 1 ~(:rn=na d & a s.a n d 1 1 EdcrtW $ .f/4. E as.5 i PAGE 4 0F 5 L---
5 30 5 ftNd ,Y A------I ll .................----t - C i h" h ; iT '~ ] jo." r-di [ 'l i. e
- .i
-4
- t !
4,. '-z Wr - .J' --4 h .i-r : i, f?5%) :@ ,1. t---.- <.,y*~f!Ry# @ 'y '~ @h, # l! ( .wm' %ds. $ ['
- l h....
..,..a >,1 I. i i v g-j g Gm43 fl:"k @t;sst@3 i L L,_ ' j 1-47 i g 3 l -- o ; <4 .li;'I,g i.o -! i oif ; ! s ,,t W .. ~ - t *,j yl I l l 1 } i i .~ i.. s i g -.3-_. L P [;..,g ., -- g v',.. ?,,, n e l .W I k E = or ) O"' O yt e.g l s r-i. ? l l l 3,- ( i t T*l v ' N q e ,p I o ,73 h. h==5 l l @? 4 3 3 L ,, - F,,, V 2 pk: ,/ )t; 1 y
- ; D.
p-- s p --U4 > g.. { h, s s \\
=
7.- ) ,~4 w e.-. l 7 y /. i ,/ e a b /[ ',N.g 4 )( 4 ) ( 4 --_-Jp-f) .Ng: @sy ) u u _ _ _ -p[- j - ~ hN:* %/, s N ,n,Ny 4_ _- v_.2 'f @) k-l ~
- gi
- ~ ' - j i 6 gy (/ x %,p, _ V/ // g l I g 'g %s. Cu v.& O 8 w -q i, a n- - . -e [j l ^ h! j r j r.LHS / . 9,p ~ = at sai3>is ,,, e' i - l
7 l i Deviation 3c-1 i
Subject:
Control Room Missile Door (
- j Location:
Building Electrical & Control Elevation 830 Room 135 Fire Area EO Fire Zone 65 f Col. N-S AA E-W 5-A 1 Reference Drawings: FHA 16; FHA 26; Overly QB164, sheets 6 thru 9; and l 2323 Al-0504, July 26, 1983 submittal item 3c l 3 Exception: Appendix A to BTP APCSB 9.5-1, Section D.1.j. l i l l
== Description:== ) The control room missile door in the west wall is not a three hour rated fire door. This wall separates corridor room 140 and the j l turbine deck. 1 The door is a single swing 4 1/2" thick solid steel structure mounted l in a 6" door jamb embedded in a 30" reinforced concrete wall. The door opens to the turbine deck at the 830'-0" elevation. The fixed combustible loading in the area of the door is non-existent for j a distance exceeding 100 feet. Only transient combustibles will be ] passing through this area. { A thermal and structural evaluation of the door indicated it would experience deformation from thermal growth and potential failure of the door jamb welds, but would remain in place during postulated ASTM E-119 "E" curve fire conditions. In actuality, the fact that the turbine deck is open to the atmosphere and lacks fixed combustible loading in the area of the missile door prevents such a fire from occurring. PAGE 1 0F 3
1 l l Deviation 3c-1 { Justification: 1. The door is installed in an exterior wall of the control room opening to the turbine deck which is void of fixed combustibles for a minimum of 100 feet and is an open air space. 2. The fixed combustibles (lubricating and concrol oil) on the turbine deck are contained within metal enclosures for the 1 turbines a distance of 125 feet from the missile door. l 3. A fire hose house with a 2 1/2" wet standpipe is located within 50 i fee t of the door. Others are located throughout the turbine deck l area. Fire extinguishers, hand-held and a 150 pound wheeled unit, are located near the door and throughout the turbine deck area. I 4. Evaluations indicate that the missile door will provide adequate j protection for the control room from a fire on the turbine deck for a period of time in excess of the burn time for the actual combustible loading (fixed and transient) for the area. 5. The design of the door ensures the door will remain standing in place under severe fire conditions and provides a tortuous path which a fire has to propagate. 6. The door is a 4 1/2" solid steel structure mounted in a 6" deep door jamb embedded in the outer surface of a 30" reinforced concrete wall. 7. The door seals against a steel frame that is poured into wall with reinforcement ties. 8. Transient combustibles in this area consist of small quantities of 1 flammable materials in transit from one location to another. l 9. The doorway is 24" deep and void of combustible materials and I there is no combustible loading in the corridor of the control room (east side of the door).
- 10. The control room has an area wide early warning smoke detection system installed for assuring early detection and response by the plant fire brigade ensuring early fire extinguishment.
l
- 11. A loss of the control room due to a iire will not prevent a safe shutdown of the plant because the shutdown can be performed by alternate shutdown.
l l PAGE 2 0F 3 A
F' l Description i i
- 12. Manual suppression is available in the control room utilizing hose stations, portable extinguishers and fire hydrants.
