ML17354B017

Rev 1 to PTN-FPER-97-013, Evaluation of Turbine Lube Oil Fire.

ML17354B017
Person / Time
Site:	Turkey Point
Issue date:	06/29/1998
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17354B015	List: ML17354B014 ML17354B017
References
PTN-FPER-97-013, PTN-FPER-97-013-R01, PTN-FPER-97-13, PTN-FPER-97-13-R1, NUDOCS 9807080076
Download: ML17354B017 (424)

Text

FIRE PR ON EVALU4TION REPORT COVER HEET REPORT NUMBER'PTN-FPER-97W I3 TITLE: EVALUATION OF TURBINE LUBE IL FIRE LEAD DISCIPLINE:

FIRE PROTECTI N ENGINEERING ORGANIZATION:

PLANT ENGINEEIUNG REVIEW/APPROVAL:

'ROUP INTEIKACE TYPE INPUT REVIEW N/A~MECH K PREPARED REVIEWED APPROVED FPL APPROVED I&C NUCoo ESI NUC FUEL PROT.For Contractor Evah As Dctcnnincd By Projects C3 Review Otcrlaco As A Mm Oa All lOCFR50.59 Evais aod PLAs SPECIAL PROGRAMS APPROVAL: OTHER MKRFACES: DATE: DATE: VKM)OR PROPMKTARY INFOKNATION

'sr807080076 980702 PDR ADOCK Q5000250 PDR Ci 0 41 FIN-FPER-974t3, Rey.>Page 2 LIST OF EFFECTIVE PAGES Pa e Section Pa e Section Pa e Section Rev O.10 12 14 15 16 18 18 19 20 20 22 25 26 27 27 Cover Sheet List of EfFective Pa es Table of'ontents 1.0 2.0 3.0 4.0 5.0 6.0 6.1 6.1.1 6.1.2 6.1.3 6.1.3.1 6.1.4 6.1.5 6.1.6 6.2 6.3 6;4 6.5 6.6 6.6.1 6.6.2 6.6;3 6.6.4 6.7 6.7.1 6.8 6.9 6.10 29 30 7.0 8.0 Attachment A Attachment B

0 0 SECTION TITLE COVER SHEET TABLE OF CONTENTS PTN-FPER.97'3 Rev i Page 3 PAGE 1 1.0 2.0 3.0 4.0 5.0 LIST OF EFFECTIVE PAGES TABLE OF CONTENTS PURPOSE/SCOPE BACKGROUND REFERENCES METHODOLOGY KNOWN S/ASSUMPTIONS EVALUATION 6.1 Fire Protectioa Features 6.1.1 Existiag Wet Pipe Spriaklers

6.1.2 Existing

High Hazard Areas 6.1.3 Proposed Augmentatioa of Wet Pipe Sprinkler System 6.1.3.1 Effectiveness of Automatic Spriaklers on Lube Oil,Fires 6.1.4 Thermo-Lag Protected Raceways 6.1.5.Retention of Lube Oil-18'0" elevation 6.1.6 Physical Arrangement

.6.2 Drain Flows 6.3 Fiuid Retention Around Drains 6.4 Critical Values Associated With the Turbine Lube Oil 6.'5 Lube Oil Pool Depth.6.6 Postulated Fire-Pre4priakler Activatioa 6.6.1 Heat Release 6.6.2 Ceiling Jet aad Centerline Plume Temperatures.

6.6.3 Velocity

of the Ceiling Jet 6.6.4 Sprinkler Response Times 6.7 Effects of Sprinklers oa'the Energy aad Temperature Outputs of the Fire 6.7.1 Ceiling Jet Temperatures with Sprinkler Flow and Reduced Heat Release 6.8 Flame Height 6.9 Effects of Not Iastalliag Sprinklers Various Areas of the Turbine Building 6.10 Effect of Turbine Building Ceiliag Configuration and Obstructions on Anticipat Temperatures

7.0 CONCLUSION

S 6.0 ed 6 7 7 8 8 9 10 11 11 12 14 15 16 18 18 19 20 20 22 25 26 27 27 29 8.0 RECOMMENDATIONS 30 ATTACHMENTS A B Letter, Texaco to Florida Power and Light (R.Conrad), dated March 12, 1997 (11 pages)Suggested Locations for Addition of Spriaklers aad Curbs to be Installed in the Turbiae Building (2 pages)

PIN-FPER-97413.

Rev.t Page 4 1.0 PURPOSE/SCOPE The purpose of this evaluation is to review the existing and proposed, active and passive, fire protection B'atures to determine if the protection is adequate to protect those Thermo-Lag raceways in the Turb'ilding fmm a fire which results from a release of turbine lube oil from failed generator and/or low pressure tuibine bearing seals.This evaluation will show that the effects of a postulated Turbine Building lube oil fire on Thermo-Lag protected raceways in the transition area of the OUTDOOR Fire Area (Fire Area OD)will not challenge the raceway protection to the point of failure.The existing and proposed fire protection features will be reviewed for their mitigating effects on the fire and resulting protection of the Thermo-Lag protected raceways.In addition, the anticipated temperatures will bc shown to be below the furnace temperatures at 25 minutes during ASTM E-119 fire tests.The scope will include those raceways in the transition area of the Turbine Building located bctwecn the'D and J, column lines along the entire length of thc east siCk of the Turbine Building.'This evaluation does not justify a'change to the configuration or operation of any equipment described in the FSAR (Ref.7), and does not alter any plant design basis related to fire protection.

Proposed changes to thc plant for fire protection will be evaluated using the plant change process.Revision I is issued to document a refinement of the firc scenario, to include additional supporting documentation for the evaluation, and address additional areas of concern.The conclusions of Revision 0 remain valid and are supplemented by, conclusions resulting Gem evaluating other areas of concern.Due to the extensive nature of Revision I, revision bars are not included within the text.

2.0 BACKGROUND

Thermo-Lag conduit and cable tray wrap material was installed (circa 1985), in the Turkey Point Plant on various conduits and terminal/pull boxes.The wrap was installed to provide a I-hour and 3-hour level of protection in various areal of thc facility to mcct thc requirements of 10CFR50 Appendix R, Section III.G.2.In 1991,'he NRC alerted licensees to problems associated with certain Thermo-Lag barrier configurations (NRC IN 9147).These problems were related to the material's inability to succc.&illy pass a fire test for a specific configuration.

Further testing at various independent laboratories showed several deficiencies with the material when installed per thc manufacturers directions.

Thcsc deficiencies included lower than specified fire endurance, inability to withstand hose strcattts and the material was found to be combustible.

The Thermo-Lag in the outdoor areas was installed to meet a I'-hour fire rated configuration.

Further testing has shown that the material when tested in it's as4uilt configuration on 3/4" diameter conduits in accordance with ASTM E-119 withstands a standard timc<emperature curve fire for approximately 25 minutes (Ref.'12).The constrttction of thc Turbine Building is such that there are no fixed walls forming a perimeter around the building and no roof above thc operating deck.This allows for the release of smoke and hot gases to the atmosphere in thc event of a firc within the Turbine Building.The D to J, sector runs north-south along the length of thc east side of the Turbine Building which hccs the Containment, Control and Auxiliary Buildings.

The area between the D to J, column lines contains varying ceiling heights and degree of openness to the.atmosphere.

3.0 REFERENCES

I.National Fire Protection Association, Fire Protection Handbook, Seventeenth Edition,.2.Society of Fire Protection Engineers and the National Fire Protection Association, SFPE Handbook of Fire Protection

&gineering, Second Edition.3.National Fire Protection Association, NFPA 92-1937,'uggested Good Practice for 8'aterproofing of'loors, Drainage, Installation of Scuppers 4.NFPA 325M-1991, Fire Harard Properties of Flammable Liquids, Gases,;and Volatile Solids il FlN-FP~R-97ZI3 Rev.I Page 5 5.Drysdalc, D., An Introduction to Fire Dynamics, copyright 1985, John Wiley and Sons publishers 6.Baumeistcr,et.al., Marks'tandard Handbook for Mechanical Engineers, Eighth Edition 7.Turkey Point Safety Analysis Report.Revision 13;dated October, 1996 8.Alpcrt, R.L., Calculation of Response Time of Ceiling Mounted Fire Detectors, Fire Technology, 1972.9.Florida Power and Light, Evaluation FFN-FPER-97415, Rev.0, Technical Evaluation for Turbine Building Fire Protection IO.American Society for Testing and Materials.

Standard Methods of Fire Tests of Building Construction and Materials (ASTM E-119)11.Florida Power and Light, Calculation FIN-BFJM-91452, Rev.0, Fire Protection System Pipe Flow Analysis.12.Omega Point Laboratories, Fire Endurance Test of a Thermo-Lag 330-l Fire Protective Envelope Test 2-2, April I I.1994 13.Electric Power Research Institute, Fire-Induced Vulnerability Evaluation (FIVE), EPRI TR-100370, April 1992.14.National Fire Protection Association, Standard for the Installation of Sprinkler Systems, NFPA-13 (1996).15.Evans, D.D.and Stroup, D.W., Methods to Calculate the Response Time of Heat and Smoke Detectors Installed Below Large Unobstructed Ceilings, Fire Technology, 1986 16.Mower, F.W., Lag Times Associated 0'ith Fire Detection and Suppression, Fire Technology, August 1990.17.Florida Power and Light Calculation M08-203M, Rcv.0, Hydraulic Calculation for Unit Atadliary Transformer Deluge Hater Spray System, Units 3&4.I8.Florida Power and Light SpeciQcation 5610-M-29A, Rev.I, Speclgcations for Hydraulically Designed Sprinkler Systems 19.Florida Power and Light drawings-a.5610-M-75, Rev.14 Tursine Area-Area dh Equipment Drainage, Radwaste Area-Roof Drainage Ground Floor Plan b.5610%-13, Rev.18 Utility Piping, Main Plant Area c.5610-A<1, Sht 2, Rev.6 Floor Plan at El.18'A" Showing Detection, Suppression and Lighting 20.Babrauskas, V., Temperatures in Flames and Fires, May, 1997.21.Factory Mutual Research Corporation, Fire Tests of Automatic Sprinkler Protection for Oil Spill Fires, Sept.9, 1957.4.0 METHODOLOGY l.2.3.4.5.6.7.8.Determine which bearing failures would result in a worse case Qre cxIesure for the Thermo-Lag protected raceways.Review the existing and pmposed Qre pmtcction features to determine if the features will provide adequate protection of the Thermo-Lag raceways in the Turbine Building.Power plant accidents which resulted in turbine lube oil Qres will be reviewed under a separate evaluation.

The conditions which led to those accidents will bc compared to the Turkey Point hcility to determine if similar conditions could occur at Turkey Point.(Ref.9)Determine the type and location of features in Fire Area OD which act as mitigating features.Determine the envimnmental conditions to be utilized in thc evaluation.

Utilizing documented Qre and heat transfer formulas and general Qre protection theory, determine the anticipated tcmleratttres based on the postulated fuel loading.Document the overall conclusions of the cumulative effects of the worst case anticipated actors with respect to the effects of Qre on the Thermo-Lag protected raceways in the, transition area of Fire Area OD.Provide recommendations, if necessary, to enhance the protection of the Thermo-Lag protected raceways in Fire Area OD.

0 0 PTN-FPER-97413, Rev.1 Page 6 5.0 KNOWNS/ASSUMPTIONS

5.1 Known

Data 2..3 5.6.10.The 18'0" elevation is sloped toward the floor drains such that the openings to the floor drains are 2" (0.167')below the floor grade.(Ref.19)Floor drains are 4" diameter.Waste oil drains are 3" diameter.(Ref.19)Based on measurements taken during walkdowns the total width of openings which would allow flow to escape from the 18'0" elevation to the Condenser and Condensate Pump Pits is 26'5" and to the outside (west)of the Turbine Building are two flood gate openings which are 36" wide each..Four drains are in the area between column lines A-D and 23.1-25.1 (and 30.1-32.1), three-fow inch diameter heavy cast iron pipes which drain to a catch basin and one drain not identified on drawings.(Ref.19)Oil pressure at the bearings is 10-15 psi based on field observation.

Plant records indicate that the turbine lube oil is Texaco 00700 Regal RAO 32.Composition of the turbine lube oil is contained in Attachment A.Turbine vibration significant enough to cause the failure of three bearing seals (generator and/or low pressure turbine)will trip the turbine.The turbine coastdown time may be as long as 45 minutes (Ref.9)Walkdown measurements indicate that 37.65%(1,139.14 ft)of the area bounded by column lines A-D and 23.1-25.1 is occupied by fixed equipment or structural components, (electrical cabinets, curbed dikes and Turbine pedestals).

Walkdown measurements indicate that drain covers throughout the Turbine Building are slotted or perforated.

The slotted drain covers provide an effective opening to the drains which is equivalent to an actual diameter of 3.3 inches each while the perforated drain covers provide from 1.24 inches to 1.7 inches in equivalent diameter opening.Wet pipe sprinklers installed in the Turbine Building are intermediate temperature sprinklers rated at a temperature of 212'F (100'C).5.2 Assumptions:

Based on PTN Evaluation PTN-FPER-97415.bearing.

vibration within the generator and/or low pressure turbine as a result of an overspeed event causes three bearing seals to fail.The evaluation further concludes that a maximum of 150 gpm flow of lube oil from each failed seal would occur under a worse case scenario.(Ref.9)All drain covers are assumed to be slotted to allow for the maximum equivalent diameter for the drain covers to be utilized throughout the evaluation.(See Recommendations)

6.0 EVALUATION

The assessment of the postulated lube oil fire in the Turbine Building will start with an evaluation of the existing and proposed fire protection features both active and passive.An analysis utilizing fire protection engineering calculations will be used to quantify the effectiveness of the features described'in'the evaluation.

The analysis will proceed through a determination of the basic values which will be used throughout the remainder of the evaluation.

Area features such as the drain flow rates, amount of fluid which can be retained over the drains prior to overflow, the characteristics of the lube oil, rate of discharge for the lube oil will be discussed/evaluated prior to the evaluation of the heat and temperatures generated by the fire, and the postulated sprinkler responses.

These features form the basic building blocks from which the evaluation of the conditions resulting Qom the fire will be based;Evaluation PTN-FPER-97415 (Ref.9)determined that the credible failures of bearing seals would be a total quantity of three (3)in the generator and/or low pressure turbine which would release 150 gpm of lube oil Rom each bearing for a total of 450 gpm.The location of the bearings which present the worst case fire scenario are the generator and¹6 low pressure turbine bearing.These bearings are located such that two are directly over the area bounded by the proposed curb 6.5'est of the C column line and D column line and 23.1-25.1 (Unit 3)and the 0 0 FIN-FPER-974 t3.Rev.I Page 7 proposed curb 6.5'est of the C column line and D column line and 30.1-32.1 (Unit 4)at the 18'0" elevation, a second is located directly over the condensers and the third is located over the condenser and the 18'0" elevation.

Therefore, it is reasonable to postulate only half of the 450 gpm Qow of lube oil to the Condenser/Condensate Pump Pits and half to the area between the Switchgear Room and the Condenser (for this evaluation, the area bounded by the proposed curb 6.5'est of the C column line and D column line and 23.1-25.1).The areas bounded by the proposed curb 6.5'est of the C column line and D column line and 23.1-25.1, and the proposed curb 6.5'est of the C column line and D column line and 30.1-32.1 column lines are the areas where aa accumulation of lube oil released due to failed generator and/or low pressure turbine bearing seals would occur in the event of the postulated bearing failure.These areas will herein be referred to as the"curbed area" for the remainder of the evaluation.

6.1 Fire Protection Features Thc existing and proposed fire protection features are both active and passive in nature.(See Attachment B)The proposed and existing features in the Turbine Building support the coaclusion that the Thermo-Lag raceways in the Turbine Building (column lines E-J)and the transition area to thc out~f4oors area (J-J,)do not require any further upgrade to their existing fire resistive properties.

This is supported by the augmentation of the sprinklers in the areas where lube oil will pool (the"curbed area" (Sce Sectioa 6.0 for description))

and at the location of thc Thermo-Lag raceways within column lines A-J, as well as, the addition of retention curbs to prevent migration of lube oil from the spill area to the D-J, column lines.The provision of full coverage of sprinklers over the areas where the lute oil will pool (the curbed area" (See Section 6.0 for description))

is the predominant factor in support of the conclusions reached regarding the integrity of the Thermo-Lag protected raceways in the event of a postulated generator and/or low pressure turbine bearing seal fhiiure.Full coverage sprinklers have been shown to be eQective ia extinguishing fires involving combustible liquids with flash points of 200'F (93.3'C)aad higher.The lube oil utilized at Turkey Point has a flash point of 395'F (202'C)which is well in excess of the above stated value.The essential'ontributor to extinguishing high fash point fires is considered to be the cooling of the liquid surface by the water discharged from the sprinklers to a point where it can no longer generate enough volatile vapors to support combustion.

The coofing is through thc absorption of appmximately 8,440 kJ (8000 Btu)of heat for each galloa of water converted to steam.Predominant in-situ combustible loading throughout the Turbine Building is limited to the materials which are presently protected by Qxed water spray systems with other minor amounts of combustibles protected by the existing sprinkler coverage.6.1.1 Eastiag%et Pipe Spriaklcrs Partial coverage of the Turbine Building is provided by wet pipe sprinklers.

Hazard: Thc wct pipe sprinklers were installed to protect against the hazard of lubricating oil.The sprinkler installation is such that it follows thc routing of the guarded oil pipe and also provides coverage of areas where localized pooling of lube oil may occur.The localized pooling of turbine lube oil would occur at thc 18'0" elevation between the Switchgear Rooms and the Condenser Pit aad within thc Condensatc Pump Pit.The lube oil with a fash point of 395'F (202'C)is considered to bc a Class IIIB combustible liquid.(Rcf.I, p.3M).Hydrogen in the generator is not a coatributor to the fire hazards within the Turbine Building other than serving as an ignition source for the lube oil in the event of bearing seal failure on thc geaerator and low pressure turbine.The hydrogen supply to the geaerator is ia a closed piping network whose supply valve is normally closed.Density: The original design density for the system was to provide 0.3 gpm/flP/3000.ft

.(Ref.18)In accordance with NPPA 13 (Rcf.14), lube oil'hazards in'piping, such as those considered in the original design, are classified as an Extra Hazard Gmup I occupancy.

The rcquirtxI density for a 0

PTN-FPER-97413.

Rev.t Page 8 similar design area in such an occupancy is 0.28 gptn/ft/3000 f6.Therefore, the design density used at Turkey Point exceeds the NFPA 13 required density for this hazard type.Spacing: Sprinkler spacing along the majority of the existing wet pipe sprinkler system is conservative in that it is below the maximum spacing allowed by NFPA 13 which allows a maximum of 100 fthm/head for an extra hazard occupancy.

Coverage: Sprinklers provide full coverage in the Condensate Pump Pit, partial coverage in the Condenser Pit.and partial coverage is provided throughout the remainder of the Turbine Building primarily located to protect areas where guarded oil pipe is routed throughout the Turbine Building.Any fire postulated to be occurring in the Condensate Pump Pit simultaneously to that on the 18'0" elevation is assumed to be suppressed by the existing closed head sprinkler system in the pit.Based on original design documents the sprinkler system for the entire turbine building was designed to provide the area with 0.3 gpm/It/3000 R.The head spacing in the lowest area of the Condensate Pump Pit was observed to be conservatively installed at approximately 50'lo of the maximum 100 ft/head spacing.In addition, the configuration of the Condensate Pump Pit lends itself to consideration as an enclosure due to the massive equipment obstructions, and the presence of multiple coverings over various elevations.

Therefore, the production of steam in this area will result in aiding in extinguishment via smothering.

6.1,2 Existing High Hazard Areas Hazards: Density: Spacing: Passive: Coverage: Lube Oil Reservoir, Lube Oil Transfer Pump Skid, Main Transformer, Auxiliary Transformer, Hydrogen Seal Oil Vnit, Start-Vp Transformer Design criteria for the fixed water spray systems installed to protect these hazards indicates that the minimum design density for the systems is 0.25 gpm/ft'ver the protected surface.The actual design density has been shoWn by calculation to be higher for the as-installed system prdtecting the Auxiliary Transformer.(Ref.17)The heads are spaced in accordance with the requirements of NFPA 15 (1977 and 1979)and the manufacturer's test documentation for the spray nozzles installed (Automatic Sprinkler 668 and 668WA)so that complete coverage of protected surface area is provider'ach of the above named high hazard areas is provided with a diked area for containment of fluid leaks from equipment thus preventing combustible fluids from migrating to other areas.Each system is equipped with heat actuated detectors (rat~f-rise) which are activated when a change of 5'F/minute is detected.This type of detection will sense both a fire involving the equipment being protected as well as a fire adjacent to it.In the event of a Qre involving equipment in one of these areas, protection is provided.In the event of a fire adjacent to these areas, such as the postulated turbine lube oil fire, exposure protection will be provided by the spray system to prevent damage to the equipment.

6.1.3 Proposed

Augmentation of the Wet Pipe Sprinkler System Areas of the Turbine Building will be augmented by additional wet pipe sprinklers as a result of a postulated turbine lube oil release and resulting Qre.These sprinklers will be provided to complete coverage in areas where pooling of lute oil will occur, and beneath areas of Thermo-Lag protected raceways between the D and J column lines.Sprinkler modifications in the Condensate Pump Pits will be performed as outlined in Recommendation 4 to replace sidewall sprinklers with standard upright sprinklers.

The addition of sprinklers under the Thermo-Lag protected raceways results in the complete coverage of all Thermo-Lag protected raceways throughout the Turbine Building between the A-J column lines.Further, the area of coverage for sprinkters installed within the Turbine Building will be based on a 5000 ft area and density will be based on a potential lute oil hazard Hazard: The additional wet pipe sprinklers will enhance protection in two areas.Sprinklers will be added to the existing wet pi pe system in the area where lube oil will pool on the 18'0" elevation.

This area where pooling is a concern is the"curbed area" (See Section 6.0 for 0

PTN-FPER-974 l 3, Rev.t Page 9 description).

The addition of sprinklers to the existing system'will provide complete coverage in S prinklers will also be installed within, adjacent to, or over locations where Thermo-Lag protected raceways are installed along the length of the Turbine Building between the D-J column lines.The sprinklers for this particular area will be installed where appropriate to protect both the 18'0" elevation and thc 30'0" elevation.

The additional suppression will provide both cooling of smoke/hot gases from a lube oil fire in an adjacent area as well as protect against the effects of a transient fire beneath the raceways.Density: The original design density for the existing system was to provide 0.3 gpm/ft/3000 ft.Due to the nature of the postulated lube oil fire, the area of coverage will be increased to 5000 fti and the design density will consider the lube oil hazard.Thc increase in area is based on the facts that the areas at the 18'0" elevation and within the pit area where lube oil will pool is approximately 3000 ft and that the intensity of a combustible Uquid fire presents the possibility that elevated temperatures adjacent to the area of the fire may be such that the sprinklers therein will also activate.As such this density will be equivalent to or in excess of the NFPA 13 recommended density of 0.2 gpm/It/5000 ft.Spacing: Sprinkler spacing will bc in accordance with NFPA 13 which allows a maximum of 100 fti/head for an Extra Hazard Group I occupancy.

Coverage: Covcragc throughout the Turbine Building will remain partial after the installation of the additional sprinklers.

However, the areas where lube oil is postulated to pool after a generator and/or low pressure turbine bearing seal failure will be protected by full sprinkler coverage.6.1.3.1 Eficctiveness of Automatic Sprinklers on Lube Oil Fires NFPA 13, Standard for the Installation df Sprinkler Systems, specific design densities for hazards such as the lube oil hazard which the Turbine Building sprinklers will be designed to suppress.The design densities in NFPA 13 are considered to reQect historical experience with the concept of fire controVcontainment.

Sprinkler head spacing itt the Turbine Building in the area of the postulated fire is more conservative than that required to meet the minimuin requirements of NFPA 13 and design densities will'mcct or exceed those required by NFPA 13.Factory Mutual Research Corporation (FMRC)performed sprinkler discharge testing over lubricating oil fires for the Atomic Energy Commission (AEC)(Ref.21).The oil utilized was more volatile (ignition temperature approximately 360'F)than the lube oil used at Turkey Point.The oil and Qoor were preheated to approximately 165'F and 130'F respectively.

In all cases the oil was difiicult to ignite and required thc use of accclerants (gasoline soaked products).

The ceiling height in the test facility was 33 feet with vented openings at the ceiling and around the perimeter.

Standard 212'F.I/2" orifice sprinklers were installed on a 10'x10'pacing.

Sprinkler operation began to occur at 17 seconds after the pool fire had grown to 5 feet in diameter.The ceiling temperatures in Test 42 never exceeded 600'F (3 16'C).The'maximum pool radius was 6 R.which was at I&seconds aIIcr the first sprinkler operated.However, it was noted that the fire had been knocked down to a lingering flame at thc pool suriace within one minute of the first sprinkler operating with an application rate af 0.13 gpm/sq.ft Another test was performed to establish the effectiveness of sprinklers over a large pool fire.Gasoline/kerosene micttires were spilled over thc lube oil pool and ignited.Water was manually contmllcd to the sprinklers and not allowed to discharge until the pool fire had grown in size to approximately 1400 sq.ft Fire control was achieved between 2-1/3 and 4 minutes.Although ceiling temperatures reached 1200'F and Qames extended up to 10 feet beyond the vent openings in the structure.

the fire was brought under control quickly and without damaging effects to the building.Steel temperatures with automatic sprinkler protection in the area indicated that temperatures which would result in failure would not be rcachctL The FMRC testing shows that effective control of temperatures and fire can be achieved for lube oil pool fires with a minimum of discharge density.This supports the conclusion that the sprinkler head type, temperature rating, and discharge density as utilized in the Turbine Building will effectively control the firc and prevent structural steel failure.

0 PTN-FPER-974 t3.Rcv.I Page 10 6.1.4 Thermo-Lag Protected Raceways The Thermo-Lag protected raceways located within the area bounded by the A-D aad 23.1-25.1, and A-D and 30.1-32.1 and located within and over the Condensate Pump Pits will be upgraded to meet a 1-how Qre resistance.

Other Thermo-Lag raceways between column lines E-J, throughout the length of the Turbine Building will remain in their present configuration will be assumed to provide approximately 25 minutes of Qre resistance.

T'em erature Pro>le The NFPA,Handbook (Ref.1, p.6-77 and 6-78)provides descriptions of various occupancies sutveyed to develop the characteristic time-temperature curves based on occupancy and fire loading.High hazard occupancies are depicted by the"E" curves in the time-temperature Qgure.The maximum Qre loading which could occur on the 18'0" elevauon prior to runoff to other areas would be 483.7 gallons which actuates to a combustible loading of approximately 3.1 lb./ft.This fire loading when compared to the NFPA fire scvcrity time-temperature"E" curve produces a Qre of approximately 15 minutes in duration and maximum temperatures of approximately 760'C (1400F).This approximated temperature is nonconservative when compared to those temperatures presented in Section 6.7.1, and does not account for cooling which would result from sprinkler discharge in the area.In addition, it, is not conservative to utilize the time temperature profiles provided in the NFPA Handbook as a result of changing combustible loading on thc various elcvatioas of the Turbine Building as a result of thc postulated spill time for the Lube Oil Reservoir to drain as well as the drainage from the elevations via drains, runoff and sump pump operation.

Babrauskas (Ref.20)indicates that the peak value for Qre temperatures is governed by the ventilation and fuel supply characteristics.