- 13. Based on the thermal and structural evaluation,. size and design of the door, and lack of combustibles in the vicinity of the door this door meets the intent of BTP APCSB 9.5-1, Appendix A and j
i provides an adequate level of fire safety. i J l I l l l 1 PAGE 3 0F 3 l-
E j Deviation 3d Slides View Location Bldg. Safenuard l Elev. Spe Attached Table 3d l Room See Attached Table 3d l l F.A. See Attached Table 3d l Col. N-S Systems Path A Path B i E-W I Reference Drawings: Overly Drawing Q7068X2, Sheets 1 - 4 7068 , Sheets 1 105 2323-Al-0540 FHA-2 l FHA-4 l FRA-5 l Exception: BTP APCSB 9.5-1 Appendix A, Section D.1.j l
== Description:== Watertight doors are installed in fire barriers, but are not a fire tested construction. Justification: 1. Doors are of substantial construction and will not l degrade the integrity of the fire barrier. Dogs l hold the doors closed on three sides. Seals are l constructed of RTV Silicone elastomer materials, similar to elastomers used in penetration seal construction. 2. Automatic water sprinkler coverage is provided in areas of high exposure hazard, and other areas per Table 3d. Hose stations and portable extinguishers are available. 3. Combustible loading for each fire zone is per l Table 3d, 1 4. Primary design criteria is containment of internal flood water to prevent damage to redundant essential equipment and systems. PACE 1 OF 2
TABLE 3.d WA"'ilflG!TD0 ORS l l \\ l l Fila 200M FIhE ECNE EB3"RIPfl0W EAIAD DUEATION D002 PROTECION FIEE ZONE R30M IES*EIPfl0N HAIAE Dt'EATION PETECTf0N l l i 84 S010: DieselGenera;or High 194sinutes S-28 Sprinkler / SDS 83 train A Switetgear Medius 34 sinutes Cable fray l Roostrain-A MPFL180 Detection Electrical @FL60 Sprinklerl l sinutes Equipent Boca sinutes Detection l l l l l l l 2 85 Silla DieselGenerator Hige 196sinutes S 16 Sprinkler / SD9 83 train A Svitetgear Medius 34 siretes Cable fray l l bcs train A & B EFL180 Detection Electrical KFFL(0 Sprinkler / l sinutes Equipsent bcs tinutes Detection l l 1 l 4 100A fil7a Light Feedwater Low 10sinutes 'f60Sprirl!er/ SE48 103 Electrical Light 16 sinutes Sprir.kler/ l PipePenetration MPFL 60 Detection Equipent kes NFFL 60 Detection ; sinutes sinutes l l l l $ 110 Sil7b MainSteas Lew Isinute S-40B Sprinkler / SFl9 107 FilterStorage Low I sinute Sprir.kler/ l PenetrationArea M?PL60 Detect;en Area MPFL90 Detection l sinutes sinutes l l l l 5 IM SE:'c WanSten Lcw Isinute S4r!;ritklerl SW!5! 108a Stairway Low Negligitle Fetetra'.:enAres KFFL60 Nie:ti:r, sinutes EFL!!0 l sinutes l l l IWegligiblefireseverity,lessthanIsinute. ) l I l PAGE 2 0F 2
Deviation 3e
Subject:
Containment Air-Locks i Location: I Building Containant/Safemiac.Q - Elevation Ste Attar;hed Room Sie 1eeacbed l Fire Area $3 _$h'. CA ._a_ Fire Zone See J.3LSched Col. N-S j E-W l l i Reference Drawings; ) l CB&I: 74 2427-236-4, 74-2427-110-4, 74-2427-200-2 l CB&I Figures: El, E3, E4, P1' l FHA-3, FHA 6 ] ) l { El 2022, El 2024 t 't 1 Exception: BTP APCSB 9.5-1 Appendix A, Secqb n.D.l.j l s 4 .\\ t
== Description:== i j s. The perAon.tel and emergency AirbrN fc{ containment are not4 fire ^ rated construction. g l Jus tificat.t on : -( l 'l. Hutch corvstruction is substantial with 5 0 :.ti-el GSorp> on either 9 , end of the air lock assembly separaceClef sim,than 17 ' feet. \\- ic, s 2. Detection is available in Fire Zone. SB15 and 5720 in the l j 'Jafeguards siip In contai:vnent, $ dea (de detection is provided l g in Fire Zone CA101d, and in the 7;,fa'QAlMg whfeb Jis adjacert to. l C ( 'l, il s ] kire Zone CA101h. { i [ ) i 6 at j s-E' i 3. The primary design function c,f the afz-locks ~ is 99 mipf.raize che leakage of containment atmosphere. i ( g Manua'r suppte.ssion is availaAe uQdzing botbycsn stadicq gnd 4. portable extippishet's'. Hose coverage fqr Fire Zone SF20.is~ l available; by utilizing station CF1-FPFESH-19, in Fire Zone SF19,, l and additional hose suppif ad by the EN)Prigado. l s l k$ i. [ '., T ~ j s' ?? L - f i [ V l i i i i S q l tt i t i s i E 4 s ) 1 I PAGE 1 03 i\\ n gp s 't l E
Deviation 3e 5. The design and construction of the hatch provide an equivalent 1cvel of protection te the requirements of BTP APCSB 9.5-1. [ 6. See Table 3e for fire severities and maximum permissible fire l l loadings. l l ? PAGE 2 0F 5 i
- \\
t