The maximum value documented is approximately 1200'C (2192'F).Aipctt's experiments of large scale Qres (668kW-105 MW)without sprinkler protection indicated a maximum temperature for a large scale Qrc at a 15'eiling height was 927'C (1700'F), and temperatures at higher elevations were lower during thc same fire.Temperatures of laminar or turbulent diffusion flamcs as summarized by Babrauskas (Ref.20)show that an upper temperature limit of 1250'C (2282'F)was observed for natural gas.Other fuels yielded lower upper limit temperatures as well as lower temperatures for the intermittent and continuous flaming regions.Average continuous Qame region temperatures of 900'C (1652F)and intermittent fame temperatures of 320'C (608'F)have been documented for a variety of fuels.Discussion regarding the adiabafic fame temperature (i.e.ao loss of heat occttrring) for methane aad propane indicate temperatures of 1949'C (3540'F)and 1977'C (359 1F)respcctivcly.

However, atliabatic temperatures are not realistic in an actual Qre scenario due to the continuous loss of heat to surroundings through various means (i.e.radiative, convective, etc.).In addition, the ASTM E-119 time-temperature curve has a maximum temperature of 1260'C (2300'F)which is reached at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.The FMRC testing described above in Section 6.1.3.1 indicates that ceiling temperatures at 33'ver the base of the fire never exceeded 600'F (3 16'C)with automatic sprinkler protection and control was established within minute>of the operation of the Qrst sprinkler.

Thc fire duration is postulated to occur over the time frame in which the entire contents of the lube oil storage tank are assumed to be discharged as a laming stream.This was postulated in order to prcscat a very conservative analysis.However, due to the complete coverage with sprinklers of the area where pooling will occur at the 18'0" elevation and the manual Qre fighting effort which will be involved, suppression is likely to occur at an earlier time within the postulated scenario.Therefore, based on the above discussion, the temperatures that are predicted throughout the duration of the fire as shown in Section 6.7.1 are significantly conservative in view of the documented maximum temperatures for gas hyers, and'Qame temperatures.

As such, the areas east of the"E" column line will not be recommended for Thermo-Lag upgrade, since tcmpcratures at the"E" column line arc conservatively calculated to bc below the temperatures in the ASTM E-119 furnace at 25 minutes.

0 Cl FtN-FPER-~7413, Rev.t Page 11 Tubular Steel Survivablli Conduits and pipes, which are located above Thermo-Lag protected raceways, in the vicinity of the fire scenario are supported by tubular steel (unistrut).

Failure of the supports for these unprotected conduits or pipes could affcct the integrity of the Thermo-Lag protected raceways located beneath them.Therefore, a review of thc potential for steel failure is included in this evaluation.

Steel failure is known to occur when the steel temperature reaches approximately 649'C (1200F).However, steel will not fail at the same time that a room or ceiling jet temperature of 649'C (1200'F)is reachccL Heat transfer within the steel itself must occur for a period of time before the member will reach its critical temperature.

Discussion in Temperature Profile (above)regarding the temperatures in the fire scenario has concluded that the temperatures predicted for the ceiling jet and in the intermittent and continuous flamiag'egions will be lower than those postulated in Section 6.7.1.As such the only areas of concern based on the temperatures documented in the referenced section will be within the area bounded by the B-D column lines where temperatures are postulated to be in excess of the temperatures at which steel Mure can occur.Additional protectioa of supports in the area of the fire are not recommended or considered necessary based on thc foUowing points of consideratioa:

~Sprinkler discharge will provide water impingement on the supports of raceways/pipes within the boundaries of the Qaming firc.This discharge will provide direct cooling to the support steel for the raceways.This is supported by the FMRC testing discussed in Section 6.1.3.1.~Temperatures which are postulated are very conservative based on the discussioa in Temperature Profile.Actual temperatures are postulated to bc much lower, thereby reducing the threat to the soundness of the steel supports.This is supported by the FMRC testing which indicated that the ceiling temperatures over the pool fire never exceeded 600'F (3 16'C).6.1.5 Rctcatioa of Lube Oil-18'0" elcvatioa The areas bounded by the"curbed area" (Sce Section 6.0 for dcscriptioa) where an accumulation of lube oil released due to failed generator aad/or low pressure turbine bearing seals will occur.Due to the open areas associated with normal ingress/egress Gem these areas to other areas of the Turbine Building, thc potential exists for the migration of turbine lube oil beyond thc area to the exterior of the Turbine Building and to the J column line.Retention curbs are proposed to prevent the migration of released lube oil and sprinkler discharge beyond the D column linc and 6.5'est of thc C column line.(Refer to Section 6.3 and Attachment B)6.1.6 Physical hnaagemcat Mitigating physical ammgctncnts within the 18'0" elevation of the Turbine Building exist which could shield or othcrwisc inhibit thc Qow of smoke and hot gases Gum an oil release and fire to the areas where Thermo-Lag protected raceways are located.This is due to the presence of the structures or equipment in the area with respect to generator and/or low pressure turbine bearing locations and postulated pooling areas.The area to be botmdcd is thc"curbed area" (Scc Section 6.0 for description) and was determined to present the worst case scenario for transmission of heat to the Thermo-Lag protected raceways due to the location of Thermo-Lag protected raceways with respect to thc postulated pooling area In addition, the location of the generator and/or low pressure turbine bcamtgs postulated to leak are such that one is directly over the area mentioned, a second is directly over the coadcasers and the third is over both areas.Therefore, it is reasonable to postulate only half of the 450 gpm Qow of lube oil to the Condenser/Condensate Pump Pits and half to the area between the Switchgear Room aad the Condenser (for this evaluatioa the"curbed area" (Sce Section 6.0 for descriptio)).

Sloped curbing will be introduced to confiac the lube oil spill between approximately 6.5 feet 0 II PIN-FPER-97413, Rev.t Page 12 west of the C column line and the D column lines thus providing a limited pool size which will be channeled'o runoff to thc Condenser and Condensate Pump Pits.6.2 Drain Bows No credit is taken for drain Qow Gem the 18'0" elevation through the waste oil Qoor drains duc to the low capacity of the waste oil separator.

The waste oil separator is located at the Turkey Point Fossil Facility.Based on a 2" (0.167')depth of oil over the drain opening and utilizing Bernoulli's equation (Ref.6), where the slotted drain covers provide an effective diameter opening of 3.3 inches each, the effective flow into any one of the 4" diameter drains is approximately:

2 2 Ps-+-+2)=-+-+ss Pi 2S Ps 2S where: Pi Ps r~is considered negligible 2S=0 therefore, V s~=~~v>~J2gt~~2(322/t/s X0.167@)~328'/s 2$Based on an approximate 3.3 inch diameter opening: vz=328+/sing

=vsA=v>m"=(328@/s)x(01375/t)

~0195//s Converting to gpm: Q=(O.I95jl/sX7.481gal/Jl

)(60s/min)

=8753gpm Therefore the Qow resulting from the 2 available drains is: Quern=2+(3z~2~(8753gpn)~175.06gpm Full Qow of oil/water output at the catch basin through the 4" drains is not antici pated due to the lower flow rate calculated through the drain covers (175 gpm).However, a Qow rate of 66 gpm will be used in the evaluation as thc maximum rate that the turbine lube oil or other Quid will drain lrom the 18'0" elevation.

Therefore, based on a 4" diameter main drain, converting to velocity we obtain: V=(66gpm)(lmin/60secXljl

/,748lgal)

/rr(0.16775+)

=1.66jt/s Assuming entrance, Gtting and exit losses within thc drainage piping are considered negligible, their associated valves will not be considered in thc evaluation of the drain flows.Using Bcrnoulli's equation we Gnd that for tll drain Qow resulting Gem a combination of flows Gem 2 drains to the catch basin:

Cl 0 PTN-FPER-97@i 3.Rcv.l Page l3 Drains at 18'0" elv.Overall length of piping from drains,'to z2.is approx.100'0" z1=1 5'7" 12.83'z2=12'5" Discharge to Catch 8asin Figure 1 General Elevations in Drain Piping from 18'0" Elevation pl vt p2 v2++2 1/f(cps-++22 pl 2g p2 2g where: pl p2 pl p2.1=vMD=662'/s sl=15.6'2=l2.4'lid hloss=friction loss in the approx;l00'f pipe between the drains and the catch basin=JLv/D2g where: f=friction factor based on thc Moody diagram L~length of the pipe in feet~lOOjt.v=velocity of the Quid in feet/s~l.66jt/s D~internal diameter of the pipe in feet~03355f g acceleration due to gravity~322jt/s The values for viscosity and density of the turbine lube oil shall bc used in the calculation of the friction factor.The friction factor (f)is based on the Reyrlld's number (NRs)and the relative roughness (s/D).Nor-=vD/u 2 a 2 u=kinematic viscosity=3L5cSf=3L5<<10Ž=(3L5<<10Ž)<<(10.76-r)s s mr o=338%10 jt/s 2 N trr=(L66jt/s)(0.3355 j?)/3389<<10-=L643<<10 s s/D=(0.00085 jt)/(0.3355 jt)=2.55<<10 0 0 FIN-FPER-974l3.

Rev.1 Page 14 In applying these values to thc Moody diagram, one observes that the Reynolds number above is representative of laminar Qow which follows a friction loss formula of 64/Naa.The friction loss factor of 4" pipe is therefore~64/1.643'0

~0.0389 ft lhc fiiction hss (hI)=(00389X100j?XL66j?/s)

/(03355 j?X2)(322j?

/s)=05 j?Substituting these valms hro Bernoulli's Equation yields: vz=v<~2g(z<-zz-h~)=(662j?/s)+2(322j?/s X156'-124'WS)

=1475j?ls Converting to gpm vz=1475j?/s>>g~=vzA=(1475/PI sX(03355 j?/2)trX6/3s/~X>48?gal/3

)=5853gp~Therefore, based on the above calculations, the reduced Qow into drains which is postulated at 66 GPM is valid.:6.3 Fluid Retention Around Drains The presence of drains with to~f~n~levations (TODE)below the grade elevation of 18'0" coupled with slope indications toward those drains are indications that conflguration similar to inverted pyramids exist over the drains.Although the drain areas are not mirror images of one another (Ref.19a), it is assumed that dividing the non-occupicd area equally amongst the four drain areas would present a reasonable representation of thc volume of fluid which could be retained over the drains as a whole.a.Gross Qoor area (Q between column lines A-D and 23.1-25.1:

A=62.85'+48.125'=

3026.sq.ft.b.Each drain opening is 2" (0.167)below grade which will be used as the height..'.Floor area not occupied by structural components or equi pmcnt (Af): Af=1887sq.ft.d.Divided into four quadrants, thc area per quadrant (: A~=0.29'/=472sq.ft.e..Gross area bounded by curbing (A,): A (33.875'48.125)=1630.23 fl'151.4 m')f.A areaoccupiedbyequipment(A

): A~457ft (42.45 m'),g.Area of floor unoccupied where lube oil can pool (~: A t~'1173.23 ft (109 m')h.Calculating thc volume of a quadrant as a pyramid: Vq=(1/3)(base)(height)

=(033)(472 j?.)(0.167j?)

=26j?V~=(26j?)(7A81gal/

Jt)=194.6gallons i.Total potential retc,ation over the drains prior to runoff occumng: V,=(1 17323 j?/472Jf)+194.6gallons

=483.7gallons 0

PTN-FPER-974 l3, Rev.l Page 15 6.4 Critical values associated with the Turbine Lube Oil A comparison of characteristics of the Turbine Lube Oil used at Turkey Point was performed against similar parameters of other.combustible liquids.Table 1 Material and Burn Characteristics of Various Petroleum Based Hydrocarbons Flash Point V('C)380'F 193C Lubricating 300'F450'F Oil, Mineral (149'C-232'C)Ignition Tc nip.'F ('C)500'F-700'F (26Q'C-371'C)Spec.Gravity 0.8%.9 Boiling Point V('C)680'F 360 680'F (360'C)NFPA Fire Hazard-Rating'5.8-46.0 Mass Loss Rate kg/m's Turbine Oil Regal Oil Fuel Oil No.1 Fuel Oil No.2 Fuel Oil No.4 Light Fuel Oil No.5 400'F 204'395'F 202'C 100'F-162'F (38'C-72'C) 126'F-204'F 52'C-96'C 142'F-240'F (61'C-116'56'F-336'F (69'C-169'00'F 371'10'F (210'C)494'F 257'05'F (263'C)0.8681 0.825 5 482'F (250'C)305'F-574'F (152'C-3015.37 43 1 46,5 Heavy Fuel, 160'F-250'F Oil No 5 (71'C-121'.94-1 3<1 39.7 0.035 Fuel Oil No.'6 150'F-270'F (66'C-132'765'F (407'C)42.5 Notes: All values except heat of combustion are Rom the Texaco Material Safety Data Sheet for 00700 Regal RHINO Oil.(Att.A)Fire Protection Handbook,.

17th edition, Table A-3 (Ref.1)Handbook of Fire Protection Engineerin, 2nd Edition, Table 3-1.2 (Ref.2)Fire Hazard Properties of Flammable Liquids, Gases, and Volatile Solids, NFPA 325M-1991 (Ref.4)Handbook of Fue Protection Engineering, 2nd Edition, Table C-1 (Ref.2)Fire Protection Handbook, 17th edition, Page A-7: bH,"(M/kg)~52.12-8.79d'0.14d where d~spccdic gravity (Ref.1) 0 0 PTN.FPER-974 l3, Rcv.l Page 16 ln comparing the known values for fiash point, ignition temperature, spccific gravity boiling pomt and Q hazard rating we sce a distinct similarity in values associated with the lubricating oils, and the Texaco Regal Oil.In reviewing the characteristics of the fuel oils one can see that fuel oil is more volatile than the lubricating oils with Qash points and ignition temperatures lower in almost all cases.The comparison of heats of combustion

(~shows a small deviation in values for all fuel chosen including the approximated value for the Texaco Regal Oil.Although the heat of combustion may be determined from empirical rules characterizing petroleum products due to it being a material property, the mass loss rate (m")is typically found experimentall (Ref.1, p.10-100 and Ref.2, p.3-3).Due to the limited information available on mass loss rate values, the mass loss rate value associated with heavy fuel oil will be used throughout'the remainder of this evaluation where necessary as that of the Texaco Regal Oil.This assumption is felt to be valid based on the comparison and similarity of the mab:rial properties of several petroleum based hydrocarbons.

The Turbine Lube Oil used at Turkey Point is Texaco 00700 Regal RkO 32 a lubricating oil consisting of 95-99/o solvent dewaxed heavy parafiinic hydrocarbon distilla+(mineral oil)with the remainder being composed of butyl phenol, an and methaactylic acid as additives (Att.A).The burning characteristics of the lube oil will be slightly different from 100%mineral oil since the lighter hactions will ignite earlier and are likely to burn faster.However due to the small amount of additives in the total volume it is not likely to have a significant impact on the mass loss rate to be used.6B Lube 011 Pool Depth Based upon assumptions related to the Qow rate and dispersion of the turbine lube oil,~gpss is postulated to flow to the 18'0" elevation.

The pool depth at any point in time will be affected by the following factors: Drain capacity Mass loss due to burning of the fuel Runoff to the Condenser and Condensate Pump Pits or through Qood gates a.The postulated Qow of lube oil to the 18'0" elevation is 225 gpm.Bearin seal failures at three bearings (generator bearing and bearings 7 and 8 of thc low pressure turbine)are postulated.

The bearing locations arc such that one is directly over thc"curbed area" (Scc Section 6.0 for description), the second is over the column line separating the condenser fmm thc 18'0" elevation and the third is over the condcnscrs.

Therefore, it is postulated that 50%of the lube oil released due to the postulated bearing seal failures will discharge to the 18'0" elevation and the remaining 50%will be discharged over the condensers and will collect in the Condctlsatc Pump Pit'(Scc section 5.2.1).b.The calculated drain capacity at the 18'0" elevation calculated in Section 6.1 was determined to be 175 gpm.As a matter of conservatism this value will be reduced by approximately 62%to 66 gpm for calcuIation of thc cffccts of a lube oil Qre with or without sprinkler interaction.

c.The capacity aver the drains before spill over to the Condenser Pit, down the stairs to thc Condensate Pump Pit is calculated to be approximately 483.2 gsQeas based on calculations performed above in Section 6.3.d.The total width of openings&om the area of concern at the 18'0" elevation to the Condenser and Condensatc:

Pump Pits is 11'2" pcr unit.Suggested Good Practice for Watcrproofing of Floors, Drainage, Installation of Scuppers (Ref.3)which is no longer in effec but the majority of whose content is contained in the Fire Protection Handbook (Rcf.1, 6>>28), pmvidcs information on the tested discharge values through standard 4" scuppers.The approximate discharge for the total width present in thc area of concern will be used later in this evaluation.

The discharge rate will be applied such that the Qow k~~rzi~~g g M ol'L MINIM!.

PTN-FPER-97413, Rev.t Page 17 associated with the fluid height calculated will be extrapolated based on the values shown in Table 2 below.Table 2 Flow Rates for Standard Scuppers and Other Openings Depth of water inches (meters)1 0.0254 2 0.051 3 0.0762 4 0.1016 4.4 0.1118 5 0.12 6 0.1524 Discharge from a 4" scupper (gVA 92-1937)33 m 71 m 132 m 188 m 210 m 218 m 245 m Average Discharge Per Square Inch (Opening Width x Fluid Depth)8.25 m 8.875 m 11 m 11.75 m 11.93 m 10.9 m 10.2 m Approximate discharge through 1 1 12'134 inches)of openings to the Condenser and Condensatc Pump Pits 1105.5 m 2379 m 4422 m 6298 m 7033.9 m 7303 m 8200.8 m c.Based on no sprinkler activation, the above discharge rates of oil (225 gpm)and drain Qow rates (66 gpm), fuel accumulation over time will be seen on the 18'0" elevation.

f.ConQnement of the buining lube oil will be primarily contained within the curbed area, minor splashing is expected to occur but will bc limited due to the position of the curbs.Addition of water due to sprinkler.

activation will increase the effective pool area and pool diameter due to spreading of the fuel across the area bounded by the curbing on thc 18'0" elevation.

The effects of the addition of water will bc calculated on a one minute time step basis in order determine the eQective curb height, the mass loss and heat release due to burning.For the purposes of calculating the heat release fmm the Qre an effectiv pool diameter will be calculated based on a circular pool with an area approximately equal to the unoccupied area bounded by the pmposed curbing.g.Based on pote,ntial lube oil Qow patterns and assumed drainage rates from the 18'0" elevation, thc heat release and resulting ceiling jet temperatures prior to sprinkler activation will be based on streaming burning combustible liquid which is estimated to cover the entire unoccupied portion of the curbed area which is aquivalent to 109 m'1173.23 Q').h, The activation of tbc spray systems which pmtcct the Hydrogen Seal Oil Unit and the Auxiliary Transformer discharge approximately 105 gpm and 390-gpss respectively.

The diked areas surrounding each of these hazards wiH contain the systc:m discharge for appmximately 5;23 minutes and 11.11 minutes rcslectivcly.

After thee discharge times overQow will occur onto the 18'0" elevation in the area being evaluated.

It is postttiatcd that at approximately 2 minutes into the Qrc scenario the temperature rise in thc vicinity of these spray systems will activate the respactivc detection systems which are set to respond to a temperature risc of 5'F/minute.

Therefore, at the above mentioned times at which overflow will occur, the discharge of these systems will be added to the amount of Quid on the 18'0" elevation outside of the curbed area.i.Prior to runoff occurring down to the Condenser and Condensate Pump Pits the maximum pool depth of 2" is postulated

(-483.7 gallons of lube oil on the 18'0" is postulated to exist).

0 Cl

6.6 POSTULATED

FIRE-PRE-SPRINKL'ER ACTIVATION PTN-FPE~-974 t3.Rev.t Page IS Hydrogen release as a result of the failed hydrogen oil seals will ignite and cause thc subsequent

'i f th lube oil.en ignition o e As stated above, 225 gpm of turbine lube oil is calculated to be fiowing across the 18'0" elevation during thc initial phase of the postulated fir.There will be no runoff to the Condenser and Condensatc Pump Pits during the early stages of the postulated fire based on floor slopes in the areas of concern.Flow of oil beyond the D column line is not postulated due, to the addition of a retention curb.It is postulated that the initial release of lube oil will generate a pool with an area of approximately half the total unoccupied floor space in the curbed Sprinlder response times are affecte by the radial distance of the sprinklers with respect to the fuel package, fire plume temperatures; ceiling jet temperatures and ceiling jet velocities.

The sprinkler response times in the areas of concern will also bc affecte by the inconsistent ceiling heights in the area.Since sprinklers arc located at various heights in these areas the response times in both will bc calculated using ceiling heights of 3.66 m (12'0")and 7.315 m (24'0").6.6.1 Heat Release The heat release in the area due to the postulated fir will not include any other in-situ or transient combustibles other than the postulated release of turbine lube oil.This is based on coinbustibles documented in the FSAR (Ref.7)for those fire zones where the firc is postulated to occur and those fire zones adjacent to the fir.The combustibles documented are either negligible or consist of combustible liquids contained within equipment which is bermed'and protected with automatic water spray, systems.The following assumptions pertain to the determination of the heat release in the area of the fire as shown in Table 4:~Transient eQ'ects such as unsteady burning during the initial stage of the fire as a result of gradual heating of the ground underneath and surrounding boundaries will be ignored.This effect cannot be quantified particularly for a nonenclosed structure.

This is a conservative measure resulting in greater heat release in the early stage of the fire.~Wind effects will not be considered.

Prevailing winds in the area as documented in the FSAR (Ref.7)were reviewed and found to be from the easterly direction.

As such the affects of the prevailing winds in the area would actually benefit this analysis.The configuration of the Turbine Building is such that partial shielding fi'om thc eQccts of the wind will result due to other structures and equipment.

Further, it has been observed that the effects of wind are dampened to a point of insignificance upon entry into the.area where the firc is postulated to occur.Therefore, in an effor to provide conservative results the effects.of wind will not bc considered.

The heat release generated by,thc pool fire size postulated is found by using the formula (Ref.'2, p.3 t): where: Q=heat release in kilowatts m'Žmass loss rate in kg/m's ddt, heat of combustion in kJ/kg A=pool area in m' 0 Cl FTN-FPER-974 l3, Rev, t Page.19\A semithcoretical analysis together with a study of'available experimental',data showed that thc following formula can be used to represent the mass loss rate of a pool fire burning in the open.(Ref.2.3-3).c.,p.//3"=//3"(1-e)where//3=mass loss rate for an infinite diameter pool 0.035kg.lm s (for heavy fuel oil)II 2 k the extinction-absorption coefficient of the fhme P the mean-beam-length conector kP m 1.7 m (for heavy fuel oil)D~pool diameter in meters Calculating the effect of the Gre based on a circular unrestricted pool entirely involved will provide conservative results because by doing so we will be postulating morc complete combustion, unrestricted air Qow and entrainment, an utirestricted Qame structure and that turbine lube oil.will.be present across the surhce of the pool.However, a 20%reduction in the mass loss rate is typically used for pool sizes greater than 10 meters which is based on test results which show incomplete combustion for pool diameters of this size (Ref.2, p.3-5).Additional tests (Ref.5, p.172)conducted to evaluate the faction of total heat release which resulted&om the combustion of various fuels showed heptane releasing as low as 69%of the total potential heat release during its combustion phase.Therefore.

since actual heat release rates will be significantly lower than the theoretical heat release rates, a reduction of 20%of thc total heat release will be used for all estimates of actual heat release.6.6.'2 Ceiling Jet and Plume Centerline Temperatures The area of concern has an ceiling configuration of varying heights such that the.ceiling at the center of the area (A-D, 23.1-25.1) is'at a higher elevation than the remainder, thus forming a pocket (Sec Figure 2).Although some heat will pocket in the center of the area due to the higher ceiling elevation, the remainder of the ceiling area which is lower will transport heat Gom the plume laterally to the exterior.of the structure and to the east of the D column line.The ceiling height east of the D column line is higher than west of the D line and as such the higher ceiling elevation will be used to postulate temperatures anticipated at Thermo-Lag protected raceways in this area.Alpert (Ref.8)reported on the behavior of fire plume and fire induced Qow near ceilings.The tests used to justify the equations derived were of a variety of flammable liquids and combustible materials.

The fire sizes varied as well as ceiling heights and room sizes.Room sizes in many cases.were up to 100 m in width.Therefore, the usc of these formulas for the postulated'case is sound.The following formulas show that the maximum temperature of the plume is dependent upon the ceiling height and radial position&om the center of the plume (Rcf.'5, p.137 and Ref.2, p.2-33).These formulas will be utilized in the development of values shown in Tables 3, 5, 6, 8, and 9.forr>0.18H~2/3 53 Q r max for r c 0.18H (i.e.within the area where the plume impinges on the ceiling)~2/3 16.9Q mix&3/3 H 0 0 0 PTN-FPER-974 l3.Rcv.t Page 20 Q=heat release (kW)r=radius Gum the centerline of the fuel package (m)H=height above the fuel package (m)T=ambient temperature in the area ('C)assumed to be 29.4'C (SS'F)6.6.3 Velocity of Ceiling Jet Flow Similar to the ceiling temperatures there are correlations for the ceiling jet velocities which are dependent on both the ceiling height and the radial distance from the center of the fuel package (Ref.2, p.2-33).This formula is used in Table 3.For r>0.1SH: gl/3 U=0.19-/I'it'/$and'for r 5 O.ISH:~I/3 U,=0.Q III'Q=rate of heat release (kW)r=radius Gem the centerline of the fuel package (m)h=height above the fuel package (m)U=gas velocity (m/s)6.6.4 Sprinkler Response Times Sprinkler response times are dependent upon the characteristics stated above as well as a value known as the Response Time Index (RTI)value.The RTI is a value which results from the sprinkler or heat detector time.constant (obtained&om contmlled testing)multiplied by the square root of the velocity.The formuh shown below for determination of the sprinkler response time (Ref.1, p.10-106 and Ref.2, p.4-5)will be used to determine the time at which sprinklers at various distances fmm the center of the fuel package are antict pated to operate.This will be a rough correlation since the hctor of varying ceiling heights will affect the responsiveness of the sprinklers in the area In addition, this formula is based on instantaneous transport and detection of heat, i.e.not incorporating a factor for the transport lag time.Therefore, due to this and the open nature of the Turbine Building sprinkler response times are assumed to be delayed beyond those times indicated below due to heat transport and dissipation.(Ref.'8, IS, and 16) 0 II RTI T-T~U'-T,~,PTN-FPER-974 f3, Rev.I Page 2l where: , t,=time to operation (seconds)RTI=Response Time index value (l lp.4l5 m's'200 ft's')U~maximum gas velocity (m/s)TM=plume or ceiling temperature (C)(dependent on distance fiom center of pool)T~ambient temperature

('C)T~=operating temperature of the sprinkler head (lpp'C (212'F))The columns shown in Table 3 are based upon a 225 gallon spill of turbine lube oil on the l8'0" with an approximate pool diameter equal to that occupied by a one inch depth of Quid (-I/3 the available unoccupied area on the Qoor bounded by thc"curbed area" (See Section 6.0 for description)).

The table shows the time required to operate sprinklers at various radial distances from the center of thc fuel package.It is also noted that this formula will gg be used later in this evaluation to determine the sprinkler operation in the'remainder of the area after the first sprinklers in the area operate over the fire plume.This is due to thc cooling effects that the operated sprinklers will have on the firc below thereby resulting in lower ceiling jet temperatures, thus effecting whether additional sprinklers will or will not operate.Table 3 Characteristic Temperatures and Velocities and Sprinkler Response Times Associated with Turbine Lube Oil'Fire on the 18'0" elevation Pre4prinkler Activation PodArea38.18m 411 Effective Poof Da 6.97 m 88 ft 0.01 m 4m 0 Cd'.97m 8m 10.66 m 17.37m Heat Rd ease , Pfume Centerline T 3.%m 12ft.7.31 m 24ft.CdT Jet T 3.m 12ft, 7.31 m 4ft.Vd'fCel Jet 3.tS m 12'.31 m 4ft, Tinea sec 48 501.61 614.98 22.71 48 501.61 13.60 501.61 501.61 1,261.38 805.47 645.80 417.70 7.63 5.45 10.79 7.70 48 501.61 48 501.61 48 501.61 565.33 518.28 433.13 274.01 231 40 241 3.81 3.40 2.68 48,501.61 175.28 1.78 3.%m 12ft.7.31 m 24ft 0.64 1.10 238 4.51 4.09 7.99 17.11.10 15.42 20.39 29.02 0 0 PTN-FPER-974 l 3, Rev.l Page 22 6.7-EFFECTS OF SPRINKLERS ON THE ENERGY AND TEMPERATURE OUTPUTS OF THE FIRE General The rough correlation of sprinkler response times calculated in Section 6.6.4 was based on a smooth, unobstructed ceiling in a large enclosure.

The varying ceiling heights in the Turbine Building will affect the responsiveness of the sprinklers in the area.In addition, factors associated with the cooling effects of discharge from the Qrst sprinklers to operate as well as the characteristics of the Qre being three dimensional must be considered.

Sprinklers which activate during the early stages of the Qre will provide cooling of the ceiling temperatures aad make it impossible to predict (by current methods)the actuation times for all sprinklers.

However, due to the postulated Quid being on Qre as it is running down from the operating deck.the ceiling temperatures may be elevated resulting in the activation of the sprinklers outside the plume at the shown.Therefore, the sprinkler response times are assumed to be delayed beyond those times indicated below due to less uniform ceiling jet Qows and the cooling efiects of the initial sprinkler response.Sprinkler activation is assumed to occur within 1 to 2 minutes over half of the curbed area" (See Section 6.0 for description).

Cooling sects and Production of Steam The design density stipulated during the original design of the existing wet~ipe systems in the Turbine Building was 0.3 gpaAt/3000 ft This design density is in excess of the reqttirements of NFPA-13 (1996)(Ref.14)for a Extn Hazard Group 1 hazard.NFPA 13.design densities are coasidered to reflect historical experience with the concept of Qre control/containment.

This presents an area where additional cooling and steam production effects are anticipated due to increased water applicatioa The Qre postulated herein is a three dimensional one.The lube oil coming from the failed bearing seals is'resumed to be Qowing down&om the 42'0" elevation to the elevations below.Upon activation the sprinklers'ill be wetting and cooling the burning fuel near the elevation at which they are installed, i.e cooling the burning fuel before it reaches the floor elevation.

Production of water droplets will lead to significaat cooling of surrounding equipment and structures, thereby reducing the radiative feedback to a fire which is necessary to sustain the combustion process.Evaporation of water droplets create steam with a volume more than 1700 times that of water aad will aid in smothering the Qre since it reduces the ability of the fire to obtain aeeded oxygen (Ref.1, p.5-156).Steam production over the fire will be removing heat Qom the fire which results in lower radiative feedback to the pool.It is not necessary for the sprinkler discharge to remove the heat as hst as it is being released since the Qre is transferring heat to the surroundings as well.In some cases only a small additional loss of heat will be'ufhcient to upset the balance of the chain reaction of the combustion process resulting in extinguishment.

Further, manual fire fighting efforts are likely to be implemented within 5 minutes of the Qre which will provide hose stream Qow directed into the base of the Gre.The 5 minutes for initiation of manual Gre fighting is based on average response times by Gre brigade members during training and actual fire events.The cooling provided by the hose stream will provide additional removal of heat Gem the Qre.Droplets from the sprinkler discharge which contain sufiicient momentum to penetrate the plume will provide cooling of the fuel pool.Steam rising&om the suppression of the Qre in the Coadensate Pump Pit will rise up directly adjacent to the edge of the fuel pool on the IS'0" elevation.

This steam will be entrained into the Qre plume at the base of the fire (combustioa zone)which will aid in smothering the Gre.All of these effects will reduce the overall heat release and plume temperatures in the area aad thus the temperatures resulting within the areas where the Thermo-Lag protected raceways are installed.

0 paste parameters for the wet pipe sprinkler discharge in the area F04-FPER-974t 3.Rey.t Page 23 For the puqeses of calculating a curb height the original design criteria for the closed head sprinkle system (0.3 gpm/ft i3000 fii)shall be applied to the area of concern which has a gross floor area at thc 18'0" elevation of 3026 fi.Based on fiows stipulated by previous system calculations (Ref.I I)for the wet pipe systems in the Turbine Building the demand for the 18'0" elevation over the lube oil fire will be postulated to be 1000 gpm based on the gross area of coverage with afl sprinklers operated (i.e.column lines A-D and 23.1-25.1).Discharge over thc curbed and non~areas will be determined based on their size when proportionaHy compared to the size of the overall gross fioor area.Therefore, the flow of sprinklcrs over the curbed area where lube oil will be present will be approximately equal to (1630.23 fii/3026 ft)'000 9 gpm or 53 gpm and the flow over the remainder of the area outside of thc curbs wiH be approximately 461 gpm.The effects of the sprinkler discharge on the pool size are postulated to be that the pool size will cover thc entire area bounded by the curbs and result in overflow to the Condenser and Condensate Pump Pits.Sprinkler discharge over thc area not bounded by the curbs but located between the A-D and 23.1-25.1 column lines will overflow to the Condenser Pit and discharge through the flood gates located on thc west side of the area.The time step sequence for the addition of water due to sprinkler operation will conservatively assume that II2 of the sprinklers over the area of concern operate at 2 minutes into the fire and the remainder operate at 5 minutes into the fire.The addition of water due to hose streams from manual fire fighting efforts wiH be assumed to occur at 5 minutes into thc fire.Addition of water Pom fixed spray systems The imminent activation of the deluge systems within the area will also be considered.

The Auxiliary Transformer and Hydrogen Seal Oil Unit spray systems are located within the area under evaluation.

The flow rates to each of the aforementioned spray systems is approximated from the total demand of aH three systems (1498 gpm), the known deman'd for the auxiliary transformer spray system (389 gpm)and then approximated for the remaining spray systems based on the total number of nozzies protecting the commodity.

As such the flow rates are as follows: Main Transformer

-1009 gpm, Auxiliary Transformer

-389 gpm and the Hydrogen Seal Oil Unit-100 gpm.The volume of the diked areas were determined to bc-523 gallons for the Hydrogen Seal Oil Unit, and-4,321 gallons for the Auxiliary Transformer.

The drains in each of thee diked areas are routed to the oil-water separator which will allow flow through without separation in the event of a high flow situation.

Under normal conditions the oil-water separator can accommodate an approximate Qow of 100 gpm and still coatinue to perform it's function.In the event of higher Qow rates the separator will allow flow to be directly routed to discharge.

Therefore, back up of this system is not anticipated.

From a conservative standpoint and based upon the discharge rates of the two aforementioned spray systems, overQow wHI be considered to occur.This will present a,worst case runofF scenari for the 18'0" area under review.This will bc conservative as flow is anticipated to be drained to the oil-water separator.

Therefore, the Auxiliary Transformer pit will be postulated to overflow its dike at 11.11 minutes after activation, and the Hydrogen Seal Oil Unit will be postulated to overflow its dike at 5.23 minutes after activation.

Activatioa will be postulated to occur at I minute into the scenario.The effect of the overflow of these systems are shown below based on the available Qoor area outside of thc diked area where the lube oH wiH be contained.

Calculations below will be used to assure that a curb height suf6cient to prevent overQow from/to either side of the curb will not occur.The maximum width of openings from this area is 255 inches.The unoccupied floor space and amount of fluid that can be retained prior to runoff are approximately 713.8 ft'nd 295 gallons respectively.

Thc total postulated flow rate to this area from sprinklers aad spray system overQow is approximately 950 gpm which is less than calculated for the area where lube oil will be contaiaed.

Therefore, based on the greater width of openings in the area beyond the lube oil containment area and aH other factors being aearly equal, the area where thc lube oil will be discharged presents the greater chaHengc for containment and calculations for runoff from the area beyond the lube oil containmeat will not be performed.

0' PTN-FPER-974 t3, Rev.t Page 24 Pool widdi and depth Based on the calculations in Section 6.2, which show that as much as 483.7 gallons of fluid can be retained over the drains, the maximum pool width will be assumed to occur at 5 minutes into the scenario due to the no occupi y activation of thc sprinklers.

The maximum pool area would be equivalent to the Qoor area not ed b structural components or equipment.

As determined by walkdowns the unoccupied gross Qoor area is 1.887 ft~between the A-D and 23.1-25.1 column lines and the unoccupied area to be bounded by the"curbed area" (Sec Section 6.0 for description) wiO be 1173.23 fl (109 mi)(Sce Section 6.3).For the purposes of this evaluation the curbed area will be used to determine water/fuel pool depth and Qow through availahlc openings.Revised heat release rates and ceiling jct temperatures wiO be based on the smaller area bounded by the curbing being thc location of the fire.The effectiv pool diameter which corresponds to the unoccupied floor area bounded by the curbs is approximately 38.65'11.78 m).The pool diameter will be based on a circular pool area and the pool edge will be postulated to bc at the D column line which is conservative.

The actual pool will bc essentially made up of smaller interconnected pools due to the intervening equipment in the area.Calculating the efiects based on a large utirestricted pool wiff result in larger heat release values and temperatures.

A 20%reduction in the mass loss rate will be used due to the pool sizes being greater than 10 m.(32.81 ft)in diameter which is based on test results which show incomplete combustion for pool diameters of this size.From thc 2 minute time step and to final release oi Turbine lube oil a maximum pool area will be assumed.The lube oil reservoir has a nominal capacity of 10,000 gallons (Ref.7).Based on the postulated 450 gpm total Qow rate from failed bearing seals an approximate release time of 23 minutes will result.As such, the total scenario time will bc postulated to bc equivalent to the release time plus five minutes to stop all manual and automatic fire suppression activities and thc time to drain the fluid retention over thc drains at thc 18'0" elevation.

Therefore, based on the drain Qow of 66 gpm via the drains (Section 6.2)and the Quid retention over thc drains of 483.7 gh11ons (Section 6.3), a scenario time of 35 minutes will be postulated throughout the remainder of the evaluation.

'arameters for the determination of heat release In calculating the heat release from this fire a reduction of 50%is taken in both the mass loss and heat release values during the time step sequence from time 2 minutes to time 4 minutes and a 75%of the total heat release and mass loss will be credited from time 5 minutes to time 28 minutes duc to the following mitigating factors, many of which have been discussed elsewhere in this evaluation:

~Full coverage of sprinkfers over the postulated lube oil pool.~Cooling of the burning fuel prior to reaching thc Qoor.~Transient effect of heating thc surroundings are not credittxL~Cooling of other facility surfaces which reduces radiativc feedback to support combustion.

~Design densitics which meet or exceed NFPA 13 (1996)requirements for Extra Hazard Group 1 occup.~Sprinkler spacing over the pool firc is conservative at approximately 60%of the maximum allowed by NFPA 13 which will aid in droplet penetration.

~Large area of ceiling is open to the atmosphere which should aid in promoting a larger loss of heat away from the Thermo-Lag raceways.~Proposed sprinkler additions between the D-I column lines will provide additional cooling of the ceiling jet temperatures.

~NRC approved FIVE methodology allows for a 30%reduction in heat release due to absorption by boundaries in enclosures (Ref.13).~Large pool fires are known to exhibit incomplete combustion.

~Steam generated as a result of sprinkler discharge over burning fuel in the Condensatc Pump Pit wiff be entrained into the fire on the 18'0" elevation which will aid in smothering and cooling.

0 FIN-FPER-97ct3, R09.t Page 25 Based on the amount of turbine lube oil calculated to be present during the time steps shown in Table 4 below.it'can be seen that the available capacity of 483.7 gallons over the drains will be exceeded during the first minute of sprinkler operation.

This will result in runoff to the Condenser and Condensate Pump Pits.Table 4 Heat Release for the Postulated Turbine Building Lube Oil Fire CdntnA Cdtnn 8 utn find Cd ton 9 Cdntn s)Cdtnn H Cdnnt I sit Qe.ar stt QL af Mwtw Cdotnl CdntnK Cdntni.1 d33 91$$425 SS42$5 I 653.75 d~13 I 647.7)232$I 442.73 40).7))0 3)7.7)271,7)105 7)139 73 Sd 14 Iles I I 0 20 221.04 22293 192$4$14 17 So 1$de I.O)411 I.ITI 2)1.113 23 I IT)2)I 17323 I 173.23 I IT)2l$19 I 4590)le 91 17$S)1$.74)0 IS los 99 10099 10$99 los 99 Td 10 dl 21~4.)S)I et Id dl 1.74 304 3$65 1$.25 21 11.7$11.7$11,7$11.7$II.7$10.74 19 SS 17 9$27 95 1195 Il 97 13 97 I)97 01 051 0 51 I.SS t do 1,29 1$4 S I Sell!Sd)IS I$1423 I$4$$4 I 44002 150 22~00.$$400 55 I 170 0S I 1$4.0)9590)ee I dl de2)S.73 de 175 7))4 dl2 Sd 41234)4 dl 1.14 ee 2))4 d I 34 dl)4 dl ote: or oa 0 tune step sequence or sees)stto, cr to loa vo" oo I a pf 6.7.1'Ceiling Set Temperatures with Sprinkler Flow and Reduced Heat Release Using the formulas shown in Section 6.6.2 the ceiling jet temperatures will be calculated using the.heat release data Rom Table 4 above.The formulas utilized are dependent on heat release, radial distance Gom the centerline of the pool and ceiling height.Therefore, where the heat release as shown above in Table 4 remains constant, one calculation will be performed to show the temperatures for the associated time Game.The temperatures shown within Tables 5 and 6 for the ceiling jet are conservative in nature.Actual fire temperatures will be significantly lower than those shown in the following tables.(Refer to the discussion titled"Temperature Profile" in Section 6.1.4).Therefore, it is important to note that maximum temperatures of the ASTM E-119 tim~mperature curve are as follows: 25 min, 821'C (15 10'F);l-hour, 92TC (1700'F);2-hour, 1010'C (1850'F);and 3-'hour, 1052'C (1925'F).Table 5 Temperatures of the Ceiling Jet at 3.66m (12'0")Above the Pool Fire at the 18'0" elevation T f'C)of a's a fail dos i)see a eotestm~af u ttnl 2 to 4 dasol.61 11.7069~.11.7$3.2$1 lt)1.9$5 Ol 1.591.15 1.591.15 1.01 3.22 13.124 lt)I.OI 3.22 649.15 g 44 10000 Bsc=3"457.3$26 24$tt)$1$.2$649.1S 419$1 I Q66 metete 34.9)S tt)433.13 I.4: S41.XI'4 S.tlat 351.$1 17.37 metets 51 It)~C.~~399.00 0't r 26223 Table 6 Temperatures of the Ceiling Jet at 7.31m (24'0")Above the Pool Fire at the 18'0" elevation T of the's ttn f dnteoae fthm ttn onserlm~af tbe tint 2to4 Pod m 6 97 dttSOI.61 3.2$1 11.1$11.7$69.22S.73 34.612.$4 Etr.DIL of Hect Release I meter 2 metets 6.S62 tt)1.00$57 1.270.6$$11.34$11.34 521.5$521.9$3)9.70 4 metets 13.124 0 417.97$metets 2624$It)2577.73.I 2.243 6$274.1$339.10 n4.$7 231.54 rqoae 2$565 05,$~19002 ITS.3$214 45 97 4~11)45 10.66 ments 1737 metete S)tt)

PTN-FPER-97gt3.

Rev.1 Page 26 6.8 FLAME HEIGHT Heskestad in 1983 correlatoi data from difRsion Qames including pool fires using the equation:-=15.6N"-L02 I D where: I flame height above the fuel surface in meters D diameter of the fuel bed in meters N is a dimensionless number derived from a modified Froude number (Heskestad, 1981)and is given by the formula: where: c~~specific beat of air T~temperature of ambient air 4P, beat of combustion Q,~late of beat release (kW)pdensity of ambient air g~acceleration duc to gravity=r stoichiometric ntio of air to volatiles D~diameter of tbe pool in meters However, baaed on standard values (T~293K,g~9.81m'I s,etc.)kJ and that-'3000-3100-, then the equation for fiame height can bc reduced to r kg~2/5~0.23'1.02D which has.been shown to be a satisfactory correlation for values within thc range:~2/5 7kfY'm<<'00kJY'D~2/5 The values of Q,/D for the all postulated heat releases and pool diameters but one fhll within thc acceiltable values for which this formula can be utilized.The lowest heat release is outside the lower bounds of thc accclltablc range.Therefore, although the Qame heights are shown below in Table 7 for all heat release values and are presented for consideration, caution must be applied in utilizing the Qame height value for the lowest beat release value.Table 7 Flame Heights for Varying Heat Release t 501.61 69225.73 34612.84 11.7$11.75~~il llL76 793 5.55 10.11 33.17 25.72

'0 0 1I 0 W-FPER-974 t3.Rev.t Page 27 Further, Zukowski, et.al., as discussed in Drysdale's Fire Dynamics (Ref.'5, p.l34), commented that for (D I;the fame breaks up into a number of smaller flamelets that are apparently indepeadent.

Although the value of->I based oa the results shown in the above table, it must be noted that the above values are based D v ues are upon a circular unrestricted pool.The area in which the postulated spill will occur is occupied by aumerous obstructions including structural components and equipment.

Due to the nature of the postulated spill and the intervening equipment and structural components, the phenomeaoa of smaller fame heights associated with smaller pool diameters may be observed under actual conditions.

However, it is not possible to dcfinitively say this will occur due to a lack of documented tests conducted of pool Qres involving configurations where intervening equipment/structural components such as those existing in the Turbine Building are present.In addition, where a fire source is close to the wall or in a corner formed by thc intersection of two walls, the resulting restriction on fee air entrainment will have a significant effect on the fame length.Flame extension will occur aloag the wall to allow for air entrainment as needed for combustion of thc volatiles.

It is further discussed that where the vertical extent of the fame is confined by the ceiling, the hot gasses will be defiected as a horizontal ceiling j et (Ref.5, p.135).Flame extension for a configuration similar to that postulated here as related to interferences.

ceiling and boundary conditions that exist in the area under evaluation have not been studied.Therefore, no attempt to correlate the potential fame extension which may bc experienced during this scenario will be performed.

6.9 EFFECTS

OF NOT SPRINKLERING VARIOUS AREAS OF THE TURBINE BUILDING Column Lines A-D, at Column lines 27 to 29 and 34-36, l8'0" elevation-The areas bounded by the column lines noted have similar layouts and represent Unit 3 and 4 respectively.

The respective units'ube oil transfer pump and the Steam Generator Feed Pump Room are found in this area.Those sections of each of these areas which contain Qrc related hazards arc currently protected by Qxed protection systems.These include the Steam Generator Feed Pump Room (partial wet pipe sprinklers), lube oil transfer pump (Qxed water spray system)and the pit south of thc coadenscrs (wet pipe sprinklers at two elcvations).

The lube oil reservoir is adjacent to each of these areas to the west of the Turbine Building aad is diked to contain a spill and is protected by an automatic spray system.Essential raceways are aot located within these areas.Turbine bearings located over this area are high pressure turbine bearings.High pressure turbine related accidents resulting the release of turbine lube oil in this area are aot postulated (Ref.9).The evaluation of a postulated tttrbine lube oil release shown above presents worst case for proximity of burning-oiL4aTI tenno.Lag protected raceways.Therefore, the scenario is a bounding case for resultiag temperatures Gem lube oil related Qrcs in the Turbine Building.As a resdt, the Qrc related incidents in this area, being adcqttatcly protected and contained, do not present a hazard to safe shutdown raceways located in other~af the'Fm&a BaHdmg and fbrthcr augmentation of the suppression systems in these areas are aot 6.10 EFFECT OF TURBINE BUILDING CEILING CONFIGURATION AND OBSTRUCTIONS ON ANTICIPATED TEMPERATURES Tables 8 and 9 illustrate the conservatively postulated temperatures that are calculated for various distances 6am the centcrlinc of the Qrc under.the postulated firc condition.

A percentage split of heat release is usaf to determine the approximate temperatures.

The division of heat release to thc mezzanine (ceiling El.42'0")is likely to be significantly larger than thc flow of heat that will ll PTN-FPER-97413, Rev.t Page 28 contribute to the temperatures seen at the 18'0" elevation (ceiling height 30'0").This is the result of the sudden change in ceiling elevation at the D column line.The configuration of the ceiling over the area which includes the"curbed area" on the 18'0" elevation is similar to that shown below in Figure 2.4 2~Q II 30'0" 8~Q N~Q E J Ktglmk Cross section of Qoorlceiling elevations in the Turbine Building at column line 24 (or 3 1)The areas beyond the A and J column lines to the east and west, respectively are open to the atmosphere.

There is existing, between the E to J column lines, dense congestion of equipment and cable trays which will significantly inhibit the flow of smoke and hot gasses beyond the D column line at the 18'0".In addition.the calculations used to determine the maximum temperatures in Tables 5,6,7 are based on a flat unobstructed ceiling.Therefore, the existing analysis for the temperatures at the various elevations, as shown in Tables 5.6 and 7 are conservative in nature for determination of the Thermo-Lag functional integrity.

The temperatures which are likely to be seen beyond the"curbed area" will be significantly less.It is postulated that 35%of the total heat release will contribute to the temperatures on the 18',0" elevation and 65%to those on the Mezzanine level.This is supported by the following:

~FMRC Tests (Ref.21)indicated that the ceiling temperatures at 33'ver the lube oil pool Gre did not exceed 600'F (3 16'C)during the test where automatic sprinkler protection was provided.~Ceiling configuration is irregular rather than Qat (varying heights throughout).

~.Ceiling elevation at the D column line is 42'0".~The D-E column lines are open to the Mezzanine level and provide a means of transport of smoke and hot gasses away from the 18'0" elevation.

~Severe congestion exists directly across from the"curbed area" between column lines E-J and 23.1-25.1 (and 30.1 to 32.1)'Heat loss to surrounding equipment in the area of transport will reduce temperatures.

~Effects of radiant energy on the heat release will be negligible due to loss of a direct line of sight with the majority of the area.~Heated gasses rise.

0 0 PTN-FPER-974t3.

Rev.t Page 29 Table 8.Anticipated Temperatures of the Ceiling Jet at 3.66m (12'0")Above the Pool Fire at the 18'0" elevation a cbe fd docecse&ceo cbe accserbm cf cbe&ed I 0 Cohecst Une BCchecstfcne 1ochecct line K8$mccccs 1556mecccs tcme BK OeL of mescm Pod 1m)2 macss f6562&)$.16 maas.7 maas 4 cnetaS 13.124 lt 3XI&)169375 h)Sl 063 h)155925 1665 517 337.1 21 11.7&12,1121 517 337 I 241.145 01 Table 9 Anticipated Temperatures of the Ceiling Jet at 7.3 lm (24'0")Above the Pool Fire at the 18'0" elevation T C)of cbe a cbe f heacecsce&csn cbe ncccchne of cbe hed D Cchecml'ae 5.16 maes&562 lt)I6937$1t)3.&l lt)13.124 h)hW 51.06)h)474 I 175 I X5.91 6.77 134%2.21 11.7$2cn4 616.ISC)17 262.21 176 I Sc)SI I I 6~\V The temperatures at the ceiling level of the mezzanine show acceptable temperatures at the J line with respect to IEEE 634 (325'F (164'C)).Therefore, consideration of the linear distance from the centerline of the fire (16.875'est of the D line;24'outh of the 23.1 and 30.1 column lines)to the J column line (51 feet from the centerline of the fiie)at both elevatioas will be acceptable with respect to survivability of unprotected cable (cable in trays), The length of time which cable in conduit would survive would be greater.than unprotected cable.internal temperatures of conduits will be less than the maximum predicted in Tables 8 and 9 at the various distances for longer periods of time due to a time lag related to the heat transfer through the steel conduit

7.0 CONCLUSION

S The existing and proposed additions to the active and passive fire protection for the Turbine Building p&c)vide adequate pratectioa of those mceways ia 8>>Turbine Building (column lines A-J, and 22-36)such that further.upgrades to the Tborml~g protected raceways beyond the E column line throughout the Turbiae Building are unnecessary to assure tbo protc)etio&&

of the raceways..

The configuration of diamond plate over the length of the Condensate Pump Pit presents only two areas where surface Qaming in the pit has the potential for communicating with the 18'0" elevation.

These areas are at the stairway leading to the pit from the 18'0" elevation and directly over the Condensate Pumps.The overall size of the openings and the complete coverage of sprinklers in these areas within the pit does not lend itself to becoming The fire analysis presented within this report supports the review of the existing and proposed features.ASTM Test Standard 8-119 (Ref.10)utilizes the standard~emperature curve to establish furnace temperatures during testing of Qre barriers.The standard time<emperature curve temperature of 821'C (1509F)corresponds to the furnace temperature at 25 minutes into the Qre test.This is the temperature at which the 3/4" diameter conduits protected with baseline Thermo-Lag failed the test criteria The temperatures presented in this evaluation for the ceiliag jet temperattues are very conservative with respect to documented Qre tests and do not indicate that this temperature will be exceeded based on the distance at which the protected raceways are located between the D and J-J, column line during a postulated Turbine Building lube oil fire.These temperatures are based on cooliag effects due to sprinkler discharge at the 18'0" elevation and fuel pool location within the"curbed area" (See Section 6.0'for description).

Structural stec:1 supports will retain their structural integrity during the postulated fire due to a limited rise in temperatures as a result of sprinkler discharge.

0 0 PTN-FPER-974t3, Rey.t Page 30 a significant contributor of heat or flame height which would further threaten the protected raceways which arc located beyond the E column line during a postulated Turbine Building lube oil fire.8.0 RECOMMENDATIONS I.All drain covers in the Turbine Building between column lines A-D will bc replaced by slotted covers which provide an equivalent opening of approximately

3.3 inches

in effective diameter opening.2.!nstall curbing to a peak height of nominal 2 inches within the vicinity of the D and 6.5 feet west of the C column lines to prevent the flow of potentially burning combustible liquid Rom spreading beyond the area evaluated.

Suggested location for curbing is shown in Attachment B.3.Modify the existing water supply to extend the design area of tbc sprinkler system to provide coverage over an area of 5000 tt plus 500 gpm for manual hose streams for thc wet pipo system and the maximum low anticipated for the fixed water spray systems in the area.4.Modify the existing wet pipe system in the Condensate Pump Pit (south section)to replace the sidewall sprinklers with standard upright sprinklers (intermediate temperature) spaced in accordance with the requirements of NFPA l3 for an Extra Hazard occupancy.

5.Install additional sprinklcrs as Shown on Attachment B.6.Maintain conservative sprinkler head spacing for all sprinklers to bc add+to the areas where Turbine Lube Oil is postulated to occur.7.Modify the existing grating (other than the stairs)in the Condenser/Condensate Pump Pits to solid diamond plate.

0 4l 0 PTN-FPER-97413.