TABLE 3e FIEE DVPJ. TION FIRE DUEATION FTA OCN 20E DESCRIPTION HAZAE IMIN.) PETECTION HATCH BOOM ZONE DESCRIPfl0N HAZAD (MIW.) Pft0iECTION 2 95 SB15 Personnel Catles/ 19 Sprinklers / Perrontiel 155A CA10ld Containment Cables 8 Thernal l Aireck Transient MPFL 60 HoseStaf Aireck Detector l Access LubeOil sinutes HMP/ Ion Elev832 P.MP/Pcrt l Corridor Detection Exting. l l 6 111 SP29 Energency tresient EPE Fergency 150 CA101hContaitsett BadWaste 1 1 !!reck Negligible HP/ Ion Aireck Ccapactor I!PE l Auss MPFL90 Detection Elev90 sinutes l l 3 TheMPFLforcontainnentisthecombustibleleadingduringoperationand180sinutesduringoutages. $14 l
- 1. EMP Hand held portable sulti-purpose fire extinguisher
- 2. HP - Hand held halon fire ertiteisher
- 3. HPK - Hand held purple E fire extinguisher I
1 f i ) I i F AGE 3 OF 5 l 1 l l
l Ik 8 }5 MI ) w gm 1 'x s R3 [,R j N, 18
- g wk
~ UE"* i \\ \\ 5 e __ _N Ii .i8 a N 1 ) \\ RV 3 ~',# (G 2 4 'N N-i s \\\\I l I 5 r 's = \\ ';O
- e' E
I i ss 0 '(s ) '3 '$r j +r ~;, 5 \\ j s4 u E h Q Y s s i ( E 4 L PAGE 4 0F 5
&c g vE A eD ,r M g sN g o/ 3 CT /a4l C o Yl I p yY W 5, T M I IL ) o c i N )0 P (2 E O 5 i e E s V o m4 n L )s r CO s N t I R 0 x L a t s U E r s A D u A c Rx cr R Du e Y w E o i L o Hc r a s E t r C r E 2 u D s t S W ? b ~ Nt,s y Q' ,p A k d y ~# i \\ &q(q \\ i i ' 4 l h N \\ m 4W )9 s 'N ( S R . l/ A E c 0 g V s 7 x e o , / ? t n V a A e o n ~% n l A H \\ .w ,I\\ IQ f / h f. 1, b %g' h/f " ^ j rh r ro ' 'N N N \\ )4 O) 2 s2 ) / 1 At (e ( R( Ni 5 sf tM nV ts pC rE or 9 ,oL i r A c W Y0 - rV v 1 oe cl eS R7 ntD a A pv o! A u ot Trm f_aw N J pd h
Deviation 3e Subj ect: Containment Mechanical Penetration Seals Location: Building See Attached Elevation See Attached Room See Attached Fire Area SB. SA. SK. CA Fire Zone See Attached Col. N S I E-W Reference Drawings: 2323-M1 0502, 2323-M1-0503, 2323-M1-0503-01, 2'23-M1-0522, FHA-1, l ) l FEA-2, FHA-3, FHA-4, FMA-5, and FHA-22. l i Exception: Appendix A Section D.1.J l
== Description:== 1 l The mechanical penetration seals used as retention pressure boundary f seals are not three hour rated seals by ASTM-E-119 testing. ] Justification: 1 1, Mechanical penetration seals are designed for containment of the atmosphere inside the containment building following a Design Basis Accident inside this building. 2. These penetration assemblies are manufactured of welded ferrous metal alloy. One assembly contains tubing carrying a small quantity of high purity silicone oil used in a pressure sensor. 3. ionization, thermistor strip or UV fire detection devices ate provided in all fire zones on both sides of the seal. l l 4. The construction of these penetration assemblies exceeds the requirements for fire rating of the penetration seals and does not degrade the safety function of the containment walls or fire barriers. 4 PAGE 10F 4
Deviation 3g 5. Most of the penetra'tions are process pipe systems supplying containment. Also involved are the fuel transfer tube and HVAC penetrations. 6. The containment mechanical penetration seals provide a barrier with an equivalent level of protection as required by Appendix R Section III.G.2. 7. See Table 3g for fire severities and maximum permissible fire l loadings in the Fire Zones of concern, l l l l l I PAGE 2 0F 4 .m__ _. _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ -
j 1 I 1 LEVIATION3g TABLE 31 FIREDURATION(MIN.)/ N0.OF l BUILD:N1 B%M FIRE 20WE HA1AE MFFL(HIN.} SYSTEMS PENETRATIONS l l i l I Safeguard 65 SB2e Cables 8/60 RHR 2 l j l i Contaltaett 154 CA10lb Cables /L.0. 26/8 RCP,RHR l l l l i l I Safeguard 63 Sale Cables 11/60 RER 2 l l Contaiteent 154 CA10lb Cables /L.0, 26/1 RCP,RHB l l I Safeguard 77 SB143 Cables 8/60 CVCS,CCW 22 l j l l Contaitsent 154 CA10lb Cables /L.0. 26/1 BCP,RER l ) l l l Safeguard 77 S A'.42 Cables 17/60 CVCS,CCW 20 l l l Contaitsent 154 CA10lb Catles/L.0, 26/8 BCP,RHR l l l 1 l Safeguard 88 SB144 Cables 10/60 CCW 27 j l 1 Centaitsent 155A CA10ld Cables /L.0. 26/1 RrTrip l j ) l l Safeguard 100A SE17a Catles 10/60 FW 8 l l l I Contaitsent 155A CA10lf Cables 26/8 FW l l l t Safeguad 10s SKlib HydFluid 1/60 M: 4 l Ccttaitaent 155a CA10!g Cables 26/8 l l l l Fuel 272 AA99e Cables / transients 3/f0 fuelHandling 2 l and l 4 Containment 155A CA10lb Cables 26/t AirHandling l l l l l PAGE 3 OF 4
l J l i DEVIATION 3g TABLE 3.g FIREDL%ATION(MIN.1/ l B'J!LDING EXM FIEEZONE EAZARD MPFL (MIN.) SYSTEMS
- 10. OF PENETRAt!0NS l
l Aniliary 244 AA39 Charcoal 8/60 Air 2 l Filters Bandling l l l i contaitnect 155A CA10lg Cables 26/8 Air l 1 Handling l l I l l l Aniliary 246 AA40 Charcoal 8/60 Air 2 l Filters Bandling l l Containment 155A CA10lg Cables 26/8 Air l Handling l l I the MPFL fcr Cct.tainunt is :he ccabustible leaditg durir.1 cperation and 180 air.ates daring outages. I I J I l l l l l l l l PAGE 4 OF 4 1