Rer.0 A1TACHMENT h Letter, Texaco to Florida Pawer and Light (R'Conrad), dated March 12.1997 (11 PAGES) 0 0 4'Mls pxaco 4t3.a.0 Aaaehmeat A Page t of t 1 March 12, 1997 Ms.Roseann Conrad Turkey Point Nuclear Power Plant FPL Company P.O.Box 4332 Princeton, Horida 33032

Dear Ms.Conrad:

Enclosed'please Gnd a compositional disclosure for Texaco product code 00700 Regal KLO 32.Please note that this information is considered confidential and is provided solely for use by your environmental, health and safety professionals.

Also attached is the Texaco Material Safety Data Sheet (MSDS)for this product.We consider the Texaco MSDS to be our privy means of hazard comnnuucation for all our products.As products are reforntulated or product information changes, any new information will be re6ected in the current Texaco MSDS.We trust this information will satis8y your needs.If we can be of Rrtler assistance, please do not hesitate to contact Paula Beach at (914)838-7530.Tlmk you for using Texaco products.PMB:jms Enclosure (1)cc: ECB 4l 0 0 AVTACHNHVT hfamh 12, 1Ssr PTN-FP>.97'3 R p Atuchmeat A Page 2 of 1 I OOOO R AL RC 3 Solvent<ewaxed heavy paraffinic petroleum distillates 2,&<Mart~phenol Methactylic aad, copolymer 64742650 128392 CBI CBI 56631891:.~'yRANGE-%%':." 95.00-99.99 0.1-0.99 0.1-0.99 C NFlOEN Supplier Confidential Business information

-s ir v~+~~~."*"4~',(jt~

",'i~i,B<+<)pp,p&~Pp~JL~P~I

'l pate aauedr 1 a a 12m 10 1004-10-01 MATERIAL SAFETY DATA SHEET 04$/20 NQTK: Read anci under'atancl Mater1al SaFety Oata sheet before handl1ng or diapoaing OF product.CHEMICAL PitQ ANl~ANY ID NTI I TION MATERIAL IDENTITY Pr oauct Code and Haver 00700 REGAL RAO 32 Cheeroal Narme and/or Farwrly or'eacr rptronr Turbine 01 la ManuFacturer

'Melee and Adcll'eaa:

TEXACO LUBRICANTS COMPANY A olvlsloN QI'KxAco REFININce AND MARrcET?No INc.P.O.'box 1427 HOuaton, TX 77210-1427 W-FPER-974?3.

Rcv.0 Attachmcrl?

A Panic 3 of l I Tel ephone Nuropera: Tranaportat ton Eser gency-Corxpany r (914)CHEMTRKC (USA): (000)In Canada: (000)Heal th Emergency-Coopany r (914)Gener el MSOS Aaaiatance (911)Texaco Faxback Syatea (713)Tecnnica I?nidor rmat ion-Fuel a: (014)Chee ical: ($12)-Lubricant/:

(000)AntiFreeaea/Fuel-SOlventa: (000)5 DN/N ORNA ON ICN 031 3100 424-9300 507 T154 031 3400 030 7204 ,432 3303 030 7330 450~0543 702-7052(Option 4)Additivea F 70 3730 THE CRITER?A FOR L?ST?NO COMPONENTS

?N THK COMPOSITION SKCTIQN IS AS FOLLO'W5: CARC?NQOKNS ARK LISTED WHEN PRK5ENT AT 0.1 5 OR ORKATERI COMPONENTS WHICH ARK OTHERWISK HAZARDOUS ACCORD?NO TO OSHA ARK LISTED WHEN PRESENT AT 1.0'A OR GREATER: NQN HAZARDOUS COMPONENTS ARK LISTED AT 3'.0 5 OR QREATER.THI5 IS NOT?NTENOEO TO BK A COMPLETE CQMPOSITIQNAL DISC(.OSURK.

REFER TO SKCT?ON 14 FOR APPI.ICABLK STATKS'?OHT TO ICNOW.ANQ OTHER RKQULATORY INFORMAT?ON.

product and/or coeponent(a) car'cinogenic According to: OSHA IARC NTP OTHER NONE X C~ai ti on:, (Seqwnce~r anrS Cheaica)Kaee)Scca, cheer 1 Ira 01~SOI Vent-deVaXed heaVy Parafirinid Petr elan d1at 1 1'I atea 04742 050 95.00-90.90 PRODUCT IS NON HAZARDOU5 ACCORD?NO TO 05HA (1910.1200)

~COMPONENT,.

BY DEFINITION, IS CONS?DERED HAZARDOUS ACCORDINO TO OSHA BECAUSE IT CARRIK5 THK PERMISSIBLE EXPOSURE LIMIT (PEL)I'OR IIINERAL Oll.MIST.Expoaur~Lieita referenced by Sequence Nunber 1n the corepoaition sect1on Se, rei t 01 5 rwg/N3 TWA OSHA MINERAL OIL MIST)01 5 rrrg/e3 TWA~ACOIH (MINERAL OIL MIST)01 10 rrrg/e3 STKI.ACQIH (IIINKRAL OIL M?ST)0?F T Ql EM Rr?v vl Appearances Light pal~liquid t Odor: Mi lcl odor A NONE CQNSIOKRED NECKSSARY N.D.NQT DETERMINED c LESS THAN PA(NI 1 N.A.NOT APPI?CABLE:GREATER THAN N.T.NOT TESTED k 0 Pkp CPOE: OOTOO NANCE: REQAI RAO 22 HAZAJtp P I CAT ON 1)4L Date Issued: Suporsodos I 1SSS 1O Oi lolzS Healtnr 1 ReaCtivityI 0 Flammaoi'I Ityr I SDoci4l NFPA'vealthI I Reactivity:

O FlammaoIIIty:

1 special POTENTIAL HEALTH EFFECTS KYK Pr teary Route of Kxposuroi SKIN INHAI ATION INGESTION EFFECTS OF OVEREXPOSURE ACute: Eyes I May Cauae mintmal irI'I tat ion.Oxper IenCOO aa temporary disccmfc~t.

Skin:~SI Iei'ontact may cauSO sl ignt II I Itation.Pr Olonged contact.aa vitn cloth'Ihg wetted vI th mater'I el~may Cauae mere sever 4 II'I I sation and die comfort.seen as local I edness are swelling.othoI than the Dotential sk1n irI itation effects note4 anove, acute (shor t teI.a)adver se ei'facts ar~not expected fI oa DI Ief skin contacti soe otnor~I facts, oelow, ind section 11 for Information I egaedlng potential long tera effects.PYN-FPER-974(3.

Rev.0 Attachment A Page 4 of I I Inha l at 1 oni vapor s or mist, in excess of Deraissibl

~concentrations.

CI in urkIsuatly high concontI'at14na geneI'ated from sDI ay1ng.heat1ng tris aetaI ial OI's I'roa exposuI 4 in coolly ventilato4 aI eas or confined spaces.may cause Ir I i,tatson of the nose and throat~headache.nausea.and dt owsfnaaa.Ingest1on:

If more than sever'al mouthfuls~Ie swal lore!.aodoainat discomfort.

nausea.sn4 diat'I'nea I%4y occur i Sensi tfxatton P~l'ties: Unknovn.Chronic: No advol so oi'I'ec'ts h4vo neon documented

'in humans 44 4 I'esul't of chronic exposuI e.section 11 aay contain appl fcaD1~aniaal data.lfed f cal Cond i t 1 one AgSN'avaied ts)r Kxposupel because oi'ts III itating proper ties.repeated skin contact may aggravate an exIsting dermatitis (skin condition).

Other Remarks: Matol'I at I'I oa high pl'assure oguipeont, pinhole leaks~CI'igh pressure 1 iris rai lure can.penetrate the skin an4, 1f not properly tI'sated.can cause severe Inluly,.inCluding dfsffgureeent, loss of functiOn.or even reqvfr~smoutation oi'he affected area.To pr event sucn sei'ious injury, Immediate medical attention should De sougtlt even if'ho InIectfon.

InjuIry SDDOOI S ta De efnol'.F IltS AIO Eyes: Flush eyes with plenty of water for several a1nutes.Oet medical at~entIon If eye irr itation persists.Qc1 hi Vaan Skin vitn plenty Of Scap and Vater fOI SOVOI al ainutea.Oet Oed1Cal attention 1f skin irritat1on develops ot'ersists.

IngeSt 1 ohi Ii'oro tean seveI'al mouthfuls of'his aateti~1 ai~oval loved give tvo t glasses of vatei (ib 42,).get medical attent1on.

nha1 at I oni If Irr itation, headache, nausea.CI drowsiness occurs.I eaove to fI'esh~1I'et medical attsnt1on if Dreathing necomes difficult or I espfratory irt Itat1on persists.N.O.NOT OKTKRIIINKO LESS THAN PA(NI 2 N, A~NOT APPLICAbI.K

-"CRKATKR THAN N.T.NOT TKSTKO 0

REOAL RAO 32 Al 11EASUR ()4L pate ssuedc I sac 12 is Supersedes c Isle 10 01 Other'nstruct 1 one 1 Rieove and cr y<<clean or launder clothing soaked or so1'led vith this eater ial oefore reuse.oty cleaning of contaainated clotning say cog~effective than no<eal launder ing.Inform in4iviouals responsiol

~for cleaning of potent tal hazards associate4 vith nan41 ing contaainatag c I othing.H tgh pr essur~In)ect ion of eater 1a I can cause severe In jury.Fai lure to odor coe tne wound of al I r es14ual material can result 1n 41sf I gut eaent, loss of functlon, or say reouit~aaputation oi'he afi'ected area.5.P l R QHTI~-FPER-974(3.

Rev.0 Attachmau A Pago 5 of I I IgnitIon Teeper ature-Al Not deter nlned.plash point (degrees P): 395 (CQC)Plamabl~Lieits (%)I Lover: No'1 octal Oined Upper: Not cater ecned.(degrees): Receded Pire Extinguishing Agents And Special Proceduresl USe water SPr ay.dry Cneeical.foae.or caroon 41ox14e to extinguish flaw.Use vater spray to cool fire-exposed containers.

vater or foae may cause frothing.Unusual or Explosive Hazards 1 None i el Protective Eguipaant for Pi ref ighters:@eat ful I protective Clothing an4 poaItive pressut~bl eathing apparatus.

1.ACC E ALR L ransportat 1 on Spi s: (EOO)<2i SOOO)procecares in case of Accidenta ease, reakage or Leakage: vent i late ar ea.Avoid preathing vapor.wear appropriate personal protective eoulpeent.

Including appropi iate respiratoty protection.

contain spill Ii'ossicII

~.vipe up or apsot1 on suitapl~eaterial and shove)up.prevent entry Into severs and vatervays.

Avoid contact v1'th skih, eyes ol c I otning.T~HAfs)LINO Afa)S precautions to De Take in Handl ing: MInleuIs feaslt)le handling t~ratures should oe eaintained.

5tor age I per cods of exposut'e td high t~ratures shoulcl oe einieized.

'%ter contao inat ion shOuld De avoided.EXPOSURE protect I ve c+I Ype Eye/Pace Protect loni safety glassea.Cheeical type goggles.oi face shiel4 r ecomended to prevent eye contact'.4 Sk in Protect loni worker s should vash exposed skin sevei al tiees daily arith soap and vatet'.Soiled vork clothing should be laundere4 or dry-cleaned.

N.O.NOT DETERMINED c-LESS THAN PC%'N.A.NOT APPLICAILE

'-CiREATER THAN N.T.NOT TESTED 0

I P RO CO: OOTOO NAttEI REQAL RLQ 32 EXPOSER ROLS/PERSONAL PRO ECTZON 4L Date I SSued: 1S a 12m ia Supersedes:

lese 1O Ot Resp i r story Protect]on: AiI'bor'ne concentrations should be keoc co lovest levels posslbl~.vapor.IAISC Or Ouat IS generated and the OCCuoatlonal exDOSure 1 lett of product, or any coeoonenc oi'he proctuct.ls exceeded, use approor late NIQsH or'MsHA Appt owed air purifying or'ir suDDiled resDirator after cecerIIIning the air borne Cbnoentration of the contaIIInaht.

Alr Supplied resDir atorS Should always be worn vhen air berne conoentr'ation Of.Che cancaninant or Oxygen COntent IS unvhovn.Vent 1 1 at ion: Adeouace co Iieet colliponent occupational exposur'1 leits (see section 2).Exposure Liatt for Total Procatct: None eatab 1 I shed I'or't'oduct I I'ef er'o Sect lon 2 for coeponent.exposure 1 lsICS.s.pHTstcAL Afe)cHEttz pRop s Appearance

'ight Pal~1 lould'Odot".ill 14 odor Io111ng Po1ni (degrees P)1 Not decereined itelting/Preexing point (degrees P)i Not appl loaD 1~., Speoif 14 Orav1ty (wateriit)1

.8845 pH of undiluted procatot: Noc applicapl~Vapot'ressure:

Noc deteI'Ill ned.PTM-FPER-97413.

Rev.0 Attachment h Pago 6 of li V 1 seas 1 ty: 31.5 cSt at AO.OOC Content: NOC Oet~I'eirled.Vapor Density (air wt): Noc deter eined.Solubt 1 I ty in Itatet'%):

NOC decerII1nedo Other I None 10.STAII LITT V Th1S Ilatertal Reacta V14 etlt y ltlthl (tf otner s is checked beloit.see coweents t'or details)A lr water Heat Strong Oxidizer s other a None of These X Cental Ncrle ProcaActa Evolved ithen Sut)Sectect to Heat ot Coacattonl Toxic levels of carbon isceoxide.

carbon d1oxide.ir r itating aldehydes and ketohes.N.O.-NOT OETERlttNED c LESS THAN PAQEC 4 N.A.NOT APPLICAILE GREATER THAN N,T.NOT TESTED

~i" 0 I Pea CDO: 00100 NAME: REOAL RLO!32 11.TOXZCOLOOI CA).IN)IOR)CATION 4L Date Iaauedl 199S~12" 19 Supersedes:

199d 10 Of TOXICOLOGICAL ZNl'ORMATION(ANIMAL TOXICITY DATA)Med1 arl Lethal Ooze Oral: LD50 Believed to be i 5.00 g/ky (rat)pt'actical ly non-toxtc Znn4)ation:

Not deter sthed.Dertaa 1: LD50 Bel teved to be i 2.00 y/kc (rabOIt)PI aCtICally hon-toxIC Ir I.i tat(on, Index, Est feat(on of Zrr 1 tat1on (Speci ea)Skint (Dt'atze)Bel laved to be)~50 3.00/9.0 (rabbit)sl igntly Irr Itatihg Eyes: (Dratze)Believed to be c 15.00/110 (I'abblt)no appt actable effect Sensitization:

Not deterrathed.

Othenl None 12.DISPOSAL CONSZDERAT (PCS Haste 01 zpoaal Methods This pr oduct haa bach ev4lu4ted fot'CRA ch4I'actet Iatica and coca hot eeet the CI 1 tet'Ia of 4 hazar doua waate if dIacat'ded in 1ta put cnaaed fot e.under RcRA.It Ia tne r eapoheibi I ity of tne uaer of tne pt oouct to oetet-ntne at tne t tee of diapoeal.whether the pt'oduct oeete RcRA cr iter 14 for hazat'doua waste.Th14 14 becauae pl'oduct uaea.tf'ahaf creat iona, eixtuhea.proceaaea, etc.Ittay t'ender tne teeultiny eater 1ale hazardoua.

Raaarks None TRANSPOR IN)IDRMAT ION TI ansportatlorl DOT: phoper Shipping Haes1 Not I'egulated

~E'ER-914(3.

gcv ()A(fzchmeni A>8b 7 of 1 l IlCOt2:, Propec Shi pp iny Naas: Not I'e(tu)ated ZCAO)proper Shf ppfng Naael Not I'egu 1 ated TOO: Propel Shf pping Naeel No't I'egu 1 ated 14.RKGLILATORY IHF f edet'4)Regs let 1 ons I SARA Title ZII1 Section 302/304 Cxt~ly Hazardous Qdmtances~e.Choei 1 Na A Nu None Sectfon 302/304 Kxt~ly'azardogs SuOstances (CONT)~a~PIP a~None Sect(on 3f 1 Hazardous Categoc fzatfoff1 t ACute Chr Onio iir~Pr assur~Section 313 Toxic Chsellcal Chee1ca 1 Nattt React1ve N/A X N.Q.-NOT DETERMINED c-LESS THAN PAOC 5 N.A..NOT APPLICABLK GREATER THAN N.T.NOT TKSTKO 0 0 t I 0 1 paQ coo: 00100 4: REGAL RAO a2 ie.0 KR INFORMA It%()HL gate ISSued1 1 sag>>ta>>13 Supersedes 1 tIS4-10-01 TO OETERMINK.

APPl.ICA4ll ITY OR KFFECT OF ANY LAV OR REGULATION VITH RE5PECT TO THK PROOUCT.USER SHOULO CONSULT HIS LEGAL AOVISOR OR THK APPROPRIATE GOVERNMENT AGENCY.TEXACO OOKS NOT UNOKRTAKE TO FURNISH'AOVICE ON-SUCH MATTERS.'Qata:~I996 I t9 PHv oaie pr rlta4:~9$T 1 X Rev1sed, Suoal Sedea: Indulge les regarding MSOS should oe directed to: Texaco Inc.Manager, Product Safety P.O.Sox 50g 8eacon~N.Y.12504 PLEASE SKK NEXT PACK.FOR PRORJ~LASKL PTN;FPER-97413.

Res.0 Attachment h Page 9 of I I e N.O.NOT OKTKRMINKD c LESS THAN PAOI I 1 NOT APPI,ICA4LK

'GREATER THAN NOT TKSTKO

.C C Pko COOK 1 00100 t NAÃdt RKQAL RAO 32.14.REQ/LA Y I QÃNATIQN ()4L Oste Issued 1 1eee-12 Supersedes 1eaa 10~41 CERCLA 102(a)/OOT Hazardous Substances:

(+lhdlcates'OT Haaardous Subst~>~50.Chew i cs 1 Naa Nu oe mares n v, Nohe cKRcLA/QQT Haaardous substanc>>s (sequenc>>letsoers and Rq s>:~5~.Rll None TSCA Inventory Status: Thie Oradudt.Ot'ts Caleldhehta, ar~I1Sted oh Ot at'exehct froh, the Toxic suostshce cohtt ol Act (Tscl)chehical suostahce Inventory.

Qthet".Notie.State Regulat tons: ca11f ornl a.propos1t 1 on IS: The fol loving detectaol~cohoohents of this Product er~substances.

or oelohg to classes of suostehces.

xhovn to the State of california to cause cancet ahd/or reproductive toxlc1ty.Chetit 1 katio r No tie Internet 1ona1.Regul at lons 1 VlolZS C'1 ass 1 f teat loni Not regulated Canada Znventory Status;This product, ot'ts cohoohehts, at~1 1sted oh ot'l'except f roe,the canadian oohesttc suostahce List (osL).~~EINECS Inventory Status: Not octet hihed.Austral la Inventory Status: Not deterh theo.Japan Znventory Status 1 Not deter'h i hed o 15.ENVZROHIENTAL INFORM ZDN Aduat 1 c Tox1c1 ty1 Not.deter>>1 hed.Mob111ty'ot detel'>>1tied.

Pers1stence ahd S 1 odeeradabi 1 1 ty: Not deterh1heda Potentl al to Sloaccamslaiet Not'etet'h 1 rie4 Reaarks: NOne 10.0 R NFONCA{Xl*~FP8497413 Rcv 0 Attachment A Page 8 of I I Ndrie THE INFORlllTIQN CONTAINED HEREIN IS SKLIKVKD TO SE ACCURATE~I'T ZS PROVIDED INDEPENDENTLY QF ANY SALK OF THK PRODUCT FOR PURPOSE QF HA2ARO CCNaHICATION AS PART QF TEXlCO'S P'RQOVCT SAFETY PROGRAM.IT IS NOT INTENOEO TO CONSTITUTE PERFORMANCK INFORNATION CQNCERNINO THK PRODUCT.NO EXPRESS VARRANTY.OR IMPLIED WARRANTY'0F IIKRCHANTlSI(.ITY QR FITNESS FOR I PARTICULAR'URPOSE I'AQK'WITH RESPECT TO THE PRODUCT OR THK INFORMATION CONTAINED HEREIN.DATA HKKTS ARK AVlll.ASLK FQR ll L TKXACQ PRODUCTS~YOU ARE UROKD TO QSTAIN DATA HEETS FOR ALL TEXACO'PRODUCTS YOV SUY.PROCESS, USK OR OISTRISUTK ANO YQV ARE ENCOURAOKO ANO REQVESTEO TO ADVISE T'HOSE VHO IlAY COllK ZN.CONTACT VITH SUCH PRODUCTS QF THK INFORNATION CONTAINED HERKIN.'PIOI1 N.O.-NOT OKTERNINKD N.l.NOT APPLICASLE N.T.NQT TESTKO-LESS THAN OREATKR THAN 0

PRO NAMCI RKQAL R&0 32 I 1.P LAR L O'L cate Issuedt 1$12 le Supepsedee I 1994>>10 01 Labe Date: 1$10 01 READ ANQ UNOKRSTAIC)

MATERIAL SAFETY QATA SHEET SEFQRE IIANQLINQ QR OISPQSINO QF PRODUCT;THIS LASEL CQliPLIKS ltlTH THK REQUIREMENTS QF THK OSHA HAZARD COMMUNICATION STAIE)ARD (29 CFR't910.1200)FOR USK IN THK VORKPLACK.

THIS i ASKL IS NOT INTE)4)KD TO SK USKD VITH PACKAQINQ INTENDED FQR SALK TO'ONSUMERS ANO IIAY NQT CONFORM VITH THK REQUIREMENTS OF THE CONSUMER PRODUCT SAFETY ACT OR OTHER RKLATKD RKQULATQRY REQUIREMENTS'0100 REQAt.R&O 32 NONE CQNSIOKREO NKCKSSARY PR Y-avotd prolonged, breathing of vapor.mist.Or gas.-workers stlauld wash exposed skin several ttmes daily with soap and water.PTN-FPER-97413.

Rcv.0 Attachment h Page 10 of ll~FR~A Kye Contact t F lusn eyes with plehty of water fol several minutes.Qet medical at'tent toh I f eye 1 I'r'I tat 10h pops'I sts~Qctn Contact: wastl Skirl witt)Pletlty Of Soap shd water'ot'everal mtnutea Qet medtcal attentton if skin irritation develops or persists.Ingestion:

If mor~than sever al mouthfuls of thts aatertal at'swallowed, give glasses Of watet't4 0$.)~Qet med1Cal attent10n.

Ihhalatton:

If trrttatton, headache.nausea.or drowstr>>sa occur s.remove to fresh atr.Qet medical atteht10fl tt'peattlttlg becomes diff tcult otesp1I'story iri'ttattoh Pei'State.

Note to Physiotan:

Htgn pr essut'e th)ecttoh of material can cause severe injury.Fatlur~to~~~~~~~debr t de the woutld of a I I residua I matap I a I cah pesUI t ttl dt sf 1gupeeeht, loss of I'unction.

or may r equtre amputation of the affect'ed ai'ea.~F In case of f tre.use water spray.'t'y cheitcal, foaa ot'arbon dioxide.water may cause frothtng.Use eater spray to cool f tr e exgosed contatnets.

Chemi I Name Solveht>>dewaxed heavy papafftntc peti oleua dtattllates A NU I Ra th QT12 45 0 9$.00 99.99 PRODUCT IS NON HAZARDOUS ACCQROINO TO OSHA (1910.t200)

~COMPONENT, SY DEFINITION, IS CONSIDERED HAZARDOUS ACCQRDINQ TO OSHA 8KCAUSK IT CARRIES THK PKRMISSIILK K)(POSURK LIIIIT (PKl.)FQR iiINKRAL Oll MIST.P hna lv nta 1 I Ncne NESS Hea I th I 1 React tvttyt 0 Flammability:

1 Special R tn NAPA Health: 1 Reactivity:

0 Flaeeabt It'ty: 1 Special Transportation DOT: Proper Shtpptng Not I egul ated C~cAUTI0N: Misuse of eiM)ty container s can be haxapdous.

Eepty containers cah be hazardous 1f used to store tox1C, flaeaabt~.Op peact1ve"mater tale.cutttng ot'eld1ng of empty containers eigtlt caUse f tr~, exPIOSIOn OP tOXIC fueea, ft Oe t eatdUW.DO nOt Preesut tse ot'xpose to open f 1 see 0I'eat.Keep cohtatpxwIosed ahd dpue bungs in place.N.O.NOT DETERMINED l.KS'S THAN~AOI I 9 N.A.NOT APPL,ICAILK QRKATKR THAN N.T.NOT: TKSTKD 0 II 0-1 1 R OO OO REOAL RLO 42 LAI L (Otter ISSQC5'95+~12~19 SUPt$050$101i 10 01 04tO'990~10 Ol lianul'actorsl" 9 Naae and Aodroiel TEXACO LVIRICANTS COMPANY A OIVISION OF TEXACO REFININQ ANO IlARKETINO INC~R.O.Sex i'i27~eton, TX 77210-ii27 TRAN R RTAT oN Il RC Y CosDeny1 (914)I31 3IOO calENTREc:

(joo)iai-9300 PTNMER-97%

t3.Rev.0 AttachmeRI A Page I I of 1 l H A TH II RO Y CNOOny: (9 1 i)03 1 3iOO 0

PTN-FPER-97@i 3.Rev I Page 32 ATTACHMENT B Suggested Locations for Addition of Sprinklers and Curbs to be Installed in the Turbine Building (2 PAGES)

r'8E

.p~0 0 QQ I~'j I I I al (I I'I J II il il il~~I!I I.il I II I ep I j.I I I B.L.ae J ceo~ri I II j.J~I J O C3 O LLCLIO I~WOO~~%@%I>>II>>r>>I>>I>>40~III%MID>>Ir>>404>>I>>>>>>II r~r>>>>a>>III eeae Inane aaa anna e.r PWI LLEZZANLLE EEYEL EL 30'M>>II Il>>r Wtllsl aMS I>>~8 fdic t>>01(CMH Ilfll>>WIL LLYCL fl fVIII>>I W It fLOteA tOrlt 4 LICIIL tlat Itf~~1 OIL Ilf>>CI>>IL>>l

~

~'.Cl fgt, I ,I at<PP't'P tY~I I~~~I r pc%~E--%--~LCOCIO I ovsv Ic Ke4 vrtr rvArw Ltvp e w 0-I 0 I'I H L J L J W~-~"~~~o: L jgDI m%CD 00 e GIlIZD QzzzrrrO 0 0 0 y\'\%5 l I%\'\4\l\V l l\\'\5 pc g V't~%%\%1~I'l l i>J 0$$4 IV VEND~IVMAC LrrVV NN IVVV Ig VVRS VIVI RA OgeAV N W r~f1 f1 rI J r~II%II tCVV IMtllrr lsVI I a~fllNOA tCVLC i LOLL 0 et 4t a fIOC ttOLLCTION COOLOO f LOON tLAN Ll.LF lf O OLLOV tlat frLL LI&IL JII ICvrf al~~V I 0~" Q'p L~0!I Temperatures in flames and fires I http:/hwvw.aone.corn/~o/flametmp.html Temperatures in flames and fires Dr.Vytenis Babrauskas, Fire Science and Technology Inc.Introduction It is unfortunately not too rare to find that Gre investigators estimate fame temperatures by looking,up a handbook value, which turns out to the adiabatic flame temperature.

Statements are then made about whether some materials could have melted, softened, lost strength, etc., based on comparing such a flame temperature against the material's melting point, etc.The purpose of this short paper is to point out the fallacies of doing this, and to present some more appropriate information for a more realistic assessment.