I 1 l Deviation 3h
Subject:
Cable Spreading Room BR-PR Door i LOCATION: Building Electric and Control Elevation 810"-6" ) Rooms 133. 25 j Fire Area EN. TA I Fire Zone
- 64. 111 Reference Drawings:
FRA-15; FHA-27; Architectural Control System l Incorporated Manual No. 501210 4001-1, Operations { l Manual Auto Release Tornado Venting Door P/N [ 501210-3001 4. l l Exception: BTP APCSB 9.5-1 Appendix A, D.l.j
== Description:== The Bullet Resistant Penetration Resistant (BR PR) door to the Unit 1 cable spread rcom (CSR) is located in the south wall of the EN Fire Area Boundary. It provides access to the East-West corridor in Fire Area TA. The combustible loading in the corridor consists primarily of transient combustibles. The corridor contains the Halon system for the Unit 1 CSR. 1 The BR-PR door is a triple function special purpose door. It is designed to provide security, tornado venting, and. fire resistance. In the standard security mode, the door is secure until a card is inserted in the reader. This_ signal from the reader 1 initiates a time cycle in a switch causing the latches to release. When the timer completes its cycle, approximately 5 seconds, the electronics will attempt to resecure the latches. The magnetic reed switch must sense that the door is in the jam. When this occurs, a door position hold-off timer delays the'recircuitry of the latches by approximately 1 second to allow rebound energy to dissipate. Egress is accomplished by depressing the paddle and relearing the latch. In the card reader or system failure mode egress can be achieved via mechanical key override. If the system failure mode is such that pneumatic assist is not available, the key i r PAGE 1 0F 5
Deviation 3h cylinder directly retracts the latches. Card reader failure and some systems failure modes provide pneumatic assist to the cylinder override. This function is initiated by a switch operating off of the key cylinder. Egress is as above. In the tornado event mode-no fire, a differential pressure switch is provided and if the contacts open, the Tcrnado Event Mode is initiated, causing the latches to retract. The system latches in this mode and must be manually reset via Tornado Event Reset Switch. In addition the Pneumatic Tornado Event Hold-Open Cylinder will begin to charge with 25 PSIG air supply. The door will be held open the first few seconds by the escaping air caused by the pressure differential. Within those few seconds, the cylinder charges fully, supplying the necessary force to hold the door fully j extended. When the reset switch is actuated, this cylinder exhausts allowing the door to close. The Fire Mode overrides all other operating modes and failure modes. In the event of fire, the following events occur. Removal of Fire Alarm System Power causes a relay to de-energize immediately removing all power including battery back-up control circuitry. This causes the latches to remain extended. In addition, removal of power causes a fire dump solenoid to de-energize, exhausting all reserve air. \\ LATCHING MECHANISM The assembly consists of two pneumatically operated, modified l Sargent 12-9800 series panic devices. It contains, under the removable cover, the following compone.nts. 1 EMERGENCY FIRE DUMP SOLENOID VALVES f There valves interface directly with and receive power from the facility fire alarm system. These valves are powered at .all times, except in the event of fire, by 24VAC or 24VDC, Whea power is removed, the reserve air is exhausted causing the latching assembly to latch, regardless of any signals from other controllers. AIR RESERVOIRS These provide air at the latch to prevent pressure starvation between the latching device and the control panel, i l l l PAGE 2 0F 5
i I Deviation 3h INLET SOLEN 0ID VALVES These valves are parallel redundant. If either fails to function when energized, the system will still function. These valves are closed to air flow until energized. l EXHAUST SOLENOID VALVES These valves are series redundant. If either fails to function when energized, the system will still function. These valves are open to air flow until energized. AIR CYLINDERS Air cylinders are coupled to the latches and cause retraction when air is applied, q ( l KEY SWITCH The key switch is used to trigger the system to provide pneumatic assist when the mechanical key entry is used, j DOOR POSITION SENSOR This switch, when aligned with the magnet on the strike assembly, initiates an enatle signal to the electronic circuit j l to enable relatching of the assembly. The door control mechanism is composed of the following components: Redundant power supplier, UPS battery backup, air pressure loss detection, automatic relocking, door position hold off mechanism, card reader switching mechanism, tornado vent relay system and fire drop relay. FIRE DROP RELAY This rolay is powered by the Fire Alarm System and is energized except in the event of fire. " Fire conditten" de-energize and disconnects all power l' rom the circuits - putting the system into the latch mode. s PAGE 3 0F 5