First, we must point out that measuring of Game temperatures to a high degree of precision is quite difBcult, and many combustion research scientists have devoted decades to studying the task.The dHBculties come Gom two sources: (1)intrusiveness of instrumentation; and (2)interpretation difBculties due to the time-varying nature of the~~~~~~measurement.

Non-intrusive (e.g,, optical laser techniques) methods are available, but these are difBcult and expensive to make and are generally not applied to the study of building Gres.In most cases, thermocouples are used for temperature measurement.

These have a multitude of potential errors, including surface reactions, radiation, stem loss, etc.A whole textbook is available on the subject of instrumentation for studying flames[1].As'e see below, the flames of most interest for unwanted fires are turbulent.

This time fluctuation presents tremendous dif6culties in making measurements and in interpreting them meaningfully.

Such flames move about in little"packets." Thus, a measurement at a single location returns a complicated average value of reacting and unreacting packets flowing by.Some of these issues are elucidated in[2].Even careM laboratory reconstructions of fires cannot bring in the kind of painstaking temperature measuring technologies which are used by combustion scientists doing fundamental research studies.Thus, it must be kept in mind that fire temperatures, when applied to the context of measurement of building fires, may be quite imprecise, and their errors not well characterized.

1of6 Flame types Before we discuss details of flame temperatures, it is important to distinguish between~~~some of the major flame types.Flames can be divided into 4 categories:

o laminar, premixed laminar, diffusion 05/06/97 09:06:26 0 0 45 Temperatures in tiames and fires http:lhvww.aone.co mls/tlametmp.html 0 laminar, diffusloQ 0 turbulent, premixed 0 turbulent, diffusion An example of a laminar premixed flame is a Bunsen burner Qame.Laminar means that the flow streamlines are smooth and do not bounce around significantly.

Two photos taken a few seconds apart will show nearly identical images.Premixed means that the fuel and the oxidizer are mixed before the combustion zone occurs.A laminar diffusion flame is a candle.The fuel comes&om the wax vapor, while the oxidizer is air;they do not mix before being introduced (by diffusion) into the Qame zone.A peak temperature of around 1400'C is found in a candle flame[3].Most turbulent premixed lames are&om.engineered combustion systems: boilers, furnaces, etc.In such systems, the air and the fuel are premixed in some burner device.Since the flames are turbulent, two sequential photos would show a greatly different flame shape and location.Most unwanted fires fall into the category of turbulent diffusion flames.Since no burner or other mechanical device exists for mixing fuel and air, the lames are diffusion type.~~~~~~~Adiabatic flame temperature When one consults combustion textbooks for the topic of'fame temperature,'hat one normally finds are tabulations of the adiabatic flame temperature.

'Adiabatic'eans without losing heat.Thus, these temperatures would'be achieved in a (fictional) combustion system where there were no losses.Even though real-'world.

combustion systems are not adiabatic, the reason why such tabulations are convenient is because these temperatures can be computed&om fundamental thermochemical considerations:

a fire experiment is not necessary.

For methane burning in air, the adiabatic Qame temperature is 1949'C, while for propane it is 1977'C, for example.The value for wood is nearly identical to that for propane.The adiabatic flame temperatures for most common organic substances burned in air are, in fact, nearly indistinguishable.

These temperatures are vastly higher than what any thermocouple inserted into a building fire will register!'Flames temperatures of open fiames For convenience, we can subdivide the turbulent diffusion flames&om unwanted fires into two types: Qames in the open, and room fires, First we will consider open Qames.t The starting point for discussing this topic can be the work of the late Dr.McCaQrey, who made extensive measurements

[4]of temperatures in turbulent difRsion flames.He used gas burners in a"pool fire" mode (i.e., non-premixed) and studied various characteristics

temperatures in ttames and fires http:liWww.aone.coml~o/flametmp.html

~~of such fire plumes.He described three different regimes in such a fire plume: 1.Slightly above the base of the fire begins the continuous flame region.Here the temperatures are constant and are slightly below 900'C.2.Above the solid Qame region is the intermittent flame region.Here the temperatures are continuously dropping as one moves up the plume.The visible Qame tips correspond to a temperature of about 320'C.3.Finally, beyond the flame tips is the thermal plume region, where no more flames are visible and temperature continually drop with height.French researchers at the University of Poitiers recently made the same types of measurements and reported numerical valu'es[5]indistinguishable

&om McCaflrey's.

Cox and Chitty[6]measured similar plumes and obtained very similar results: a temperature of 900'C in the continuous flame region, and a temperature of around 340'C at the flame tips.The latter value does not appear to be a universal constant.Cox and Chitty later measured slightly higher heat release rate fires, and found a flame tip temperature of around 550'C.In a later paper[7], researchers

&om the same laboratory examined turbulent diffusion Qames under slightly different conditions, and found peak values of 1150-1250'C for natural gas flames, which is rather higher than 900'C.The above results~~were&om fires of circular or square fuel shape.Yuan and Cox[8]measured line-source type fires.They found a temperature of 898'C in the continuous flame region, and a flame tip temperature of around 340'C.This suggests that such results are not dependent on the shape of the fuel source.In studying fires in a warehouse storage rack geometry, Ingason[9]found an average solid-Qame temperature of 870'C.At the visible flame tips, the average temperature, was 450'C, but the range was large, covering 300-600'C.

In a related study, Ingason and de Ris[10]found typical fame tip temperatures of 400'C for burner flames of propane, propylene, and carbon monoxide fuels.In the SFPE Handbook, Heskestad[11]recommends, using a value of 650'C for the temperature rise at the Qame tip, i.e., an actual temperature of about 670'C.This seems notably high compared to the experimental data cited above, and Heskestad does not provide any explanation where his value comes&om.Also in the Handbook, Mudan and Croce[12]summarize some continuous-Qame region measurements for various liquid pools.With the exception of a few data points, most values lie between 827'C to 1127'C.The variations appear to be more attributable to experimental technique than to type of liquid being burned.Most of the values are for quite large (many meters in diameter)pools.Fundamental radiation considerations would suggest that smaller pools might show e somewhat lower temperatures, but data to demonstrate this point seem sparse.Curiously, in a later study[13], Heskestad adopts a criterion of 500'C for the flame tip temperature.

Taking all of the above information in account, it appears that flame tip temperatures for i 0 Temperatures in flames and fires http:/Pwww.aone.corn/~oNametm p.html turbulent difRsion lames should be estimated as being around 320-400'C.

For small flames fess than about 1 m base diameter), continuous flame region temperatures of around 900'C should be expected.For large pools, the latter value can rise to 1100-1200'C.

Flame temperatures in room fires There is fairly broad agreement in the fire science community that flashover is reached when the average upper gas temperature in the room exceeds about 600'C.Prior to that point, no generalizations should be made: There will be zones of 900'C flame temperatures, but wide spatial variations will be seen.Of interest, however, is the peak fire temperature normally associated with room fires.The peak value is governed by ventilation and fuel supply characteristics

[14]and so such values will form a wide frequency distribution.

Of interest is the maximum value which is fairly regularly found.This value turns out to be around 1200'C, although a typical post-flashover room fire will more commonly be 900-1000'C.

The time-temperature curve for the standard fire endurance test, ASTM E 119[15]goes up to 1260'C, but this is reached only in 8 hr.In actual fact, no jurisdiction demands fire endurance periods for over 4 hr, at which point the curve only reaches 1093'C.The peak expected temperatures in room fires, then, are slightly greater than those found in fice-burning fire plumes.This is to be expected.The amount that the fire plume's temperature drops below the adiabatic flame temperature is determined by the heat losses Rom the flame.When a Qame is far away&om any walls and does not heat up the enclosure, it radiates to surroundings which are essentially at 20 C.If the fame is big enough (or the room small enough)for the room walls to heat up substantially, then the Qame exchanges radiation with a body that is several hundred'C;the consequence is smaller heat losses, and, therefore, a higher flame temperature.

Temperatures of objects It is common to find that investigators assume that an object next to a flame of a certain temperature will also be of that same temperature.

This is, of course, untrue.If a Qame is exchanging heat with a object which was initially at room temperature, it will take a finite.amount of time for that object to rise to a temperature which is'close'o that of the Qame.Exactly how long it will take for it to rise to a certain value is the subject for the study of heat transfer.Heat transfer is usually presented to engineering students over several semesters of university classes, so it should be clear that simple rules-of-thumb would not be expected.Here, we will merely point out that the rate at which target objects heat up is~~~~largely governed by their thermal conductivity, density, and size.Small, low-density, ow-conductivity objects will heat up much faster than massive, heavy-weight ones.4of6 05/06/97 09:06:36 0 0 Temperatures in flames and fires http:/Avww.aone.coml~olffametmp.html

~~References

[1]Fristrom, R.M., Flame Structure and Process, Oxford University Press, New York (1995).[2)Cox, G., and Chitty, R., Some Stochastic Properties of Fire Plumes, Fire and Materials 6, 127-134 (1982).[3]Gaydon, A.G., and Wolfhard, H.G., Flames: Their Structure, Radiation and Temperature, 3 ed., Chapman and Hall, London (1970).[4]McCaQrey, B.J., Purely Buoyant DifRsion Flames: Some Experimental Results (NBSIR 79-1910).[U.S.]Natl.Bur.Stand., Gaithersburg, MD (1979).[5]Audoin, L., Kolb., G., Torero, J.L., and Most., J.M., Average Centerline Temperatures of a Buoyant Pool Fire Obtained by Image Processing of Video Recordings, Fire Safety J.24, 107-130 (1995).[6]Cox, G., and Chitty, R., A Study of the Deterministic Properties of Unbounded Fire~~~~Plumes, Combustion and Flame 39, 191-209 (1980).[7]Smith, D.A., and Cox, G., Major Chemical Species in Turbulent DifRsion Flames, Combustion and Flame 91, 226-238 (1992).[8]Yuan, L.-M., and Cox, G., An Experimental Study of Some Line Fires, Fire Safety J.27, 123-139 (1997).[9]Ingason, H., Two Dimensional Rack Storage Fires, pp.1209-1220 in Fire Safety Science-Proc.

Fourth Intl.Symp., Intl.Assn.for Fire Safety Science, (1994).[10]Ingason, H., and de Ris, J., Flame Heat Transfer in Storage Geometries, Fire Safety J.(1997).[11]Heskestad, G., Fire Plumes, p.2-13 in SFPE Handbook of Fire Protection Engineering, NFPA/SPFE (1995).[12]Mudan, K.S;, and Croce, P.A., Fire Hazard Calculations for Large Open Hydrocarbon Fires, p.3-203, op.cit.[13]Heskestad, G., Flame Heights of Fuel Arrays with Combustion in Depth, in Fire afety Science-Proc.

Fifth Intl, Symp., Intl.Assn.for Fire Safety Science (1997).[14]Babrauskas, V., and Williamson, R.B., Post-Flashover Compartment Fires, Fire and Materials 2, 39-53.(1978);

and 3, 1-7 (1979).5 of 6 0

1 emperatures in llamas and fires http:Ihvww.a one.corn/~a/flam etmp.html[15]Standard Test Methods for Fire Tests of Building Construction and Materials (ASTM~~~~E 119).American Society for Testing and Materials, Philadelphia.

Written 28 April 1997.Copyright1997 by Fire Science ond Technology Inc.

V 0 0 0 180 loire Technology Anotnei r that needs to be evaluated is the effect of particle size on the nitrogen gas requirements.

Fmm these investigations we ob-served that particle size does have some effect on the gas velocity required to avoid surging, i.e., the larger particles require a higher velocity, Hence, there should be some effect on the gaa Qovr rates required to expell a given dry chemical flow rate.We hope to evaluate these effects during future research work in the area of dry chemical flow and pressure losses.Calculation of Response Time of Ceiling-Mounted Eire Detectors a tO CD CA CD CD R.L.AI PERT Factory Mutual Research Corporation An understanding of the behavior of the fire plume and fire-induced flow near the ceiling of a room is necessary if one is to optimize detector response time and placement.

CO tO 00 IDh C)CO O NE of.the most important problems in fire protection is the rapid detection of fire in a room whBe the fire is sufficiently small to be easily controlled.

Such small, controllable fires generally exist for more than Mf a minute after ignition when lames are confined by inert bar-riers or air gapa to a distinct portion of the total avaBable fuel, Subse-quent to this initial period of relatively constant fire intensity, there is usually a period of rapid fire spread to surrounding combustible materials.

The resulting fully developed fire may aho be of nearly constant intensity but large enough to endanger the buBding structure in the absence of a sprinkler system, It is thus desirable to det'ect a fire as quickly as possible.CeQing-mounted devices that do not interfere with normal room ar-rangement are generaBy preferred for fire detection.

Pinding optimum values of spacing, placement below the ceBing, and sensitivity for such devices in all possible room geometries is a rather complicated problem.The problem can be simplified, however, by assuming that the ceiling is essentially smooth, horizontal, and large in unobstructed area.There are two main types of fire detection devices.One type is actu-ated by, radiation, a significant portion of the total thermal energy release in a fire.The most couunon devices, however, depend on a movement of hot products of combustion directly to a sensor.These combustion products contain the remainder of the thermal energy release in addition to suspensions of fine particles and droplets (smoke), Thermally actu-ated detectors and smoke actuated detectors constitute the second class of detection devices, The object of the subsequent discussion is to Mly describe tlie fire-induced environment in which thermally actuated and Names: This napcr was prosontcd et the Zsth Annual Mcethg of the Nationa1 Fire Protection tion on May 18, 18Z2 h PMadslphis, Pa.l81 O t4 0 0 102 Pire Technology smoke ated detectors must operate, so that in certain cases, the response tiine of these devices can be calculated.

PIRE-INDUCED CONVECTION Buoyancy causes the hot products generated in a five to rise to the ceiling while mixing with room air to form a fire plume.Impingement of the fir plume on a ceBing, as shown in Figure 1, resuiis in a gas Qow near the ceBing even at a considerable distance from the five axis.It is this Qow that is responsible for transferring hot gases ov smoko particles to the thovmally actuated and smoke-actuated group of tieLocliiili Iievices.Since R knowledge of the fire-induced Qow is particularly vaiuabie if the response time of such detectors is to be optimized, a detailed scientific I:tcldy of the fire plume and the near-ceiling Qow resulting from'tlie plume Iins been undortaken at Factory Mutual Research.Only smooLh, hori-.zontal ceiTings are considered in the study, although it should not be dif-ficult, using the methods described herein, to extend the results to most typL, of ceiling, Two parameters of considerable importance in any discussion of fire-iliduclxl convection near a ceiling are the rate of heat released by the burn-ing fuel and tho ceBing height above this fuel, Experimental data indicate tliat these two parameters, properly defined, generally determine the major characteristics of the fire-induced flow.The ceBing height, H', henceforth refers to the distance between the uppermost burning fuel surface and the ceBing, while the rate of heat release, Q, is consistently the product of the rate of the fuel weight loss and the maxhnum theo-retical heating value por unit mass of fuel.In reality, only a portion of the maximum combustion energy is transferred directly to the flow, but this portion may be about the same for most ordinary combustible materiahi.

The period of rapid fire spread a short time after ignition usually results in a rapid increase in the magnitude of the heat release rate.If, during such periods, the magnitude of Q doubles in less than about one minute, the near-ceiling Qow wBl ba somewhat different in character from that due to a constant rate of heat release.Although the study described herein is only applicable to the latter caso of constant or slowly varying Q, many real fires will, in the initial or final stages (after flame spread), have such a slowly varying heat release rate.Basic research on fire-induced convection at Factory Mutual healed to development of a theoretical analysisi for predicting gas velocity, temperature, and dimensions of the near-coiling Qow induced by constant intensity,"small" (Qamo zone maximum dimension.

much less than ceil-ing height)fires.This analysis, which extends work previously done by Morton et al'n fire plumes, is in excellent agreement with measurements obtained during"small" fires beneath Qat ceiTings 4 ft to SO ft in height.However, the air Qow induced by such small fires is easily afi'ected by room Gee hat of nomenclature on page 184.~irc Detectors l83 ventBation and often will not trigger ceiling-mounted detectors.

arger fires, on the other hand, are of greater interest for practical detection de-vices.An experimental and theoretical program'as, therefore, been~~~~~~~~~undertaken to study convection associated with large fires for which J lames are often comparable in height to the ceiling.Epri tsd igth ot t o tio tdy p fo d~I at the Factory Mutual West Glocester Test Center and involve the use-of several different combustible materiah, As shown in Table 1, heat release rates for these experiments range from 38,000 to nearly 6,000,000 g,(p~~Btu min I while coiling heights from 16 to 61 ft are used, Figure 2 is~cz,~~an example of the heptane spray fire produced by 8 nozzles located on a 12-ft diameter circle.The plume can be seen impinging on a ceiling 26 ft above the nozzles and spreading out radially in a thin layer near the ceiling.For all the large-scale tests shown in Table 1, the radially spread-ing ceiling fiow is obstructed by walh only at distances 100 ft or more from the fire axis.In addition, the test building is either ventilated at ceiling level or data is obtainod only when the accumulated layer of hot gas and smoke is far from the floor.'I BMPBRATUIlB MBASURBMBws Extensive measurements of gas temperature have been made during the test fires in order to determine how gas temperature, T, varies with CELln-NWJEo FRE oETEcTNI>C~t nEAs.eELcia Fura r (----1~C I I i I I I I I FIICK PINK I I'ill i'll P~~'ft (~Figurc l (Above).Schematic rlivgram of tile gac/lola induced by a fire.Figure 2 (Right).Photograph o/the hrp-tane cproy fire.Ccifing bight abave eprav nacelce ic 26 ft, ond heptane iloui rote le 12.gpm.o lo la co Ca~\Cb co 00 CA o o o 0 Cl T4tnLs 1.Summary of Fire Tests&irc Technology Fuel Fuel array sire tft)Fire intensity Ceiling height (Btu min I){t)Heptane spray Heptane psn in 90'orner Ethanol pen Wood pellets in 90'orner Cardboard bores Polystyrene in cardboard boxes Polyvinylchlotide in'cardboard boxes Polyethylene psllete 12-ft diameter 2 by 2 3.2 by 3,2 4 by 4 by 6 high 8 by 8 by 16 high 8 by 8 by 16 high 4 x 10'o 1.3 x 10l 6.8 X 10'8 X 10'.8 X 10'2 X 10'.8 X 10'6, 28 26 28 20 46 46 8bysbyl6high 2 X10'by 4 by 9 high 2.4 X 10'o 8.6 X 10'1 for r greater tlian 0.18H and: 14.9 Q'." T.-T, HIh (2)for r less than or equal to 0.18H;where temperature, T, is in'F, heat distance, Y, below the ceiling at several radial distances, r, from the fire axis (see Figure 1), It has been found in each case that, outside the fire plume, i,ho maximum gas temperature, T, occuiu a fow inches from the ceiling and that temperatures decrease to near the"room tempera-ture" value, T, a fow feet below the ceiling (see diagram in Figure 3), The exact locations below the ceBing where T~T..and where T ap-proaches T are a function primarBy of ceiling height, radial position, and thermal characteristics of the ceiling material (transfer of heat through the ceBing causes a small decrease in gas tempemture).

All available experimental data show that, when the hot gases are vented some dis-tance kom the fire or when there is only negligible accumulation of stag-nant hot gases, T, occurs a distance below the ceiling of tto more than 1 percent of total ceBing height whBe T approaches T a distance below the ceiling of 6.5 percent to 12.5 percent of total ceiTing height.Within the fire plume, experiments show that gas temperature in-creases with vertical distance, Y, below the ceiling.However, for distances below tho ceiling to 5.5 percent or even 12.5 percent of total ceiling height, there is a negligibly small increase in gas temperature kom the value at the ceiling.From the measurements of gas temperature described here, it has been found that all data on T., the maximum gas temperatur'e at a given radial position near the ceiling, can be correlated by the equations:

4.74 (Q/r)'" (1)H.Io Io CO CD~~W ll00~alt I~I~<SCIViI'"nt 4>0NI I.WIN%0 hr 440eh CD CO CD CD hO Figure 3.Gas temperature close to the fi ceiling for a typical large-scale fire.Ceil-ing ie a height, H, abooe fuel burning with heat.releate, tII.SM~N~20 h 4IO'0441itt tan&'F il~Iolt Itua 4+CtaN 0~Ion 0 lo 20 00 CO 50 4 htOAL 00'tiler rhett rat Are (lti It can be seen&om Figure S that T..is nearly constant for a radial distance hem the fire axis of about 18 percent of the ceiling height.Be-yond this point, which actually corresponds to the outer boundary of the fire plume at the ceiling, there is a rather sharp drop in gas temperature with radius, r, until the ambient or room temperature value is approached.

As expected, gas temperature at all radial positions, but especially near the fire plume, decreases as the ceiling height increases.

All of the t@nperaturo measurements used to derive Equations 1 and 2 were made with the burning fuel either a minimum of 300 percent of total ceBing height from the nearest wall obstruction or practically in contact with wall obstructions.

Gas temperatures obtained from Equations 1 and 2 should, in fact, be valid for a wide range of fioor areas as long as the fire axis h either immediately adjacent to walls or at least 10 fire plume L6ti o lgh I Fire Detectors 185 release rate, Q, is in Btu min', and ceiling height and ran sition (H and r)are in ft.These empirically determined relations for gas tempera-ture and similar types of relations for gas velocity are in good agreement with the previous theoretical analysis'or a"small" fire.Typical values of Tnear the ceBing are shown in Figure S for a one-mBlion Btu min'ire beneath ceBinga of various heights, H.Gas temperatures would increase from room temperature to the values shown a short time after the attainment of the one-million Btu min'ire in-tensity.At later times, gas temperatures would not change significantly if the hot gases were vented or not aHowed to accumulate, Insufficient venting of the hot gases would result in a gradual increase in all gas tem-peratures at a rate that depends on the room size.

186 Fire Technology radii, a 80 percent of total ceiling height, from the nearest wall, In the former case, the minimum wall to wall distance should be about 180 percent of total ceiling height, and a modified value of fire heat release rate, Q, must be used.If, for instance, the burning fuel is adjacent to the 90'orner formed by two walls, the appropriate value of Q is four times the usual value while, for a fire adjacent to a single Qat wall, Q is twice'he usual value.The preceding rules have been verified by fire tests in a simulated room corner (see Table 1).VarnctTT MithstnNMsNTs Measurements of gas velocity, as well as temperature, have been made during fire teats similar to those discussed above.These experi-ments mainly yield the maximum gas velocity, Vat each radial position, r, outside the fire plume and the gas velocity near the ceiTing within the fire plume.The gss velocity data can be correlated quite well by the following equations:

0 26 Qlh Hl/2 V.=(S)for r greater than 0.15 H and V...-1.2-(4)20 I CC Nia/C Nr 20IC cog'err/eh

"~iO rt/Cr r>CN5N lt~L2al/Nt" rco/0N NI Colt Figure 4.Gas I/docity dose to the ceiling ,H, or a typical hrge-scots fire, Ceiling is a eight, H, above fuel burning Iofth heat re-lease, q.0 P 20 30 Co 50 60 r ICAaAI.05TIoct;INCsC twe AX5 tICI for r less than or equal to 0,16H, where V., is in ft sec.-I Calculations of gas velocity from Equations S and 4 are shown in Figure 4 for a one-mBlion Stu min i fire intensity.

In much the same manner as the gas temperature, the velocity is nearly constant in the fire plume but decreases sharply with radial distance beyond the fire plume.A rather unexpected result shown in Figure 4 is the increase in gas velocity with increasing ceBing height at radial positions outside the fire plume, This effect is due to the increase in the mass of hot air rising to the near-ceBing Qow as the ceBing height increases.

As noted before, the gas velocity in Equations S and 4 refers to the ire Detectors 187 axhnum value at a given radial position.This maximum v en-erally found quite close to the ceiling.Although gas velocity is nearly independent of distance below the ceBing within the fire plume, a velocity considerably less than V., would be measured outside the plume if the distance, 7, below the ceiTing is suflicientiy large.Evidence available from small-scale"model" fires'ceBing height 2-4 ft)indicates that, outside the plume, the gas velocity in fact approaches zero at approxi-mately the same distance below the ceiling where the gas temperature approaches room temperature.

For both temperature and velocity, there-fore, the value of 7 at the lower edge of the near-ceBing Qow outside the plume is f'rom 6.6 percent to 12.6 percent of total ceiling height.It is expected, as a result, that beams or structures at the ceBing protruding downward a distance less than 1 percent of ceiling height will not disturb" the Qow.Such ceiTings could stBl be considered"smooth".ULTIMATE SENSITIUITY OF FIXED-TEMPERATURE RATING FIRE DETECTORS The preceding description of the near-ceTiing Qow induced by"real" fires forms the basis for an analysis of heat transfer rates to objects, in-cluding the ceBing itself, immersed in this Qow, Specifically, it is now possiblo to compute the rate at which heat is transferred to the sensing elements of thermally actuated detectors by utBizing the equations for Qre-induced gas velocity and temperature, No amount.of heat transfer to a detector will cause it to actuate, however, if the detector is of the fixed temperature thermostat type and the gas temperature is below the fixed temperature rating of the device, It is, therefore, possible to determine the ultimate sensitivity of such de.tectors since the gas temperature as a function of ceiTing height, radial position, and flre intensity is known from Equations 1 and 2.If the detector is assumed to operate only when tho maximum near~ing gas temperature, Tfs greater than the fixed temperature rating, Ts, then from Equation 1, the gnyllqyf, detectable'fire intensity, Q Iis!9~I.-r f(Tc.-T~)H/4.74]'" (6)as long as the radial distance, r, f'rom the fire axis to the detector is greater than 18 percent of total ceiling height.When r is less than 18 percent of H, the detector is effectively within the boundaries of the fire plume, thus requiring the use oj Equation 2, which yields: y t, t(Tt,-T,)/14.9P" H'" (6)To be conservative, it is assumed that the fire axis is as far as pos-sible fxom any individual detector, The radial distance to the nearest detector in a square array of spacing, 8, then becomes: r S 2i(7)o ro to lt co C/I~0 lo cn co OO o o Ol 0 0 0 OPTIMUM LOCATION OF FIRE DETECTORS CeBing-mounted fire detectors should be located so that transfer of heat (thermaHy actuated)or mass (smoke actuated).to the detector is maximized in order to minimize the response time.It is thus necessary to calculate heat and mass transfer rates induced by a firo.IO'8 7 6 5 g-T~220'F X%~i'F 10 9 5 T TL-Tie'55'F Figurc t).Smallcet far tittanttty, t)I I, that can bc rtctcctcd by a thcrmottat Iuilh a fixef tcmperaturrr ratfng, Zg 188 Fire Technology V~uations 6 through 7 aHows tho smaHest detectable fire in-tensity,I, to be plotted"in Figure 6 as a function of ceiling height and the fixed temperature rating, Tc, of thermostats on a M-ft by 20-ft spacing.It is seen that, even for a 136'temperature rating (assunung T 80'), a ceiling mounted detector S5 ft above the burning fuel wiH only respond to a fire intensity greater than 100,000 Btu min', which is equivalent to the combustion of 1 gpm of heptane.The response time for this combination of Bre intensity, ceBing height, and temperature rating wouM probably be unacceptably long, since the thermal inertia of detectors only aHows rapid actuation when the gas temperature is far above the actual temperature rating of the device, Thermal inertia can be simulated, however, by assuming a 136'rated detector will respond in a reasonable time when gas temperature is greater than 300', which means assuming Tz-T is 220'For this detector.Figure 6 shows that such a detector mounted at a ceBing height of S6 ft wB1 only be actuated by a fire intensity greater than one-million Btu min'equivalent to a 9 gpm heptane fire).Fire Detectors HEhT TEhNSFEE RhTE O 189 The rate of heat transfer to an object in a Qow of high temperature gas is usuaHy expressed as the product of a heat transfer coefficient and the temperature difference between the gas and the object.Detector sensing elements are generally so smaH (compared to either the fire plume diameter or the total thickness of the near-ceBing Qow outside the plume)that the heat transfer coefficient to a given sensing element wiH be nearly, proportional to the square root of gas ve/ocity, V, and independent of temperature'.

Furthermore, the temperature difference behveen the gas and sensing element is simply the quantity T-T, as long as the sensing element is nearly at its initial stato of room temperature.

Of course, the sensing element is gradually"warmed up" (above room temperature) by the fire-induced Qow.The heat transfer rate, q, to the sensing element of a detector is, there-fore, given by the foHowing proportionality:

q~C (T T)Vltt (8).where CL is content for any one detector.Proportionality 8 is vaHd at any location in the fire-induced Qow before the temperature of a sensing element changes significantly.

With-In the fire plume, the nearmBing heat transfer rate, qis obtained by substitution of T,.and Vfrom Equations 2 and 4, respectively, for T and V in the proportionality.

This substitution is possible because'gas temperature and velocity in the portion of the fire plume near the ceil-ing do not chango significantly with vertical distance below the ceBing (for Y as much as 12,6 percent H).Outside the fire plume, the near-ceBing heat transfer rate, q, is obtained by replacing V'with the equivalent expression, (V/V,.)V,.and by substituting for V., kern Equation S and by simBarly replacing (T-Tr)and substituting f'rom Equation l.Both'Equations 3 and 1, it should be noted, are indeed applicable out-side the plume.The near-ceiTing heat transfer rate outside the fire plume relative to that within the Bre plume is then simply the ratio, q/qwhich is giveti by:/q, 0.16 (V/V)Ln (hT/hT)/(r/H)" (9)ifr/H is greater than 0.18, where 4T~T-T.By definition:

(10)IO CO CO CD 2xlo'~I4tfi I20 IL a 20 fL sFhctta)20 50 40 50 60 CGLNG If3GHT (IL)within the fire plume, where'r/H is less than 0.18.Although q, does not change significantly as long as the vertical dis-tance, Y;below tho ceBing is much less than ceBing height, both V/V., and T/T, and hence q, are strongly dependent on K Both V and dT, in fact, approach zero when Y is from 6.6 percent to 12.6 percent of ceB-ing height whBe V V, and T~T when Y is about 1 percent of H.C)o 0 0

~~190 Fire Technology LO 02 0$I 02 0 Y/II~(Nl SCLO Lt/LS h/q,e055W~IAT/ALJ/Tr/Hr 4TI T.T Y/H Iaido I\02 0/I OAi OJI IO I 2/lH IIATO OF RAOAL DSTAICE FKu f tIE AXCI TO CELNO HIKHT Figure 6.Heal transfer rate ta raam temper-ature objects Hear the eeiliIIg relatiI/e to that irI the fire plume ar OI/er the fire.Mhss sFER RhTE The transfer of combustion produch, such as smoke, to suitable de-tectors in the near-ceBing fiow is a mass transfer process similar in many respects to the transfer of heat.For example, the rate at which mass is transferred to an object is generally expressed as the product of a mass transfer coefBcient and the difference between the mass concentration (1bm ft~)in the fiow and that close to the object.A theoretical analysis does, in fact, show that the mass concentration of a given constituent (such as smoke)in the near-ceBing combustion products should always be proportional to the excess of gas temperature over room temperature, T-T,.The difference between the mass concentration in the near-ceiling flow and that close to or within a smoke detector wBl also be pro-portional to T-T, as long as no significant quantity of smoke accumu-lates in the detector.Furthermore, it is easBy shown that the maes transfer coefBcient in Rows similar to the fire-induced fiow should be proportional to the heat transfer coefBcient.'ass transfer rates should thus be pro-portional to heat transfer rates to a given detector or the quantity q/q, is identical to the ratio of near-ceiling mass (smoke)transfer rato outside'he plume to that within the plume.Equations 9 and 10, as a result, probably describe how the transfer of smoke to detectors is affected by detector position and ceiling height.OPIITuM HEhv TahNsvaa Res Calculations of q/q, obtained both from Equations 9 and 10 and kom data on hT/hT..and V/V., as functions of Y are shown in Figure 6.It is seen tliat the rate of heat (or smoke)transfer to detectors is always close to the maximum value for a ratio of radial position to ceiling height, r/H, less than about 0.18.However, there is a sharp decrease in q to about half the maximum value at r/H=0.30 if the vertical position, Y, is less than 3 percent of ceiling height.There is also a sharp decrease in q just outside the plume if the vortical distance Y below the ceiling increases to 6 pere'ent of ceBing height, In fact, the heat transfer rate outside the plume is never more than 10 percent to 20 percent of the maximum value, as Fire Detectors 191 shown by the trend of the curves in Figure 6, if a detector is ted more than 0.06H below the ceBing, The htter result should not be silrpi'is-ing because the total thickness of the hot gas layer outside the plume can be es small as 6.6 percent of ceiling height.It is clear from the preceding that the maximum heat or mass transfer rates (and hence minimum response times)wBl.be attained for detectors located a radial distance kern the fire axis less than about 18 percent of.total ceiling height and a vertical distance below the ceiling of from 1 percent to 3 percent of total ceBing height, Values for r and Y should not be much less than 0.18H and 0.01H, respectively, since tlmre is no sig-nificant improvement in heat transfer rate above the maximum value for r less than 0.18H and there is actually a slight decrease in heat transfer rate for Y less than 0.01H due to ceiTing kiction and heat loss.With r equal to 0.18H, Equation 7, therefore, shows that the spacing of detec-tors in a square array should never be less than about Ve of ceiling height.Such a minimum spacing for optimum response time would not ordinarily be practical with ceiling heights less than 40 ft, although detector spacings in use are oftenless than the minimum Yh of ceiling height for ceiling heights of 60 ft or more.Detector sensing elements, as a result, should be a vertical distance koin the ceBing of 1 percent to 6 percent of ceiling height and should be spaced at intervals no less than 26 percent of ceBing height.In order to find the TIutxtmttm possible detector spacing, specific detaBs of the ceiling-mounted detector and the intensity of the fire must bo known in addition to the pre'ceding heat transfer information.

The maximum pos-sible spacing can be determined quite easily, however, if tho detector is thermally actuated with a fixed temperature rating.In this case, Equa-tion 6 yields the maximum posmble radial distance, r, between'the fire axis and the detector, since, for the following value of r, gas temperature just equals T/r Q/.f4,74/H(Tt,-T)P" (11)where Q t.is the smallest heat release rate which must actuate a detector.If the value of r from Equation 11 is less than 0.18H, then the desired value of detectable fire intensity, QI, must be increased.

Once r is determined from Equation 11, the maximum possible spacing can be ca'lculated, for instance, by use of Equation 7.CALCULATION OR DETECTOR RESPONSE TIME FOR FIXED TEMPERATURE RATING In the earlier discussion of convection, characteristics of the fire-induced fiow near the ceBing are related to the fire intensity or heat re-lease rate, the ceiling height, and the location of a detector, The response time of all thermaBy actuated detectors can, in principle, be derived kom these relations if sufficient information about the sensing element of the.detector is avaBable, With such information, even the response time of o ta CO o Ol o o o 0 0 192'ire Technology detecto ated by the rate of rise of gas temperature can be calculated as long as the fire heat release rate both is known at all times and does not double in less than about one minute.It is simplest, for the present discussion, to consider only a constant fire intensity that must be detected by a ceiling-mounted device with a fixed, temperature rating.Both the heat release rate during the growth of the fire to this constant intensity and the time necessary to establish the steady fire-induced fiow are ignored, These effects, however, prob-ably have an equal and opposite infiuence on the detector response timL For a fire.induced gas temperature, T, that does not change with time (due to the assumed constant fire intensity), the time, t, it takes the thermo-stat detector to reach the rated temperature, Tc, from an initial room tem-perature, T,, is given by the well-known relation':

t~Ch'og f(T-T,)/(T-Tc)], (12)where C is a constant dependent only on the thermal inertia of the de-tector sensing element and h is the coefiicient of heat transfer at the de-tector.Calculation of C from known characteristics of the sensing element is, of course, possible.However, it is quite cii0icull; to determine the absolute magnitude of the heat transfer coe5cicnt, h.Not only is this quantity proportional to the square root of near-ceiling gas velocity, as noted before, but also the proportionality constant is dependent on fiow detaBs caused by the shape of a specific detector and sensing element, A more convenient procedure than the direct use of Equation 12 is the calculation of response time, t, during a'fire rehtive to the response time, tmeasured during a standard fire test Such a test might well be similar to that described in the Factory Mutual Approval Standard for thermostat fire detectors.

The time for a detector to be actuated by a fire is then found from the product of a measured value of t.and the com-puted ratio t/t>>It is easily shown with the use of Equation 12 that this ratio is given by: t/t (V./V)l ts log t1-hTc/hT]/i og (1-~Tc/<T.](13)tlTc=Tc-T,, dT T-T, etc, where V, and T.are the near-ceiTing velocity and temperature, respectively, during the standard test and (V,/V)>>s is a ratio of heat transfer co-eScients.If it is assumed the detector is positioned su5ciently close to the ceiling (&om 1 percent to 3 percent of ceiling height)for V and T to ap-proximately equal V..and T...respectively, Equations 1 through 4 can be used together with Equation 13 to give the result: r greater than 0.18H t/t,~(Q./Q)>>s (H./H)>>s (r/r.)'n'og[1

-ATc (r/Q)sis H/4,7]log t1-ATc (r./Q.)'" H,/4,7](14)193 Fire Detectors r less than or equal to 0.18H (Q~/QH.)>>s lpg[1-ATcH>>/14.7Q>>3]

log[1-ATcH,'"/14.7Q,'"]

where Q., r., and H.refer to standard test conditions, Q is the heat re-lease rate of the fire to be detected, r is the maximum radial distance between detector and fire axis, and H is tho ceihng height above the burn-" ing fuel.A plot of t/t, from Equations 14 and 16 appears in Figure 7 for the following standard test conditions:

ceiling height of 15 ft, detector spacing.of 20 ft by 20 ft (r.14.1 ft if an equally spaced, square array is used), and heat release rate (presumably from a pan or liquid spray fire).of 160,000 Btu min.'he fixed temperature rating is taken to be about 13o'and the magnitude of Q identical to Q.ui this figure.As a result, Figure 7 yields detector response time during a 160,000 Btu min'ire relative to that during the standard test and thus a t/t.of unity for H 16 ft, r~14.1 ft.3330 so 3~Slsll so3335olll Figure K Itesponse time of a fixed temper-e ature thernuetat during a typical iarge-ecale jtre relattc3e to response time during a standard test.o.T 0.$os OA 3Ilsal gxc32olll 3In a)ll~35la ll,~35 ll 3,~Isla Q I L53lO'533333C3 i'4'cere.s5 55 15 55 s5 75 ll cccsa leslis set'l'he sharp increase in response time with either ceiling height or de-tector spacing h dearly shown.It is also seen that, for each spacing, the fire can be detected in a reasonable time only if the ceiling height is less than some maximum or limiting value.In accordance with the previ-ously described concept of a minimum detectable fire in*tensity, the magni-tude of this limiting ceiling height for each spacing can be obtained di-rectly from Equation 6 or 6 with Q;,~Q..If the heat release rate of the fire to be'detected is not that assumed for Figure.Z,,the proper value of Q could be substituted into Equation o CO CD C33~~I O3 CD CO C33 0 0 Cl l94 Fire Technology 14 or rder to determine t/t..The"proper" value of Q would have to be estimated from the known composition and arrangement of the combustible materials, a difficult task indeeP.The calculation of response time either from the equations or from Figure 7 will be most conservative if the magnitude of the ceiTing height is taken to be the total distance Born floor to ceiTing rather than from the top surface of the burning fueL If, then, a fire actually occurs at a position in the fuel array well above the Qoor, the actual detector response time would be much less than the value calculated.

Shorter than calculated detector response times would also result if the fire actually is located in a corner or adjacent to a wall, but the value of Q is not modified to take this into account.CON CLUSIONS 1.Fire detectors should be located a vertical distance below the ceil-ing of no more than 6 percent of the ceiling height.2.For optimum response time,'ire detectors should be spaced at intervals of Y<of the ceiling height.Spacings smaller than this value will yield no significant improvement in deLccLor response Lime.3.It is possible to calculate froin the results of a standard test the response time of thermally actuated fire detectors under known con-ditions of ceBing height, detector spacing, and fire intensity (total heat release rate).4.These conclusions are subject.to the following restrictions:

~Detectors are ceiling-mounted..

~CeBings are smooth (vertical length of obstructions loss than I per-cent of ceBing height)and horizontal.

~Minimum wall to wall distance is 2 to 4 ceiling heights.~Pire intensity does not double in less than one minute.~Drafts induced by room ventilation and stable temperature strati-fication due to a sun-baked roof are not present, This restriction is ap-proximately satisfied whenever the fire intensity is sufficiently large, although the conclusions are otherv6e app)icable for fire intensities from several hundred to several million Btu min.'owever,.

ventilation drafts and stable stratification could prevent the plume induced by a low intensity fire from reachirig the coiling whenever gas velocity and tempera-ture over the fire (see Equations 4 and 2, with T measured at floor-level) are not much greater than draft velocity and roof-level room tempera-ture, respectively.

~195~~~Fire Detectors q~Heat transfer rate to detectors (Btu min')r Radial distance from fire axis to detector (ft)S Detector spacing (ft)T~Gss temperature

(')Ts Fixed temperature rating (')t Response time of detector V Gas velocity (ft sec')Y Vertical distance from ceBing to sensing element of detector (ft)SUB SCRIPI8~Maximum value at any one radial position Standard test condition Fire plume ,~Ambient condition REFERENCES 1 Alpert, R.L,"Pire Induced Turbulent Ceiling-Jet," FMRC Technical Report 19722-2," I nctcry Mutual Research Caqmralion (1971).~Morton, R.B., Tayler, G.1., and'I'urner, J.S., Prccctdings of the Royal 8ocicty, Series A, No.2S6 (1956), pp.1-2S.>Alpert, R.L,"The Ceiiingdet Induced by Latgekcals Fires," RMRC Tcchnical Report 19722-4," under preparation for 1972 Winter Annual Meeting of the American Society of Mechanical Engineers.

r Rohsenow, W.M.and Chol H., Heat, Mass, and Momentum Transfer, Prentice-Hail, Englewood Cliffs, N.J.(1931), pp.148>200, 413.AcirNowrstnasnnrrs:

The author Is indebted to Dr.J.de Ris and Dr.Raymond Frlcdinen for their encouragetnent during the course of this work.Many of the eit-pchnentel results reported herein were obtained by P.B.Kiley, whoso effcrta are deeply apprechted.

o tc le CO cn m cn CO o cn o NOMEN CLATURE II Ceiling height above burning fuel (ft)h Heat transfer coefficient (Btu ft-'in'F')Q Heat release rate (intensity) of fire (Btu min')QtSmallest detectable heat release rate (Btu min')o o cn 41 0' Methods to Calculate the Response 1%me of Heat and Smoke Detectors Installed Below Large Unobstructed Ceilings DAVID D.EVANS aiid DAVID W.STROUP hfational Bureau of Standards Recently developed methods to calculate the time required for ceil-ing mounted heat and smoke delectors Lo respond lu growing fires are reviewed.A cuinpuler proy am thai, calculates aulivuliun lliaes fur buth fixed temperature and rate of rise heat deluulors in response l,o fires that increase in heat release rate proportionally with the square of Lime from ignition is given.This program produces nearly equivalent results Lo the tables published in Appendix C, Guide for Automatic Fire Detector Spacing (NFPA 72E, 1984).A separate method and corresponding program are provided to calculate response Lime for fires having arbitrary heat release rata histories.

This method is based on quasi.steady ceiling layer gas flow assump.Lions.Assuming a constant proportionality between smoke and heat released from burning materials, a method is described to calculate smoke detector response thne, modeling the smoke detector as a low temperature heat detector in either of the two response time models.INTRODUCTION TUDIES OF THE RESPONSE of heat detectors to fire driven flows under unconfined ceilings have been conducted since tho early de 1970s."" Results of these largely experimental studies have been us d to eveiop correlations of data that are useful under a broad range of fire con-e ditions and building geometries.

These correlations have been used to con-flefcreneo:

David D.Evans and David W.SLroup,"Methods Lo Calculate Lho lies unsu Tlmo ol lleaL and Smoke Deleclors Inslaflcd Below f arge Uiiobslruclcd Ceilings,-

l'iechnul.

agy, Vot 22, No.1, Februory l985, p.54.Key Words: lfeat delcclors, smoke deleclors, response time, L'fires.gss flow compul iouLlncs.Hirre: This paper is a contribullon of the Nallonal Bureau of Standards and is noL sub)eel Lo copyright.

ponse Time slruct engineering niethods to determine heal, detector spacing, sprinkler response Limy, and smoke detector alarm tiines for industrial buildings where large undivided ceilings over storage and manufacturing facilities are common.The method for calculation of heat detector spacing has been adopted by the National Fire Protection Association (NFPA)as an alter.nate design m'ethod published in the standard NFPA 72E, 19'.'lthough the NFPA heat detector spacing calculation is a well documented method, it, is not in a convenient form for use by the Nuclear Regulatory Commission (NRC)in evaluating the response characteristics of existing systems for two reasons: (1)Currently, the only available form of the information is the tabular form published in the NFPA 72E standard.An analytic form or computer subroutine that produced equivalent, answers would be more flexible and of greater use to NRC, and (2)the published Lables are organized to look up spacing requirements for a given response time.In the evaluation of existing systems, the opposite problem is of in-terest-for a given spacing and detector, determine the response time.-As part of this study, the basis for the calculation niethod published in Appendix C of NFPA 72E was deterinined.

Alternative correlations of l.he seine experimental data that.are the basis for lhe tables in Appendix C of NFPA 72E were used to construct a FORTRAN program (DETACT-T2 Code)to evaluate the response time of existing heat, detector systems.Using the program, calculated values for response time agree to within 5 percent of those published in the tables contained in Appendix C of NFPA 72E.Although this calculation method is the inost firmly based of those to be discussed in this report, it is restricted to applications in which the fire to be detected increases in energy release rate proportionally with the square of time from the ignition.A separate program (DETACT-QS Code), written in PC BASIC, is capable of evaluating detector response for a fire with an arbitrary energy release rate history.The only restriction is that the energy release rate must be represented as a series of connected straight lines, the end points of which are entered as user input data.Inaccuracies may be introduced in the analysis of rapidly varying fires because this code uses a quasi.steady ap-proximation for the fire driven gas flow.This means that, changes at the fire source immediately affect the gas flows at all distances from the fire.In reality, time is required for the gases to travel from the fire to remote loca-tions.Generally, fire driven flows have a velocity the order of one meter per second.Thus a quasi.steady analysis for locations close to the fire will only be in error by a few seconds, while remote locations can be delayed by Lens of seconds.Keeping this approximation in mind, Lhis program represents the most flexible of available methods but has not been tested against ex-perimental data.Both of the codes discussed above analyze detector response at installa-tion sites under large unconfined ceilings.For smaller compartments, in which confining walls will cause a layer of fire products to accumulate under Lhe ceiling, hence submerging the ceiling jet flow before the heat detector 0 l 58 Fire Technology can respond, different calculations are necessary.

The problem of analyzing the response of heat detectors or sprinklers in a two layer environment (warm fire products over cool air)has been studied,'ut no single code has been produced to facilitate analysis.This class of problem will not be dis.cussed in this repo;t, Analysis of smoke detector response is currently performed by approx.iinating the smoke detector as a low temperature zero lag time heat detec.tor.Selection of the response temperature corresponding to a given detector sensitivity also depends on the relative proportion of"smoke" and energy release'd by the burning fuel.Test data of gas temperature rise at the time of smoke detector alarm is presented in this report.An alternative approx-imate method is given to determine this same temperature rise by using fuel smoke and energy release rate measureinents obtained in a laboratory scale apparatus developed by Tewarson.'ETECTOR RESPONSE TO t'-FIRES Appendix C of NFPA 72E" contains methods to determine the required heat detector spacing that will provide alarms to growing fires before the fire has grown to a user specified energy release rate.Tables provide infor-mation to evaluate different fire growth rates, ceiling heights, ambient tem-peratures, detector alarm conditions (fixed temperature or rate of rise), and detector thermal time constant.The tables reflect the extensive experimen-tal studies and mathematical fire modeling performed by Heskestad and Delichatsios at Factory Mutual Research Corporation." Beyler'ses a different correlation of Heskestad and Delichatsios'ata than was used to produce the tables in NFPA 72E Appendix C, to obtain an analytical expression for the gas flow temperature and velocity produced under ceilings that can be used to evaluate heat detector response.Beyler's solutions are limited to evaluation of fires that increase in energy release rate proportionally with the square of time from ignition.This class of fire is commonly referred to as a"t-squared-fire." Briefly, the problem of the heat detector response is solved using analytic solutions for the time dependent temperature of the detector sensing element up to the point when it is heated to the specific alarm conditions.

The model for the detector sensing element temperature is based on a convective heat transfer process.Characterization of the thermal response of heat detector and sprinkler thermal sensing elements is discussed by Heskestad and Smith," and Evans." The first order differential equation that describes the rate of tern.perature increase of the sensing element is dT Ulled~=-(T-T,)t RTl The notation for all equations is given in the nomenclature section.The value of RTi (Response Time index), a measure of the thermal time con-3T f=0 for tf'(t]'), 3'I[tg-0.954(1+r/H)]/[0.188

+0.313 rIH]l"'or t/>(tl'), (2)(tf),=0.954[1+r/H]Ut'0.59[r/H]""[ATf]"'here Uf'VI[A a H]"" 3T)'-3TI[Ain(T/g)ave H-as]Qt t/[A II&II%+abls]A=g/(cT q)AT=T-Ta=t'IQ The solutions to Equation 1 for detector sensing element, temperature, T., and rate of temperature rise, dT./dt, in response to the t'-iire with growth rate specified by the value of a are from Beyler's follows: DT,=(hT/hTi')hT]'1-(1-e-')/Y](3)dt (t/t]')(0,188

+0.313 r/H)(4)where Y~3 U"'U"'ET t (0]88+0.31gr/H) 4 Uf aTj RTr assuming that hT,=0 initially.

T and U in Equation 1 are obtained from the correlations in Equation set 2 for hTf and Uf respectively.

Equations 3 and 4 were programmed into a user interactive FORTRAN code called the DETACT-T2 Code.This code solves for the time required to reach a spec(fied positive value of AT, or dT./dt representing detector alarm, (Det'ails ponse Time stant of the detector, is determined by testing.'alues of the tirne-dependent gas temperature and velocity are obtained from the following correlations.'

il J Ambient air temperature Detector response temperature Detector RTI Fuel to ceiling distance Radial distance of detector from axis of fire 21.1'C (ZO').54.44'C (130'F).370.34 m"'"'6'/0.8 ft"'"').3.66 m (12 ft).2.16 m (7.07 ft).Fire growth rate constant 11.71 3ts'0.0111 Btu/s').The calculated response time using the DETACT-T2 Code is 298 sec and corresponding fire energy release rate is 1.04 MW (986 Btu/s}.This same fire and detector combination can be seen in the Table C.3-2.1.1(e) in Appen-dix C of NFPA 72E,'in the table notation.threshold Gre size 1000 Btu/s, fire growth rate, medium;DETTC=300 6 s, hT=60'F, ceiling height=12 Aft, installed spacing in the body of the tablo 10 ft).All values in the table're for detector response times of 300 sec.This is In agreement with the 298 sec calculated with the DETACT-T2 Code in Appendix A.I Eleven other randomly selected combinations of fires and detectors we e ca culated using the DETACT-T2 Code and results compared to table 0 8 were values in Appendix C of NFPA 72E.Of these cases the greatest deviation was 7.6 percent and least was 0.17 percent.Use of the DETACT-T2 Code has two main advantages over the tables in Appendix C of NFPA 72E.One is that the code is specifically designed to evaluate existing facilities.

The other is that any t'-fire growth rate can be analyzed.Tho tables in Appendix C of NFPA 72E contain only three dif-ferent fires.At present, an NBS special publication is being prepared con.taining tabular results with the same information as those in the NFPA 72E, Appendix C, but recast into a form useful for evaluation of existing~58 Fire Technology of DETACT-Code use, and worked example are shown in Appendix A.)Briefly for a fixed temperature detector, the user enters values for: Ambient air temperature.

Detector response teinperature or rate of temperature rise.Detector RTI.Fuel to ceiling distance.Radial distance of detector from the fire plume axis.Fire growth rate constant a (for t'-fires).

Outputs of the code are the time to detector response and fire energy release rate at that tiine.In Appendix A use of the DETACT-T2 Code to calculato the response time of a fixed temperature detector is demonstrated in an example using the following program inputs: DETECTOR RESPONSE TO ARBITRARY FIRES The DETACT-T2 Code is useful for evaluating the response of specified detectors to t'-fire growth rates.In some cases a fire of interest does not follow an energy release rate that is proportional to the square'.of time from ignition.For these cases use of the DETACT-T2 Code to evaluate the responses of detector systems is inappropriate.

To evaluate detector response to an arbitrary energy release rate.history, an assumption of quasi.steady gas flow temperatures and velocities is inade, With this assumption, correlation for ceiling jet temperatures and velocities obtained from experiments using steady fire energy release rsto sources can be used to evaluate growing Gree.The growing fire is represented in the calculation as a series of steady fires with energy release rates changing in time to correspond to the fire of interest.Correlations of ceiling jet temperatures and velocities.

from experiments using steady fire sources have been published by Alpert.'ecast into metric forin they are: hT=16.9 Q"'IH"'or r/H (0.18 U=0,96 (QIH}"'or r/H (0.16 AT=5.38(Q/r)"'IH for r/H)0.18 U=0.2 Q'" H"'/r"'or r/H)0,15 (6)wliere the metric units are Tf'C], U(m/s], Q(kW)r(mL H(ml.A computer code to perform the integration of Equation 1, tho differen-tial equation for detector sensor temperature, using the quasi.steady fire driven flow approximation and Alpert's correlations.

From equations in 6, called the DETACT-QS Code, is written in PC BASIC, The code requires user input similar to the DETACT-T2 Code with the one exception that the fire energy release rate is specified as a series of tiine, energy release rate data pairs.The same fire and detector case used as an example of execution for the DETACT-T2 Code was evaluated usIng the DETACT QS Code.The fire was input as time, energy release rate pairs at intervals of 6 sec to match the t'-fire with a=11.7105%/s'.Other parameters were maintained the same.The resulting predicted detection time using the DETACT-QS Code was 313 sec with the corresponding fire energy release rate at detection of 1147 kW.Remember that with the DETACT-T2 Code the calculated tiine of detection was 298 sec with fire energy release rate at detection of 1040 hW.This exemple was chosen to demonstrate specifically that there will be dif-esponse Time facilities.

This publication"Evaluating Thermal Fire Detection Systems," by Stroup, Evans, and Martin should become available in 1986.