a l EMERGENCY FIRE CONTROLLER RESERVE AIR DUMP l This enclosure is located in a separate fire area and contains a check valve that will pass air into this unit from the supply line, but not out of this unit into the supply line. In addition, it contains a fire dump Solenoid valve which is powered by the Fire Alarm System. In the event of fire, the { valve exhausts all air from the reserve air tank, preventing j the latches from retracting. l The door is a 3' 0" X 7'-0", 2 1/2" thick single swing hollow metal design constructed of 1/14" armored steel plate. The frames are constructed of j C-6 channel iron anchored with Hilti Kwik bolts to a structural concrete wall and grouted in place with a non-shrink grout. The door procured in 1980 does not exhibit a UL label although it is of labeled construction similar to a subsequent UL test File R9271-3 Project 80NK 20580 dated July 15, 1981. The door was tested utilizing a mortice type lock instead of the 1 rim latch device used at CPSES to achieve the triple function capability. l The latch utilized as described above (Sargent 12-9800 series) is a fire I and panic exit device. I i i I i PACE 4 0F 5
1 I I Deviation 3h Justification: J 1. The door is a multi purpose design providing protection for security, tornado and fire criteria. No tested designs are available meeting all three criteria. i 2. The door is of a construction similar to subsequent UL tests with the exception of the latching mechanism. I 4 3. The latching mechanism is a modified UL F listed rim lock device required to meet design criteria other than Fire Protection. The modifications to the device are limited to the unlatching hardware l I that is overridden by fire protection controls. 4. Ionization detection is available on both sides of the door, providing early warning and rapid response by the fire brigade to any fires in this corridor. Manual suppression is available using hose stations, l ] manual pre-action sprinklers inside the Cable Spread Room, and portable extinguishers. 5. Automatic Halon total flooding suppression is available in the Cable j Spread Room. j 6. The combustible loading in the corridor is light with a fire severity l of 27 minutes and a maximum permissible fire loading of 60 minutes. 1 7. The corridor fire area contains no redundant essential equipment, cables, or components. 8. Alternate shutdown is available independent of a fire in the Cable Spread Room. PAGE 5 0F 5
i Deviation 4a Slides View I Location 4b-1_ Looking North 4b-2 Looking Northeast Bldg. Containment Elev. 905 Room 161A F.A. CA101h l 1 Col. N S Systems Path A PCV-445A, HV-1-8000A, E-W 8010A i Path B PCV-456,HV-1-8000B, 8010B l Reference Drawings: FHA-5 Alison Controls - 52105D (Sheet 10 of 13) Deviation: Appendix R to 10CFR50 Section III.G.2.d l
== Description:== Redundant essential relief and isolation valves for l pressurizer control are located within the same compartment and within 20 feet inside the containment building. Justification: 1. A negligible amount of combustible material l exists in the roora. l 2. Administrative controls will be implemented to { ensure that transient combustibles are removed from this particular location prior to power operations. 3. Due to the nature of the pressurizer compartment its location within the containment, and ] restricted access, control of combustibles is considered feasible as protection of the' equipment from j a damaging fire. j i i l l PAGE 1 OF 1
') I I Deviation 4a-1 Location: Bldg. Containment Elev. 812'-0" Room 154 RCS Loons 1 & 4 i Steam Generator Compartment F.A. CA101e Co.N-S E-V Reference Drawings: FHA-2 Deviation: Appendix R to 10CFR50 Section III.G.2.d