0 0 60 Fire Technology ferences bet een the two methods even in the evaluation of the same fire.The quasi-steady fire analysis on which the DETACT-QS Code is based has the advantage that arbitrary fire energy release rates can be input as a data set.SMOKE DETECTOR RESPONSE Both of the hea t detector response models discussed are based on predic.tions of the temperature and velocity of the fire driven gas flow under the ceiling and models of the heat, detector response.The same calculations could bo used to predict smoke detector response given a relationship be-tween smoke concentration and temperature rise in the fire driven gas flow and the response characteristics of the smoke detector.The response characteristics of smoke detectors are not as well understood as thermal detectors.

Smoke detector alarm conditions depend on more than smoke concentration.

Smoke particle sizes and optical or par-ticle scattering properties can affect the value of smoke concentration nec-essary to reach alarm conditions.

For thermal detectors, measured values of R'I'I characterize the lag time between gas temperature and sensing element toinperature.

For snioke detectors thero is no analogous method to characterize the lag time between gas flow smoke concentration and the sinoke concentration within the sensing chamber.In the absence of under-standing of the many processes affocting smoke detector response, a smoke detector will be considered to be a low temperature heat detector with no thermal leg, i.e.RTI=0.The analogy between smoke obscuration in the gas flow and teinperature riso will be developed in order to determine the corresponding temperature rise to use as a model for a smoke detector known to alarm at a given smoke obscuration.

Similarity between temperature rise and smoke concentration will be maintained everywhere within a fire driven flow if the energy and smoke continuity equations are similar.For the case of constant ck, and D these equations are: qc, k Qs ss T Qssl dhT dt e d'--qDV'Y,=m"'Y, ('/)If the Lewis number k/gcD=1, then the ratio of temperature rise to smoke concentration can reinain constant throughout tho fire driven flow, if the ratfo Q"'/(cm."')

is maintained constant in all regions where energy is exchanged with tho flow.Reactions in the flame over the burning fuel will determine the ratio of temperature rise to smoke concentration throughout the flow.Other onergy exchanges in normal fire fiows, convection to cool room boundaries, and radiation from smoky gases decrease the ratio of tem-perature rise to smoko concentration because energy is extracted from the esponse Timeflow without a proportional decrease in smoke concentration.

Mixing of hot combustion products with cool smoky gases that may accumulate in an enclosure also decreases the ratio of temperature rise to smoke concentra.

tion because smoke mass is added to the flow without a proportional in.crease in energy, For fire driven flows in which the effects that alter the ratio of temperature rise to smoke concentration are not significant, the response of a smoke detector may be calculated as if it were a fixed tempera-ture heat detector.The temperature rise necessary for alarm of this substitute heat detector is calculated from the product of smoke concentra-tion needed to alarm the smoke detector and the ratio of temperature rise to smoke concentration produced by the burning mateiial.Generally the sensitivity of smoke alarms is given in terms of the amount of obscuration by the smoky flow that is necessary to pro(luce an alarm and not directly in smoke concentiation.

The more sensitive the smoke detector the smaller the amount of obscuration needed to alarm.The obscuring ability of a smoke laden gas flow is measured by the at-tenuation of a light, beam, The measure of the attenuation is the optical den.sity per unit beam length, OD,'D=(log-')/I I.I (8)OD=3330C, (9)where OD ls optical density per meter and C, is smoke mass concentration in kilograms per cubic meter.The ratio of temperature rise in a fire driven flow to smoke concentration may be recast in terms of optical density using Equation 9 as: QT gAT 3330 kT-Y.C, OD (10)Under the assumption discussed at the beginning of this section, this ratio will be equal to the ratio Q"'/(cm.'").

The last ratio may be approx-imated by a volume average over the combustion region so that~SSSO ST OD cm.By testing, Seader and Einhorn" found that the attenuating abilities of.smokes produced from many different materials undergoing flaming coin.bustion were similar.For flaming combustion they found that the optical density per unit length was proportional to the mass concentration of"smoke" in a gas flow as:

0 0 orFire Technology (ll)ponse Time REFERENCES OD~3330 c m, AT Q As an example, literature values for oak wood may be used to obtain a representative value.For oaki Q=7600 k J/kg fuel consumed per unit time" m.=0.017 kgsmoke/kg fuel consumed per unit time" air c=1 kJ/kg'C air q=1.165 kg/m'at 30'C Prom Equation ll--=8.68 X 10" (m'C)'.AT Heskestad and Delichatsios'ave roported representative optical den-sity per meter for smoke detector alarm and corresponding temperature rise in the gas flow.For wood crib (unknown type)fires, the ratio of these values was OD/AT=1.2 X 10'm'C)'.This is the same order of magnitude as tho number calculated in the analysis given above and may be representative of the expected accuracy given no knowledge of wood type.Heskestad and Delichatsios report that an ionization detector will alarm in response to a wood fire at OD=0.016 1/m.Using tho OD/AT value for wood of 1.2 X 10'(m'C)'he corresponding change in gas temperature would be 13'C (0.016/1.2 X 10').For the pur-pose of response time calculation using the heat detector models, this ionization smoke detector would be represented as a low temperature heat detector alarming at 13'C above ambient for a wood fire.Other measurements of tho ratio OD/ICT are obtained for burning materials in a laboratory scale apparatus developed by Tewarson,'alues for a large number of plastics and wood under many environmental condi-tions are given by Tewarson and Pion."

SUMMARY

Two methods have been presented to calculate the response of heat de-tectors installed under large unobstructed ceilings in response to growing fires.Smoke detector response is calculated using the same thermal calcula-tions by approximating the smoke detector as a low temperature, zero lag time thermal detector.Nore: NBSIR86-3167 Methods to Calculate the Response 77me of Haut a<<d Smoke Detec lors Installed Scion>Large Unobslructed C>dli<<gs, contains the complete DETACT-T2 Coda and DETACT-QS Code ln Appendix A and Appendix B.'lnerl R.I."Calculation of Response Time of Ceiling hlounted Fire Detectors,'"3>e Tcchnofogy, 8.1972, n.18l.'lpert, R.I.,'Turbulent Ceiling Jet Induced by LargeScale Fires," Comb<<etio<<

Science and Technology, 11.1976, p.197.'eskestad, G., and Delichatsios, M.A., Environments o/Fire Detectors Phase I;8/(ecto of Fire Siss, Ceili<<g Height ond Itfats>io4 Vofums II-Analysis.Technical Rcport Seria3 No.22427, RC 77-T.I I.Factors Mutual Research Corporation, Norw>x<<4 MA, 1977.'eskestad, G., and Odichatslos, M.A.,"The lniLiol Convective Flow ln Fire," Scur<<.trenth Svmposium If<<is>notional/

on Comb>>stfo<<, The Combustion institute, Pittsburgh, PA, 197lf, up.1113-1123.

'Standnnt on Automatic Fire Dstec(vrs, NFPA'72E-!984, Appendix C, National piro Protection Association.

Qulncy.MA.Evans D.D.,"Calculat>ng Sprinkler Actuation Time in Compartment," Fire Safety'o'<<mal, VOL 9, No.2, July 1986, pp.147-156.'ewan>on, A.~and P>on, R.."A I aboratorykcale Test Method fnc the Measureme<<L of.Flammability Parameters," FM llC serial No.22524.Factory MuLual Research Corporation, Norwood, MA.Oct.1977.'eyler, C, I,"A Design Method for Flaming Flic Detection," Fire Tech<<alogy, 2Q, 4, 1984.n.6.'eskestad, G., ond Smith H,.I<<orstigolio<<of a Nrrr Spri<<kler Scnsiiiuliy App>ouai 7'est: The Plu<<<<e Test, FMRC Technical Repott 22486, FacLory hlutual Research corpora-'ion, Norwood, MA, 1976."Evans.D.D., ond Madrsvkowskl, D..Churac(ari3ing the Theme!Resp<<<<so of Fusibls-I i<<k Spri<<kfers, NBSIR 81 2329, Nalional Bureau ol Standards.

Washington, DC.1981." Seeder, J., and Einhorn, I.,"Some Physical, Chemical, Toxicological, and Physiological Aspects of Fire Smokes," Sixlee<<rh Symposiur<<

il<<temaliunail o<<Cumbnsdo<<, The Comuus.tion Institute, Pittsburgh, PA, 19'16, pp.1423-1446."Tewarson~A., PhvsicoChemfcal m>d Combustion/Pymlysis Properties of Pofyl<<eric Motcrfnfs.

FMRC J.l.OEONG.RC, Factory Mutual Research CorporaCion, Norwooa, MA, Nov.1980, p.2'l.Ar<<3<<>ween<<earn>rr:

The authors uro grateful Lu Mr.Doug Walton for roding DETACT.QS version l.l for execution in PC BASIC.NOMENCLATURE A gifccT e)c specific heat capacity of ambient air smoke mass concentration D effective binary diffusion coefllcienC tr aoceleratfou of gravity vertical distance from fuel to ceiling I Uxht lntonsily I~Iriltlsl light Intensity I Ught beam length ml>'moke gas mass production rate per unit volume OD optical density per unit length lace Equation 8)Q fire enorgy release rate ensrev release rate por unit vohime r radfsTdistanca from lire axis to the detector RTI resnonse time index, the nroduct of the detector ther3nal Lime constant and the square rooX of Che gas speed used In the Cast, Co measure the Lies constant.'

time ty dimensioniess Lime Cl(A u'"'"'I llf)>dimensionloss Lime for time doh>y for gas front lravcl T ambient tempera Lure T gas temuerafure at detector location T, temperature of detector sensing elements hT T-T ATf dimons3onloss temperature differences hT/(A"g,lgl a""'i U xas speed at the detector location Ut 83limensionloss gas spoed U/(A a Hl"', local ratio of smoke mass to total mass ln flow a proportionality constanL for V lire growth~Qlt>sambient air density

64 Fire Technology APPENDIX A.DETACT-T2 CODE A FORTRAN Program to Calculate Detector Response to t'-Fires This appendix describes the theory and use of a computer pr'ogram which determines the response of fixed temperature and rate of rise heat de-tectors to fires with energy release rates described by the expression Q=at'.The program is designed for use in evaluating detectors installed at known spacings.The activation time of a given detector is a function of fire growth rate, coiling height, detector spacing, detector activation temperature, ambient temperature, and detector response time index (RTI).The program prompts the user to provide this information.

These input data are converted to a dimensionless form for use in the calculations.

Equations for the activation timo o a fixed temperature detector and a rate of rise detector are set up.The two equations are then solved using a Newton.Raphson technique.

Once the activation times are known, the fire enorgy release rates at those times are calculated.

Finally, the results for each detector type are printed as well as some appropriate input data.rinted in ll In the following example, input prompts from the computer pro r program are pr n m a capital letters while user responses are printed in lower case (where possible)and preceded by the character">".EXAMPLE Calculate the activation times for fixed temperature and rate of rise heat de-ctors installed, using a 3.05 meter spacing, in an area with a ceiling height of 3.66 meters.The detectors have an RTI of 370.3{m.sec)"'.

The detector ac ivation temperature is 64.4'C, and the activation rate of rise is 8.33'C/min, Ambient temperature is 21'C.ENTER 1 FOR ENGLISH UNIT INPUT 2 FOR METRIC UNIT INPUT>2 ENTER THE AMBIENT TEMPERATURE IN DEGREES C.>21 ENTER THE DETECTOR RESPONSE TIME INDEX (RTI)IN (M-SEC)<<iA.

>370.8 ENTER THE DETECTOR ACTIVATION TEMPERATURE IN DEGREES C,>54.4 ENTER A DETECTOR RATE OF RISE IN DEGREES C/MIN.>&.33 ponse Time ENTER THE CEILING HEIGHT IN METERS.>J.66 ENTER THE DETECTOR SPACING IN METERS.>3.05 ENTER: S FOR SLOW FIRE GROWTH RATE M FOR MEDIUM FIRE GROWTH RATE F FOR FAST FIRE GROWTH RATE OR 0 FOR OTHER>m RESULTS: CEILING HEIGHT=3.66 METERS{12.0 FEET).DETECTOR SPACING=3.05 METERS (10.0 FEET).DETECTOR RTI=370.3 (M.SEC)~*'/z (670.8{FT-SEC)~~'li).

FIRE GROWTH CONSTANT=(.1171+002 WATTS/SEC*~2).

{.>>11-001 B'rU/SEC"3).

FOR TEMPERATURE ACTUATED DETECTOR: ACTIVATION TEMPERATURE

=64.4 DEGREES C{129.9 DEGREES F).TIME OF ACTIVATION

=297.88 SECS.HEAT RELEASE RATE=.1038+007 WATTS (.9840+003 BTU/SEC).FOR RATE OF RISE ACTUATED DETECTOR: ACTIVATION RATE OF RISE=8.33 DEGREES C/MIN (14.99 DEGREES F/MIN).TIME OF ACTIVATION

=182,75 SECS.HEAT RELEASE RATE=.3908+006 WATTS (.3704+003 BTU/SEC).The results show that the heat detector would activate approximately 298 seconds after the fire reaches a flaming state.The heat release rate at this time would be 1038 kilowatts.

A rate of rise detector would activate at about 183 seconds with a corresponding heat release rate of 391 kilowatts.

If English units had been selected, the Input requests would have called for data in English units instead of metric units.Ths program is written in ANSI 77 FORTRAN.A PC BASIC version has been coded, Each is in a form which makes it, easy to incorporate it into existing computer firo models as a subroutine.

0 0 Cl<<F SVPPREBSIOH LAG TIMSS I.ag 17mes Associated With Fire Detection and Suppression Frederick W Mowrer*Abstract Tho eAectiveness of fire detection systems and fire niitigation stratogies can bere)stod to three distinct time)age associated with building fires: a transport time lag, a detection time)ag, and a sup-pression time)ag.The impactsof these)agporiods onfire detection and suppression are devo)oped.%

anspor t)ag periods are considered in terms of available correlations of fira plume and ceiling jet date, detection leg periods in terms of avai)able heat de'tactor response models thatuse these data correlations.

Suppression legs are dove)-oped in terms of expected response times for automatic and manual suppression.

Example calculations are prosented.

Rtmduction Calculation of the response of fire detectors, sprink)ers, and other heat-sensitive objects located atceilinglevel requires a know)edge of the fire environment to which these elements are exposed.Currently, such information is available for large spaces with flat, unobstructed ceilings in terms of temperature and velocity correlations for fire plumes and ceiling jets.Correlations currently utilized to describe the fire environ-ment at detectors are reviewed, and the re)ationship between the available t squared and quasi-steady corre)ations is developed.

The response of fire detection devices and fire suppression systems can be evaluated in terina of three distinct lag periods: a transport time lag, a detection time lag, and a suppression time lag.%ansport)ags are considered here within tho context of the available data correlations, while detection lags are developed in terms of'avai)ab)e detector re-sponse models that use these data correlations.

Suppression lags are Key Nrorde: Fire plumes;ccBing jete;detection; euppreesha; respoaea time,"Dapartrmnt of'ru Frotectfon Eriglrieering, Ualvcraity of Maryland, Ca)iege Far)r, Maryland20742.

Flgg rSCHNOLOGr hVGUST l990 considered in terms of expected response times for automatic and manua)suppression systems.The overa))impact of these lag periods on the response of fire detectors and on the formu)ation oi'fire mitigation strategies is developed.

Example calculations are presented to illustrate these influences.

I Review of Fire Plume/Ceiling Jet Data Correlations Availab)e fire plume and ceiling jet data correlations are of two types: quasi-steady and power law.Quasi.-steady correlations are based on fire experiments with heat release rates that do not vary appreciably with time;power)aw correlations are based on fires characterized with heat release rates that growas a power of the time from ignition.The primary focushere is on the relationship between these two types of correlations and on the use of these correlations for fire detection analysis.Data correlations of A)pert,'eskestad and Delichatsios (Ik&D)z and A)pert and%ard (A&W)'re used for this discussion.

Bey)er'as compiled a comprehensive review of available fire plume and ceiling jet data correlations.

A)pert developed the original of these correlations based on large.scale quasi-steady fire experiments, while Heskestad and Delichatsios have developed correlations forboth quasi-steady fires as well as power law fires.More recently, A)pert and Nard have suggested new coeAi-cients for the original A)pert correlation.

These new coeHicients produce results closer to the quasi-steady correlation ofHeskestad and Delichat-sios.aquas)-steady Fires P)ume theory suggests that the maximum temperature rise above ambient of a plume ofhot gases rising from a point source ofhea tean be expressed with an equation of the form: dT=kQ'I I EPI where: dT=Temperature rise above ambient (K)k~=Temperature coeAicient Q=Heat release rate of fire{kE'/)H=Height above plume source (m).Available correlations of fire plume data have been developed in this form..The theory of ceiling jet flows is more complicated, as evidenced by

246 ptRE rscHNotaor

~uousT tsso U=k(Q/H)'~s Alpert'st detailed analysis of this region.It involves consideration of the rate of entrainment into the ceiling jet as well as the viscous effects and heat transfer associated with the flow ofbuoyant gases beneath and in contact with the ceiling.The maximum temperature rise occurs within the area where the fire plume impinges the ceiling and falls off as a function of the radius beyond this zone.The ceiling jet data correlations of Alpert, Heskestad and Delichatsios, and Alpert and Ward can all be expressed in the form of Equation 1, but in the ceiling jet region, the coefficient kr is also a function of the nondimensional radial distance from the plume centerline, r/H, to account for the temperature decay that occurs with increasing distance from the plume impingement region.Similarly, plume theory suggests that gas velocity in the plume region has the form: SUPPRESSION LAG TlÃES 1b hie 1: Quasi-steady correlations.

Alpert Hcskestad and Delichatsios Al port and VFard Beyler recommendation Plume 16.9 2.75/D~22.0 22.0 Ceiling jet 5 4/(r/H)~2.75/D'o 6.8/(r/H)~H&D correlation b.Velocity correlations'.

U~k, (Q/H)u~a.'Ibmperature correlations:

d T~kQ'/'/EP" Values for kr 247 Q,~x,(l-xPQ (3)where: U=Fire gas velocity (m/s)k=Velocity correlation coefficient.

As with the temperature data, the velocity correlation coeHicient, k, is expected to fall oKas a function of the radial distance from the plume, Available velocity correlations have this characteristic form.The coefficients, AT and k, for the quasi-steady temperature and velocity data correlations of Alpert, Heskestad and Delichatsios, and Alpert and Ward are tabulated in Table 1.Where available, recommen-dations of Beyler, based on his review, also are tabulated.

Normalized curves are illustrated in Figures la and 1b, which show the nondirnen-sional temperature rise, dT, and velocity, U~, respectively, as functions of the nondimensional radial distance, r/H, from the plume centerline.

Two regions are used to correlate the data: a plume impingement region and a ceiling jet region.The plume impingement region occurs within a radius of approximately 0.2 H (r/H<0.2).The correlation coefficients provided in Table 1 are based on theoreti-cal total heat release rates, which are determined as the product of the fuel mass loss rate and the theoretical heat of combustion.

The heat release rate actually contributing to the velocities and temperatures in the plume and in the ceilingj et is the convective heat release rate.The convective heat release rate differs from the total theoretical heat release rate because of combustion inefficiency an radiative losses from the fire source.This can be expressed as: Values for kPlume Ceiling jet Alpert Heskestsd and Delichetsios Beyler recommendation D~0.25 D~0.188+0,31S r/H 0.95 None 1.04 r/H<0.2 r/H>0.2 0.2/(r/H)+~0.21/f(r/H)

~~D+']=Convective heat release rate (kW)=Combustion efficiency factor (Q/Q)=Radiative fraction of actual heat release rate (Q,/Q,)=Total theoretical heat release rate (kW)=Total actual heat release rate (k%).The ratio of the convectivo to theoretical heat release rate, Q,/Qis expected to remain fairly constant for a given material, but can vary considerably among difTerent materials'or wood, which serves as the primary basis for the available correlations, Heskestad and Delichat-sioss suggest this ratio has a value of about 0.45.Adjustments should be made for application of the correlations to materials with convective ratios considerably different from this value.'Ibwarson'provides convec-tive ratio data, measured in small-scale tests, for a range of materials.

According to Alpert and Ward, these correlations provide reasonable accuracy for predicted temperatures between approximately 70'C and 860'C (160-1500'F).

Predicted temperatures above 860oC indicate the likelihood of flame at the location beingevalusted.

The low temperature 4l 248 FlRR TBCHNOLOGY AUGUST 1990 SUPPRESSION LAO TINES 10 PLUME/CEILING JET CORRELATIONS IA)TEMPERATURE-e)-H&D-)e-A&W~ALPERT extreme is not representative of a threat to the building structure, so bettIir accuracy is not normally warranted unless nonthernial damage is ofinterest.

Power Law Fires Heskestad and Delichatsios also have correlated temperature and velocity relationships for idealized, yet realistic, classes of fires referred to as"power-law" firesbecausetheheatrelease rateis considered togrow as some power of time: 0 0 10 Q=a(t-t.)p where: a=Power law fire growth coeKcient (kW/sp)t=Time from ignition (s)t,=Incubation time offset (s)p=Fire growth exponent.(4)IB)VELOCITY~H&D-1'H&D-QS~ALPERT This equation can be applied to either theoretical or convective heat release rates, provided appropriate values of a are used in conjunction with either the theoretical or convective heat release rate.The relation.ship between convective and total theoretical growth coe6icients is the same as that between convective and theoretical heat release rates expressed in Equation 3: a,=x, (1-x,)a, (5)For this class of fire characterizations, Heskestad and Delichatsios developed nondimensional correlations of the form: dT~=(gHG-p)I"'p)/(AaH J'Ile')(dT/T,)P Ue=((Ho-p)IIp'e'/(AOHP" p))U P t e-((AapJIIP ip)/Heile+

p))t (6)(8)10 Figure l.Illuetration of the plume/ceiling jet correlalione of Alpert (Alpert), Alpert and iVard(A&W), and Heekestad, and Delichateioe (H&D);(a)nondimen.eional temperature rice vereue nondimeneional radial dietance, r/H, from the plume centerline, and (b)nondimeneional velocity vereue radial dietance, where: dPp Ue P t p A T.=Nondimensional temperature rise above ambient=Nondimensional velocity=Nondimensional time=Gravitational constant (9.8 m/s')=g/(c p, T)~(0.028 m%g orm'/kWs)=Ambient temperature (298 Ig.

'0 0 0 250 0 FlRZ TECHNOLOGY

~tlOUSr 1990 SUPPRESSION 1AO CHES 251 dT",=(gHI(AaHJ'")(dTIT)(/(AaHJi sJ U (10)For the case of parabolic fire growth'(p=2), which has become widely used to represent a range of realistic fire growth rates, these relation-ships reduce to: where: D, t>>,~=0.813 (1+r/H)=Nondimensional distance parameter=0.17 forr/H<0.2

=0.126+0.210r/Hforr/H

>0.2=Nondimensional transport time lag parameter.

(17)dT"s=Ofort>>sdt>><,'nd dT'((t>>-t>><)/D j'l fort>>>t>>U>>s/4 dT's=0.59/(r/H)~~t>><=0.954(1+rIED (12)(13)(14)t>>s=((AaHJHrIHJ t The t-squared temperature and velocity correlations originally devel-oped by Heskestad and Delichatsios use the total theoretical heat release rate.These correlations, based on large-scale experiments with wood cribs, are.d T=0 for t<t'nd dT=(A"'/gD'l')T, Q.'>>IEP" for t>t, (18a)(18b)These correlations have the same form as the original ones, but the coeAicients are different t accountfor thedifferencebetweenconvectivo and total theoretical heat release rates.Appropriate values for a, must be substituted into Equations 9-11 to use the correlations in the forms of Equations 15-17.These nondimensional forms are useful for the correlation of data over a wide range of fire testconditions, but they are cumbersome for engineering calculations.

For engineering use and for comparison with thequasi-steady correlations, itis useful to rewrite the t-squared correlations of Hoskestad and Delichatsios in dimensional form as: where: D=Nondimensional distance parameter=0.25 for r/H<0.2;and=0.188+0.313 r/H;for r/H>0.2 t>><=Nondimensional transport time lag parameter.

For representative values of A, g, and T;, this evaluates to: dT=(2.75/D")Q,"~/H'ort

>t, U=(0.18/((r/H)

~D'>>J J(Q,/H)U (18c)(19)Appropriate values for a must be substituted into Equations 9-11 to use the correlations in this form.Recently, Heskestad and Delichatsios'have restructured their origi-nal correlations in terms of the convective heat release rate rather than the total theoretical heat release rate.These generalised correlations, which permit direct application to combustibles with convective frac-tions significantly different from wood, are expressed as: where: t,=Transport time lag (s)Q,=Sensed heat release rate (kVf).These dimensional forms apply to both the original and convective correlations of Heskestad and Delichatsios, provided appropriate values for D, Q,, and t, are used.dT's=0fort"r,5t

<,',and dT;=((t>>-t>>~)

I D,J'>>;for t>>>t>>, UI ddT i,=0.59 I (r/E6o~(15)(16)The Relationship Between Quasi-steady and t'orrelations The temperature correlation expressed by Equation 18cis identical to the quasi-steady correlation of Heskestad and Delichatsios once the instantaneous heat release rate, Q(t), at any timeis replaced by tho heat release rate sensed at the location of interest, Q,(t), at that time.The 0 0 252 0 IIRE TECIINOMOY AUGUST t990 SUPPRESSION LAO TlhfES 258 difference between these terms can be considered in terms of a simple translation along the time axis equal to the transport time lag.HRR CURVE WITHOUT SUPPRESSION Q,('t)=0 for t (t'nd Q,('t)=Q(t-t,)fort>tI (20)Equation 20 applies to either the original or convective correlations, dependingon which value ofQ is specified.

Vo use the original correlation, Q, is substituted for Q;to use tlie convective correlation, Q, is substituted for Q.The topic of transport time lags is developed in tho next section.The t-squared velocity correlation has the same functional form as the quasi-steady correlation, but has a magnitude approximately 15 percent less than the quasi-steady correlation.

These similarities are more than fortuitous; Heskestad and Delichatsios forinulated their t-squared cor-relation to asymptotically approach the quasi-steady limit.The difference between the instantaneous heat release rate and the heat release rate sensed at a location is a function of the distance from the fire source to the location and the transport speed of the fire gases, For the t-squared correlations, this transport speed is expressed in terms of the parabolic fire growth coefficient, tr.As developed in the next section, the differenco between the instantaneous and sensed heat release rates can be significant and, according to the t-squared correla-tion, this difFerence continues to grow as long as the fire continues to grow parabolically.

Lag Times Associated With Fires The potential for manual or automatic fire control based on the operation of fire detection and suppression systems relates directly to three distinct delay periods between fire initiation and the start of suppression.

These threo periods can be considered as 0)a transport time lag, t;, (2)a detection time lag, t;(3)a suppression time lag, t,.The transport time lag, trepresents the time between the actual generation of heat or another fire signature and the transport of that signature to the fire detection device.The detection time delay, t, represents the time period from the first transport of afire signature to a sprinkler or fire detector until the device actuates.The final lag period, tho suppression tiine lag,t,, represents the time from fire detection until the initiation of fire supprossant application.

These periods are similar to ones suggested by Johnsoni4 and by Newman." These three lag periods are illustrated schematically in Figure 2 for an idealized heat release history.The idealized fire history without suppression illustrates a period of accelerating fire growth, followed by HRR CURVE WITH SUPPRESSION c I~TOTAL TIME LAG PERIOD/TIME Figure 2, Schematic iliustration of the influence of transport, detection, and suppression lag periods in terms of a representative heat release rate curue.a period of steady heat release rate associated with full involvement of aburningobjector room.Thedecay period thatfollows this steadyperiod would be associated with fuel burnout in the absence of any fire suppression activity.The suppression curve in Figure 2 illustrates an example of satisfac-tory performance because the total lag period is less than the time to critical damage.Unsatisfactoiy performance would result for situations where the total lag period exceeds the time to critical damage.'lb use this concept of performance-based criteria, the time to critical damage must bo established by appropriate analyses of the expected rate of hazard development and the response of building systems, contents, and occu-pants to this development.