== Description:== Residual Heat Removal Loops 1 and 2 are located on the 808' 0" elevation, in the Containment Building. Inlet isolation motor i 4 operated valves 1-8701A, 1-8702A, 1-8701B and 1-8702B are control valves essential to safe shutdown. Valves 1-8702A and I 1-8702B are located in the steam generator 1 and 4 compartment Fire Zone 101C while valves 1 8701A & 1-8701B are located in the corridor outside of the steam generator compartments in Fire Zone 10lb. Valves 1-8701A and 1 8701B are separated by more than 20 feet with intervening combustibles. Three cable trays constitute the intervening combustibles; however, none of the trays transcend the space between the valves. A partial barrier is located between redundant essential inlet isolation motor operated valves (1 8702A and 1-8702B) for residual heat removal loops 1 6 2. The valves are located approximately five feet above the floor and are spatially separated seven feet apart center to center. The partial l barrier does not provide physical separation between the redundant valve bodies. The control circuits for the ] motorized valve operating mechanisms, as well as the motorized I valve operating mechanisms themselves, are located above the l valves, and are separated by a three foot thick barrier which extends from the top of the valves at approximately the 819' elevation to the 832' elevation, separating the operating mechanisms and redundant circuits. l l I 1 l PAGE 1 OF 6 i \\ .i )
i l J Deviation 4a-1 Justification: 1. Confleuration - Valves 1-8701A and 1-8701B are located well in excess of 20 feet apart. The distance separating the valves eliminates the hazard of a fire under either valve impinging on the other valve. The partial barrier separating valves 1-8702A and 18702B is a three foot thick reinforced concrete wall. The barrier separates redundant components so that radiant energy from a fire involving the motorized valve operating mechanisms and control circuits of one train would not degrade or ignite components of the l other train. The barrier also directs the convective energy from the fire away from the surviving train of l components. j 1 The floor in the compartment is slightly sloped j toward the doorways mitigating the accumulation of l I fluids beneath the valves. 2. Combustibles - Between valves 1-8701A and 1-8701B there are 3 cable trays. One cable tray is full and extends from the vicinity of 1 8701A to a point 12 feet short of 1-8701B. Another cable tray is approximately 10% full and spans from the vicinity of 1-8701A to a point 12 feet short of 1-8701B. The last tray is located between the valves and does not extend to either of them (see attached diagram). Since no tray is closer than 12 feet to the train B valve, a fire in the area disabling both valves is highly unlikely. The combustible loading for fire area CA is 34,200 BTU /Sq.Ft. This is approximately equal to a 26 minute fire duration. However, this is not a realistic representation of the possible fire that could occur in containment. There are no insitu combustibles in the room housing valves 1-8702A and 18702B with the exception of lubricating oil in the reactor coolant pumps. The reactor coolant pumps are 1ccated at opposite ends of the compartment near the doorways more than 10' from the valves. A reactor coolant pump oil collection system is installed per the requirements of PAGE 2 0F 6
~ Deviation 4a-1 regulatory guide 1.29 paragraph C.2. The reactor coolant pump oil collection system provides control for a postulated reactor coolant pump oti spill. Both sets of valves are located in a high radiation area where transient combustibles are administrative 1y controlled consistent with utility policies for minimizing radioactive waste materials. 3, Ignition Sources - Fixed ignition sources in Fire Zones CA10lb, CA101c are limited to electrical faults. Transient ignition sources are minimized by administrative controls. l 4. Protection - Fire Zones CA10lb end CA101c are provided with area wide thermistor strip detection which alerts the control room for prompt emergency response. Summary: Based on the above justifications redundant component's operability will not be affected by a fire in the area. l l l 1 PAGE 3 0F 6
i / / /. T12DRBK05 T120RBK01 q / ,/ 'l g.g* \\ , 4 '-0* g l l 7 ~ y -0* 5 1-8701E 1-0701A - p 42'-O' 7 / CDNDUIT W n I T13QRC104 T13GRC102 & B B 4 j VfffY $lffh RHR LOOP 1 ~ RHR LDDP 2 -NONESSENTIAL 1-0702A w 1-6702B V;? s f' \\ \\ j \\ '-8' (TYP) 3'~ 3' - ESSENTIAL ESSENTIAL p; -; // ^ A AA ^ l &~rf~>3Tf////gg ) 1 yp9%V& ~ 1 3 l CONTAINMENT FA CA 101c j ELEVATIDN 812'-O' i PAGE 4 0F 6 yTM 1 JHT.1 l
1 i l l SECTION A-A I 1 ) \\ ? / -['. /l/-l/'. /.l /- ,/. /. } l . I '. /. ./*. ., /.,/ ../. i /.' /. // /' CONDUI1 S CONDUITS })/ / .. /.,./, 1-8702B i 1-8702A /) / i' i s
- //,.
63 /MM c6 YY [T)^ (Q W CONDUIT NONESSENTIAL l 6'-10' FLOOR ELEV 812'-O' f ^^ / CONTAINMENT F.A. CA 101c ELEVATION 812'-O' SKETCH 40-1 SHT. 2 NOT TO SCALE PAGE 5 0F 6
i i a i SECTION B-B j i i \\ N i \\ N 1 B.O.C. r - T120RBK05 T120RBK01 4 '-6' l k, S j i 7 V ) n n v T13QRCIO2 / / 9'-O' ) T13QRC102 / / / / 12'-D' i 18'-O' 'TYP.) / ./ ~ T13QRCIO4 / 15'-O' / / / 1-8701A 1-8701B l i I 1 9 '- O' f y 4 2'-O' d. ( 7 / FLDDR ELEV 808'-0* i CONTAINMENT F.A. CA 101c. ELEVATION 808'-0' SKETCH 4a-1' SHT. 3 NOT TO SCALE-PAGE 6 0F 6- . - _ = _ _ _ _ _ _ _ _
Deviation 5a Slides View Location Bldg. E&C Elev. 830. 807 Room 133. 135. 147 F.A. EN64.E065.E069 Col. N-S Systems Path A E-W Path B Reference Drawings: E-81388-3 E-81388-5 Exception: Appendix A to BTP APCSB 9.5-1, Section D 3.f l l
== Description:== Non IEEE 383 cable is installed in the ERF Computer System. Justification: 1. The fire hazard impact is of a minor nature with 10 cable runs totalling 450 feet of cable installed in the Control room, cable spread room, and computer room to link { the ERF computer. 2. Cable is constructed of 6 each 22 gauge conductors insulated with.010 inches of polypropylene and jacketed by .045 inches of PVC. l 3. Tre rooms through which Non.IEEE 383 cables travel are Control Room (Fire Zone 65) with hand held Halon and water extinguishers, Cable Spread Room (Fire Zone 64) with fixed automatic Halon System and Fixed Water Suppression System, and Computer Room (Fire Zone 69) with an automatic Halon System. 4. A low impendance cable is required to meet NRC data transfer rates. No IEEE 383 cable construction providing the impendance values required was available. S. If cable spread room and control room are affected by a fire, alternate shutdown is achievable from the Alternate Shutdown Panel. PAGE 1 0F'l
Deviation 8b 4. The combustibles at elevation 810 do not present a significant hazard I to the MCC's over 20 feet above these cables because rising hot gases l will be cooled by the volume of air available and automatic sprinkler l suppression is installed at all three elevations, j 5. The MCC's are protected from water suppression actuation by the sealing of all conduits entering the top and by the addition of spray deflectors to the lower level sprinkler heads in the immediate vicinity of the MCC's. 6. Area wide early warning ionization smoke detectors are provided to ensure immediate fire brigade response and quick suppression activities. 7. The elimination of intervening combustibles, that present a hazard to the MCC's and the provision of automatic and manual suppression systems provides l an equivalent level of protection to that of the requirements of Appendix R.III.G.2. I l PACE 2 0F 2 a___--_________
Deviation 10 Subj ec t: Control Room Lighting 1 Location: 1 Building: Electrical & Control l Elevation: 830-0 Room: 135 l Fire Area: EO ] Fire Zone: 65 l Col. N-S E-W 1 l Reference Drawings: FRA-16 l 1 Deviation: Appendix R to 10CFR50, Section III.J
== Description:== The control room does not contain 8 hour battery pack powered emergency lighting. l Justification: 1. The Control Room lighting is provided independently of off-site l power from the combination of the 120V AC Essential Lighting train, l I powered by separate diesel generators, and/or the 125V DC Emergency l I Lighting Trains powered by the 1E station batteries. CPSES provides l an adequate illuminance level for Control Room operation under the i following conditions: l If the diesel generators are inoperative, both 125V DC Emergency l a. Lighting Trains adequately illuminate the Control Panel for a l cycle of 4 hours. This situation occurs to compensate for the l delayed response (automatic activation: 10 sec; manual activa-l tion: 7 minutes.) of the diesel generators to provide AC lighting. l In other words, as stated in FSAR 9.5.3.2.1, p. 9.5-139, paragraph l 2, the DC Emergency Lights are normally deenergized and are acti-l vated by the loss of power to the AC Lighting Systems. l { PAGE 1 0F 2 1
Deviation 10 Justifications (Continued) b. For loss of Train A Essential power, the Train A 125 V DC [. Emergency Lighting and Train B AC Essential Lighting provide l adequate illumination. l For loss of Train B Essential power, the Train B 125V DC l c. Emergency Lighting and Train A provide adequate illumination l of AC Essential Lightin&- I d. For loss of one train of DC Emergency Lighting concurrent l l with a loss of off-site power, the opposite train will pro-l vide some level of illumination for 10 seconds until both j trains of AC Essential Lighting are available although no [ no level is required per the recommendations of the ISE l Handbook. 2. Provisions have been made to ensure that adequate lighting is l provided in the Control Room in the event of a fire in one or l more of the following fire areas: AA, EA, EO or EN. Design l Modification Request 87-035 addresses the DC Emergency Lighting l power supply for the Control Room. A design has been generated tol replace the El Station battery supply of the DC Emergency l Lighting in the Control Room with two sets of batteries on the l Turbine deck. One set of batteries provides power for l I Unit 1 DC emergency lights (10fc) while the second set of l batteries supplies Unit 2 DC Emergency Lights (10fc). l Egress Lighting from the Control Room during an evacuation is l 1 provided by either Unit's DC Emergency Lighting. This addi-1 i tions is made to state the alternative design change and con-l { sideration which has.been evaluated to provide an adequate l Emergency Lighting System in the Control Room. l ) 3. Alternate shutdown is available independently of fires in the control room or cable spread room. 4. Loss of all four power systems is highly unlikely because of their sources. 5. Lighting equivalent to the requirements of Appendix R, III.J is provided for the control room. 3 I PAGE 2 0F 2 i
Deviation 14 Subj ect: Two Hour Rated Penetration Seals Location: Various Bldg. Various Elev: Various Room: Various Fire Area: Various Col N-S E-W 1 Reference Drawings: Penetration Seal Schedule l FSM 253 Sht. 28, Detail 31 l BISCO Fire Test 748-98 dated 5/18/83 Exception: BTP APCSB 9.5-1 Appendix A, Section D 1.j l
== Description:== Spare conduits were tested in accordance with ANI acceptance criteria and not ASTM E119. The seals tested performed through a three hour endurance test and hose stream, but the temperature limits of ASTM E119 were exceeded after two hours into the test. Justifications: 1. The spare conduit seal detail' performed for tro hours within acceptance criteria for temperature rise and also passed the hose stream test. 2. The combustible loading on either side of the penetration I seals in safe shutdown related areas is controlled by the I maximum permissible fire loading combustible control program. { l PAGE 1 0F 1
l l a d I i l i TECHNICAL JUSTIFICATION 1 I J l J
i i Technical Justification 1
Subject:
Radiant Energy Shields j i Location: Building: Containment Elevation: Various Room: 154. 155A Fire Area: CA i ) Fire Zone: 10lb. 101d i Reference Drawings: Specification 2323 MS-38H l' Procedure EEI-25 l One Hour Qualification Test Protective Envelopes for Class 1E l Electrical Circuits. (HEMYC Cable Tray and Conduit Wrap System). Rev. - May 25, 1982.
- i i
Deviation: Appendix R to 10CFR50, Section III.G.2.f l I
== Description:== ) ( Radiant energy shields installed at CPSES are constructed of B &' B 2 HEMYE system insulating blankets and marinite board. The insulating blankets are constructed with Siltemp on both sides and incorporate j 1 1/2" thick refractory wool blankets. All stitching used is of { Astroquartz sewing thread. The blankets are wrapped around and banded to the components being protected. Typical details and installation are in accordance with vendor approved procedures (reference 2). The single application of marinite board is placed flush over an embedded junction box. 1 The B & B HEMYE System qualified as a one hour rated barrier system l ) during tests when installed in two different configurations. The first l configuration involved wrapping a cable tray with 1 1/2" thick B & B and l 1eaving an air gap between the cable try and the B & B wrap. The second l l configuration involved wrapping conduit with 2" thick B & B. At CPSES l B & B is used in slightly different configurations. The cable trays l that are protected with B & B are wrapped tightly without an air gap l around them. Conduits at CPSES are protected with 1 1/2" B & B. Throughl f i PAGE 1 0F 2
rm p, 9 n \\ \\y. 5 .c ) t ,t '\\' ' j> e ,e ~,4 \\, l l l ~ Deviation _8.b_. l
Subject:
20 feet Sepatstion Criteria l t t Location: .; ) l Building: Atxiit sty - 1 Elevation: 852' Room: 241 Fire Area: AA. Fire Zone: 21f \\ h Reference Drawings: PHA 15, 16, 17; Critmr;11 Drawings 101, 103, 106, 150 l 2323-E1 0703, 2323-El-0710-12, 2323-El-0711 11, 2323-El-0702, l l. \\ 2323 Al-0509, 2323-Al-0510. Deviation: Appendix R w 10CFR50 Section III.G.2.t. l r t
== Description:== ( f i Redundant motor control centers for the. UPS ventila:dxn system are located in the same fire nrge, AA21f, on the 852' elevation in the Auxiliary Building. / / l 1 , 1-Separation of the Train 'A MCCs from Triin B redundant MCCs and raceways on elevation 852 ft. and from t'rie; remainder of (the hazards, associated w~ thin Fire Area,AA is achieved by the elimination of intervening combustibles and the protection of redandgnt lr Train B raceways'. The intervening combustibles arm comprised of ,1 exposed IEEE 383 cables transversing the corridors on elevation 852 ft. \\i and 830 ft. 1he only contributing fire propagative fathrj are openings T provided as equipment hat;ches and tornado ve.sts. 1 j 1 4 .( '), Justification: i ~ .? i 1. Suppression is installed in the corridcrOl'olow ';he MCC's at 810' ' 's ' l elevation and 832' elevation as well as'lNN4e'the MCC's in the
- I 852' elevation.
.) \\! 3 l' 1 2 2. Redundantessentialracewaysintheprotectionareaarewrahped. ij I ,\\ 3. The intervening comestibles above the MC0'ty and at the ( i N, l elevatlon immediately'below the MCC's are fire stopped to preven;," y '& l 1 the spread of a firt from one redundani WCC to the other. 2 Q '/ / \\q t v' ) j
- 4
'a k' r l \\ 6 ? j )(] FAM 1 0F 2 l3 i 3 9% i, (( 't Q l T l, -__-._--..._-_-.__-..-----___--_____-_.-_--.lL t ' ' ~J-[; g, } /> .A t u 'l - i;*
(- i i l l TJI i evaluation it was demonstrated that 1 1/2" B & B wrapped without l an air gap around cable trays performs better in a 1/2 hour ASTM E-119 l fire than 1 1/2" B & B with an air gap wrapped around cable trays per-l forms in a one hour ASTM E-119 fire. Thermal analysis also demonstrates l l that 1 1/2" B & B wrapped around conduit performs better in a 1/2 hour i i ASTM E-119 fire than 2" B & B wrapped around conduit in a one hour ASTM l ] l ( E-119 fire. 1 Protection provided at CPSES against the effects of radiant energy from an exposure fire is adequate to provide the level of fire safety required by Appendix R to 10CFR50 section III.G.2 for areas inside the Containment Building. I 1 l i 1 a l l i t i ci s PAGE 2 0F 2 . _ _ _ _ _ _ _ _ _ _ _ - _ - _ - - _ _}}