For this example, the critical time is repre-sented in terms of a critical heat release rate.Transport Time Lags Upon preliminary inspection of Figure 2, the transport lag does not appear to be important because it is represented at the start of a fire, before the heat release rate has grown to significant levels.But the influence of the transportlagpropagates through the fire growth period, As illustrated in Figure 3, the heatreleaserate being sensed at a detector can lag the actual heat release rate by a significant margin.This 0

254FIRE TECHNOLOOF AUOUSF 1990 SUPPRESSION Lho T/bfES 255'1)ansport Lags Associated UIith t Correlations The t-squared correlation of Heskestad and Delichatsios considers the transport lag explicitly.

The heat release rate sensed at a location in a fire plume or ceiling jet, Q,, legs the instantaneous heat release rate by a transportlagtime, tr This canbe expressed as: Q,=0 for t~tand Q,=a(t-t)sfor t>tI (21)This can be applied to either the original or the convective correlations through use of appropriate a and t, values.The relationship between the instantaneous and sensed heat, release rates for t-squared fire representations is illustrated in dimensionless terms in Figure 3, The curves differ only by a translation along the time axis equal to the transport time lag, Once this transport lag is consid-ered, there is no difference between the quasi-steady and t-squared difference continues to grow as long as the fire continues to grow.The longer the three lag periods are;the larger this margin will bo.The detector responds to the heat release rate sensed at tho detector, while it is the actual heat release rate of the fire that must be suppressed.

Qi/at,=(t/t)'fort

<t,;and Q,/at,'(2t/t,-1)for t>t, (22)~This relationship is illustrated in Figure 3, where Q, is the actual instantaneous host release rate at any time, Q, is the sensed heat release rate at any time, and Qi is the difference between Q.and Q,.The longer the transport lag, the larger the lag will be between the instantaneous heat release rate and the sensed heat release rate at any time.According to the Heskestad and Delichatsios correlations fort-squared fires, transport time legs can be calculated as: t,=(O.M4(H+r)J/(Aa, H)ne s=(0.813(H+

r)J/(Aa,gl" 9 (23a)(23b)temperature correlations of Heskestad and Delichatsios.

The difference between the instantaneous and sensed heat release rates continues to grow with time.The rate by which the sensed heat releaseratelagstheinstantaneousheatreleaseratecanbeexpressed for t-squared fires as: 2S 20 15~Q(a)~-a(s)0(e)-Q(s)The terra(H+r)is the characteristic distance traveled by fire gases from the fire source to the ceiling location of interest.The term (AaP)'I has units ofm/s and can be interpreted as a characteristic velocity of the fire gases.Newinann suggests an alternative expression, based on a data corre-lation and applicable to power law fires, for calculating transport time legs;~\8 P 10 t(=(1.4(r/H)+

0.2J (H'/(Aa, H)Jor t-squared fires (p=2), this expression evaluates as: (1.4 (r/H)+02J (H'/(Aai H)J'(1.4r+0.2H)/(Aai H)IIe (24)(25a)(25b)Fig'ure S.Illustration of thein fluence of the tronsport time log on the response of thermol detectors to t.squared/iree, Newman's correlation for the transport time lag in t-squared fires (Equation 25b)makes more physical sense than the transport lag correlation of Heskestad and Delichatsios because it recognizes the difference between the average transport velocities in tho plume and ceiling jet regions.Newman's correlation approximates this difference, 0

256 FIRS TSCilNOLOCY AUGUST 1990 SUPPRESsiON LAC TIRES 257 illustrated in Figure 1b, to be a velocity in the plume region that is seven timeshigher than in the ceilingjetregion.

While not exactbecause of the variable velocities in the ceiling jet region, this difference is consistent with the plume and ceiling jet velocities illustrated in Figure lb.S.ansport Lags Associated with Quasi-steady Correlations The quasi-steady temperature and velocity correlations do not con-sider transport legs explicitly.

EfFects of the actual heat release are considered to propagate instantly throughout the fire plume and ceiling jet.The transport time lag for quasi-steady fires can be estimated to permit evaluation of its importance for different scenarios.

The trans.port time lag can be calculated generally as: t,-d/f-where;d=Distance traveled by the fire gases (m)u=Average velocity of fire gases over distance'd (m/s).{26)Within the plume region, the distance traveled by fire gases, d, is simply the height H from the fire source to the location being considered, Average velocity in tho plume is calculated, using u(z)=1.0 (Q,/z)Us, as: l u>---J u (z)dz=-J 1.0[-)dz=1.5u (H)(27)HJ, Iz)The average velocity over the heightH is 1.5 times the local velocity at K Therefore, within the plume region, the transport time lag can be evaluated as: t>=H/(7.5 u(H)'/0 67Hns/Q U l (28a)(28b)The transport time lag within the ceiling jet region is the plume transport lag plus the transport lag within the ceiling jet.The distance traveled bygases in the ceilingjetis the radial distanceR from the plume centerline to the object under consideration.

Using Alpert's correlation for ceiling jet velocities, the average velocity of the jet is evaluated as: l u,)=-u(r)dr=-0.2-/H a dr=6u(R)ti<=R/(6u(R)j Rlll6/(7 2 Q USH!ls/(30a)(30b)The total time lag for the ceiling jet region then is evaluated as: t~=t~+ti(3l)For heat release rates that vary with time, this analysis of quasi-steady fires suggests that the transport time lag also will vary with time.For example, if a t-squared representation of the heat release rate (Q=at')is substituted f'r Q into Equations 28 and 30, this time dependence is illustrated.

Thus, due to differences in the forms of the quasi-steady and t-squared representations, they are not expected to yield identical results even if a transport time lag is added to the quasi-steady correla-tion.The Newman corrolation for transport time legs expressed by Equa-tion 24 can also be applied to the case of quasi-steady fires by setting p=0 and a=Q.For this case, Equation 24 evaluates as: t,=(1.4 (r/H)+0.2)SP"/(AQH)'" which can be separated into plume and ceiling jet regions: 0.2 H6'6/(AQH)"=0.66H'"/Qns tie=(7.4 r/H)Hly/(AQH)'4.61 r/(Q/H)us (32)(33a)(33b)(34a)(34b)Thus, Newman's expression for the plume region transport lag is virtuallyidentical to the one derivedhere andexpressedby Equation 28b if the theoretical heat release rate is used.Newman's expression for the ceiling jet transport lag differs in form from the one derived here;his expression demonstrates a first power dependenceofthe transport lagon radialdistance, while the one derived here demonstrates alniost a second power relationship.

This difference is most likely due to the difFerence in form between the Alpert and the Consequently, the transport time lag within the ceiling jet can be evaluated as:

0 0 25S FNE TECHNOLOGY AUGUST l990 Heskestad and Delichatsios velocity correlations in the ceilingjetregion (see Table 1).The form derived here is more consistent with the decaying nature of the velocity as a function of radial distance in the ceiling jet region.But over radial distances normally of interest, either form should suf6ce.Detection Time Lags The detection time lag depends on the fire environmenthistory at the detector and on the response characteristics of the device.For detection, a threshold magnitude of the fire signature being detected must be transported to the detector and maintained for a suAiciently long period to overcome inertial effects in the detector.Newman'z discusses the methods available to evaluate these parameters for a rango of detection devices.In this paper, models of heat detector response are used to illustrate the concept of detection time lags.The DETACT models"" of detector actuation developed by Evans and Stroup permit quantitative estimation of detection time legs for thermally actuated dovices.Those models use the Response Time Index (RTI)characterizations ofheat detector reaction developed by Heskes-tad and Smith.'he DETACT-QS model's uses Alpert's quasi-steady correlations; it does not incorporate a transport time lag.The DETACT-T2 model'i uses the t-squared correlations of Heskestad and Delichat-sios, which incorporate the transport time lng represented by Equation 23.Analytical solutions of the detector response equations using the t-squared correlations have been developed by BeylerP these also incorpo-rate the transport lag, Suppression Time Lags The suppression time lag is fairly easy to assess for buildings with automatic suppression systems, but it's more difficult to consider where reliance is placed on manual suppression, For wet pipe sprinkler sys-tems, the suppression time Iag should be nil;wator application begins immediately upon actuation of a sprinkler.

This does not imply that the rate of water discharge will be adequate for fire control.A separate analysis is required to determine the adequacy of the water application rate;the discharge rate needed will depend on the transport and detection lag periods as well as on the rate of fire growth.The relation-ships between sprinkler actuation sensitivity and the required dis-charge density for effective fire control have been and continue to be explored in connection with the development of the Early Suppression Fast Response (ESFR)and Quick Response Sprinkler (QRS)technolo-gies.The suppression time lag for dry-pipe sprinkler systems can be SUPPBEssloH Lho TiMES 0 25S evaluated by actual test;it should not exceed one minute at the most remote sprinkler if the system conforms with the intent of NFPA 13,'4 although for systems with a pipingcapacity of less than 750 gallons, the sprinkler standard does not require this performance.

In recognition'of the impact of the suppression time lag on the potential for fire control, NFPA13 requires that dry systems be designed for an area of operation 30%larger than for wet systems.Nonetheless, the better performance record of wet systems's undoubtedly related to their reduced suppres-sion lag times.Suppression legs associated with manual suppression can be at least five minutes under good circumstances.

Usually, it will be even longer before effective fire suppression activity commences.

For example, under ideal conditions a capable urban fire department may be notified and respond within five minutes to a building fire.But it will take more time to evaluate the situation, make attack decisions, hook engines to hydrants, pull hoses to the fire floor, and ultimately put water effectively on the fire.Any uncertainty with respect to fire department notification and response can add significantly to this delay, In any case, typical suppression legs associated with manual firo fighting can make this protection strategy inefFective against rapidly developing fires even under optimum conditions of fire department notification and response.Discussion The general goal of fire mitigation strategies is to minimize the net effect of the three time legs discussed above.It is useful to consider fire growth scenarios and mitigation strategiesin terms of these lagperiods.

This represents a convenient framework with practical physical signiTi-cance;it also helps to illustrate why some fires are difficult to control, even with automatic fire suppression systems.The transport time lag is primarily a geometric factor, although, as indicated by Equation 23, the fire growth rate has an influence on this parameter.

Transport time legs are most significant in tall spaces and in spaces with thermally actuated fire detectors located at large spac-ings.It is not by coincidence that fires in tall spaces frequently result in high challenge fires.In such spaces, the transport time lag can be minimized through the use of line.of-sight detection devices, such as optical flame detectors, which respond to radiant energy emitted by n fire.This energy travols to the detector at the speed of light, thus eliminating the transport time lag.The detection Iag for these devices is also minimal because of their sensitivity.

Due to the potential for unwanted alarms with these devices, they rarely are used to actuate.suppression systems automatically, so the suppression time lag still must be addressed where they are used.

~gf~li 0 280 0 PIRE 1'k;CIINOLOOY AUOUST l990 SUPPRESSION CAO TlhtES 2G1 Examples Two examples of t-squarod fires will be considered to illustrate the potential impact of the transport, detection, and suppression time lags on tho performanco of fire protection systems.The first example considers"slow,""medium,""fast," and"ultrafast" t-squared fires'n a sprinklered space with a high ceiling, such as an atrium, an exhibition hill, or a warehouse.

The second example considers the response to these same fires of a heat detection system installed in accordance with tholisted spacingoftheheatdetectorsin alarge space with low ceilings, such as an open o6ice area.The fire source is assumed to be at the floor level for both examples.Example 7: Spri n/tiers in a Space uti th a High Ceiling The space considered here has a ceiling height of 15.25 m (50 ft).Sprinklers with a temperature rating of 71'C and an RTI value of 150 (ms)~are spaced on a 3 m grid, representative of an ordinary hazard spacing.The maximum radial distance of a sprinkler to the plume centerline is given by: r=s/42=2.1m r/H=2.V15.25=0.14 (35)(36)Assuming a fire located at floor level that develops with a theoretical heat release rate characterized as"ultrafast," this yields: t,=[0.954 (15.25+2.1)]/(0.028 x 0.188 x 15.25)isi s (37)=27 s (12 s by Newman's method-Equation 25)The detection time lag is a function ofboth the fire environment and the detection devico being used.For detection devices, such as sprin-klers, heat detectors, and smoke detectors, that roly on the transport of buoyant gases to tho ceiling for their operation, the primary environ-mental parameters are the h eat release rate of'the fire and the geometry of the space.For such devices, tall spaceshave longer detection lagtimes than shorter spaces because of the additional entrainment of air that occurs over the additional height.According to plume theory and the available correlations, air entrainment varies as the 5/3 power ofh eight.Coupled with the longer transport time lags for such spaces, this means the design of fire protection systems for such spaces requires special attention.

In tall spaces with significant potential lifo safety implica-tions, such as hotel atria, the control of combustibles to minimize the possibility of a serious fire may be the most reasonable alternative.

The detection time delay, t, for this example is calculated to be 216 s, using the DETACT-T2 model." Thus, a quasi-steady analysis would suggest sprinkler actuation at a heat release rate of 8.8 MW (ate), while a t squared analysis yields a heat release rate at sprinkler actuation of 11.2 MVf (a (tt+t+/, a 28'fo increase.The relative importance of this diA'eronce must be evaluated.

For this example, tho size of the fire before sprinkler actuation calculated by either analysis is perhaps of more concern than the differences between the two analyses.Nonetheless, the difference between the sensed and actual heat release rates at detection may be the difference between satisfactory and unsatisfactory sprinkler system performance and should be evaluated.

Results of similar analyses for slow, medium, and fast t squared fires in this space are illustrated in Table 2.No suppression time lag was considered for these calculations, representative of a building with a wet pipe sprinkler system.The detection time decreases with increasingfire growth rate, but the heat release rate at detection increases with fire growth rate despite the faster detection.

Similarly, the transport time lag decreasos with increasing fire growth rate, but the ratio of actual to sensed heat release rates at detection increases with increasing fire growth rates.Example 2;Heat Detectors in Large Spaces utAh Lout Ceilings In this example, the response ofheat detectors listed for spacings of 15.25 m (50 ft)to the standardized t-squared fires is considered, Heat detectors that obtain this listed spacing commonly operate by rate-of-rise (ROR), but for the present discussion, fixed temperature detectors with ratings of 57.2'C (135'F)are assumed.This spacing and tempera-ture rating yield an approximate RTI value" of 54 (m-s)'~.A ceiling height of 3 m is used, representative of typical orice or similar commer-cial spaces.The worst-case radial distance from a detector is calculated as: r=s/42=10.8m (38)r/H=10.8m/3m=3.6 (39)Zhbte 2.Zxaniple results for eprinklers in o 15.25 m tall epoce.te Growth a t, te Q, Q, Rate (W/s')(s)(s)(MW)(MS)Q IQ Slow 3 63 1276 4.8 6.3 1.10 Medium 12 48 670 6.4 6.2 1.15 Fast 47 36 373 6.6 73 1.20 Ultrafast 188 28 216 8.8 11.2 1.28 Ib 0 0 0 0 262 FlRE TECNNOLOGY hUGUST l990 Ta6l>>3.Example results/ar det>>ctors at 15.25 m spacings.t'rowth a Rate (W/s')Q, Q.(s)(s)(MW)(MW)Q,/Q, Slow 3 70 828 2.0 2.4 1.20 Medium 12 52 463 2.6 3.2 1.23 Fast 47 40 277 3.6 4.7 1.31 Ultrafast 188 30 172 5.6 7.7 1.38 For a fire with a theoretical heat release growth rate characterized as"fast," the transport lag is calculated as;SUPPRESSION LAG TlkfES detection and suppression systems may not provide an adequate level of protection.

Those systems may not provide fire control or suppression before an unacceptable hazard develops.In such spaces, a number of alternative fire protection strategies can be considered:

1.The use of more fire resistant materials and products to reduce the rates of fire growth and hazard development; 2.The use of fire detection devices that do not rely upon the transport and detection of thermal fire signatures; 3.The use of automatic suppression systems to minimize suppres-sion lag times.tt=t0.954 (3+10.8)]/(0.028 x 0.047 x 3)i+s (40)=40 s (48 s by Newman's method-Equation 25)For this case, a detection time of 277 seconds is calculated without the transport lag;the corresponding heat release rate is 3.6 MW.When the transport time is considered, the detection time becomes 317 seconds and the corresponding heat release rate is 4.7 MW.This represents an increase of 31 percent compared to the quasi-steady case.Results of similar calculations for the four standardized parabolic fire growth rates are tabulated in Table 3.These calculations show the same trends that are found in the first example.These examples help to illustrate the potentially important role of the transport lag in the response of fire detection devices that rely on the transport of buoyant gases to and across the ceiling.Care must be exercised in the application of quasi-steady models of detector response, which do not consider the influence of this transport lag.Summazy The relationship between quasi-steady and power law data correla-tions for fire plumes and ceiling jets has been discussed.

Available correlations reduce to the same form, once a transport time lag is considered, The roles of this transport lag, a detection lag, and a suppression lag on the development and suppression of building fires have been considered.

The evaluation of fire protection strategies can be considered in terms of these three time lags.Methods to evaluate existing or proposed fire protection strategies in terms of the three lag periods have been presented for largo spaces with flat, unobstructed ceilings.In many spaces, particularly tall ones and spaces with large detector spacings, traditional thermally actuated fire The expected effectiveness of these alternatives can be evaluated separately and jointly by the methods discussed here.Nomenclature g/(c p, T,)(0.028 m'/kg or m'/kW s')c Specific heat of air (kJ/kg-E)Distance traveled by fire gases (m)D Nondimensional distance parameter dT Temperature rise above ambient (K)dT'ondimensional temperature rise above ambient (gHsts/(AQ)"'J (d T/TP g Gravitational constant (9.8 m/ss)H Height above plume source (m)kPlume/ceiling jet temperature coefficient (K-m~lkW)kPlume/ceiling jet velocity coefficient (m~/s-kW'a)p Fire growth exponent p.Density of air (kg/ms)Q Total heat release rate of'fire (kW)r Radial distance from fire axis (m)s Detector or sprinkler spacing(m) t Time (s)t, Incubation time offset (s)t'ondimensional time T Temporature (Ig u Average velocity of fire gases (m/s)U Fire gas velocity (m/s)U Nondimensional velocity(H/(AQUA)'t'-

U z Coordinate above plume source a Power law fire growth coeflicient(kW/s>)

0 0 264 I'IR6 TECIIHOIACV AUGlNI'SO 0 SUPPRI'%SIGH IAO 77hti'C 2(i5 Subscripts a Actual'Convective cj Ceiling jet crit Critical d Detection lag f Pertaining to the heat front l Transportlag o Ambient pl Plume s Sensed, suppression lag sup Suppression t, theoretical lot'Ibtal l3.Evans, D.D., and Stroup, D.R,"Methods to Colculute the Response Tiino of Heat and Smoke Detectors Installed Below Large Unobstructed Ceilings," Fire Technology, 22, No.I, 1985, pp.54-65.14, Stroup, D.N and Evans, D.D.,"Use of Computer Fire Models forAnalyxing

'he77nal Detector Spacing," Fire Sa fcty Journal, 14, 1988, pp.33-45.16.Heskestad, G.and Smith, H F.,'investigation of a New Sprinkler Sensitivity Approval Tbst: The Plunge'Inst," Achnicct Rcport Scrtot¹:22485.RC 76-T40, Factory Mutual Research Corp., Norwood, MA, 1976.16.Standard for the Installation of Sprinkler Systems, NFPA I3-1987, National Fire Protection Association, Quincy, MA, 1987.17."Automatic Sprinkler Performance Tables,1970Edition,"Fire Journal,64, No.4, 1970.18.Standard on Automatic Fire Detectors, NFPA 72P 1987, National Fire Protection Association, Quincy, MA, 1987.References 1.Alpert, R.L.,"Calculation of Response Time of Ceiling.mounted Fire Detectors," Pire Technology, 8, 1972, pp.181-195.2.Heskestad, G.and Delichatsios, M.A.,"The Initial Convective Flow in Fire," Scucntcenth Symposium (International) oIi Combustion, The Combustion Institute, Pittsburgh, pp.1113-1123.

3.Alport, R L,and%ard,E JEvaluationof UnsprinkleredFireHaxards,"Fire Sa fety Journal, 7, 1984, pp.12'7-143.4.Boyler, CL.,'Fire Plumes and Ceiling Jets,"Fire Safety Journo(, 11,1986, pp.63-75.5.Morton, B R., Taylor JB., and Turner, G I., Turbulent Gravitational Convec-tion from Maintained and Instantaneous Sources, Proceedings of the Royal Society, Vol.A234, London, 1966, pp, 1-23.6.Alpert, RL., lbrbulent Ceiling Jets Induced by Large4cale Fires,'Coiubus-tion Science and Ztchnology, 11, 1975, pp.197-213.7.Beyler, C.L.,'ADcsign Method for Flaming Fire Detection,"Eire Technology, 20, No.4, 1984, pp.5-16.8.Heskestad, G.and Delichatsios, MA.,"Update: The Initial Convective Plow in Fiir,'o appear in Eire Safety Journol.9.Tbwarson, A.,"Generation of Heat and Chemical Compounds in Fires," The SFPEHandbooh of Fire Protection Engineering (PJ.DiNenno, Editor-in-ChieQ, National Firo Protection Association, Quincy, MA, 1988, pp.1-179-1-199.10.Johnson, J E.,"Conceptsof Fire Detection," Pyrotronics, Inc., Cedar Knolls, NJ,1970,p.

1, ll.Newman, J.S., Principles for Fire Detection,'ire Schfioiogy, 24, No.2, 1988, pp.116-127.12.Newman, J.S.,"Prediction of Fire Detector Response, Eire Safely Journal, 1$1987, pp.206-211.1

~iO'<ll' C)C)EA QO C)00 c~~HuCle c+O pe RBg~c~~c A A I 0 If)0'f4*<<ggggEY PO~Qc)~~~.~=7 R FPL LI EN IN RKH P St.Lucie Plant February 1-2, 2000

AGENDA NRC, FP8cL and FPC Licensing Workshop February 1-2, 2000 Plant St.Lucie Februarv 1" 8:00-8: 1'5 8:15'-8:45 8:45-9:15 9:15-9:45 Introduction/Orientation Electronic FSAR Electronic Technical Specifications NOEDs: (inc.Weather Related)Facility Host Herb Berkow Paul Infangcr-Crystal River Margaret DiMarco-St.Lucie Herb Berkow 9:45-10:00 Break All 10:00-10:30 Regulatory Issues: Status of Design Bases, FSAR, and 10 CFR 50.72/73 Projects Rich Correia 10:30-11:00 10 CFR 50.59 11:00-11:30 Attributes of a Good Relief Request 1 I:30-12:30 Lunch 12:30-12:45 ADAMS Status Len Wicns Kahtan Jabbour Karen Cotton 12:45-1:45 Licensing Processes-NRC Perspective

-Environmental Assessments Robert Martin Len Wiens 1:45-2:45 Licensing Processes-FP&L-FPC Ed Weinkam Steve Franzone Sid Powell 2:45-3:00 3:00-4:15 Break Attributes of-a Good Submittal Breakout Facilitators:

Ed Weinkam Steve Franzone Sid Powell 4:15-5:00 Summary/Conclusions Breakout Facilitators NRC-NRR-FPEcL.FPC Licensing Workshop 02/Ol/00

~~lli 41' AGENDA,(Continued)

NRC, FP&L and FPC Licensing Workshop February 1-2, 2000 Plant St.Lucie Fcbruarv 2" 8:00-8:30 Risk informed Applications Rule-Making Rich Correia 8:30-9:00 9:00-10: IS 10: IS-11:00 11:00-11:30 Role of Project Manager Critique Licensing Submittals Breakout Summary/Conclusions from Breakout Workshop Conclusions and Closing Comments Kahtan Jabbour Facilitators Facilitators Herb Bcrkow Facility Host 11:30 End of Workshop NRC-NRR'FPAL-FPC Licensing Workshop 02/OI/00 lS!I FINAL SAFETY ANALYSIS REPORT ELECTRONIC FSAR Presented by: Paul Infanger February 1, 2000 IS~4S-l5 J FINAL SAFETY ANALYSIS REPORT~Electronic Format>Ease of use>>FPC workers and vendors familiar with Adobe Acrobat{free viewer}>>Built-in search tools>>"Perfect" printouts>>Cross-platform

>Convenient and portable>>Loaded on FPC LAN>>CD-ROM copies available>Improved change history and tracking

/Q~ii

~~J~~FINAL SAFETY.ANALYSIS REPORT~Saves production cost>Reduced the number of paper Controlled Copies on-site from 63 to 9>Issue about 20 CD-ROMs to vendors and employees>Reduced NRC copies from 11 paper to 2 paper and 4 CD-ROMs iR V I ,ii J FINAL SAFETY ANALYSIS REPORT~Living FSAR>Interim Revisions"quarterly">Keeps FSAR current>>NRC will get update mid-February current to 12/31>Projected changes file>Reduces burden for NRC revision k'I ik C~~c)~~FINAL SAFETY ANALYSIS REPORT~Software C v Native files in Microsoft Word...>Process into PDF with Adobe Acrobat Version 4.0>Add Hyperlinks and Bookmarks with Ambia Compose>>Autobookmarker (uses Word Styles to make TOC)>>Hyperlinks for Tables and Figures e 0 0

%U~~),~FINAL SAFETY ANALYSIS REPORT~Summary>Saves money, time and effort>Improved product, more current and accessible

>Workers and vendors like it>NRC acceptance

>Eleven plants have inquired on"How to" 0 0

~~rtle E~~Electronic Technical Specifications Presented by: George Madden dtMargaret Bimarco February 1, 2000 i it il zmz ELECTRONIC TECH SPECS~Objective:

=Place Unit 1 and Unit 2 Technical Specifications On-Line in a Controlled environjlIient

-Ability to retrieve, view, search and print Controlled Technical Specifications from desktop le iN ib z+z ELECTRONIC TECH SPECS~Project Plan-Replicated Electronic Procedures

-Word Processed Tech Specs When Time Allowed-Created PDF Files And Links-Proof Reading Final Product Piior To Implementation

-Target Iinplementation May 2000 i5ib pr z ELECTRONIC TECH SPECS NS~MOM~'R~Each TS Page Is Controlled As a Separate File in Word and Adobe Acrobat (PDF)~Individuals PDF Pages Are Combined Into One PDF Document Per Unit~Created Hyper Links by Section Within the PDF Document 0$N 0 pwL ELECTRONIC TECH SPECS~Organization

-Technical Requirements Manual-This Is Relocated Tech Specs-Facility Operating License-Tech Specs Appendix A-Tech Specs Appendix B Ip it

'0 vi L, ELECTRONIC TECH SPECS Appendix A-Unit 1 Tech Specs-List of Effective Pages-Index Section 1.0 Definitions Section 2.0 Safety Limits and Limiting Safety System Settings-Bases for 2.0 Safety Limits and Limiting Safety Settings Sections 3.0 and 4.0 Limiting Conditions for Operation and Surveillance Requirements Sections 3/4.0 Through 3/4.11-Bases for Sections 3.0 and 4.0 Section 5.0 Design Features Section 6.0 Administrative Controls

(]p 0

~~L ELECTRONIC TK~Benefits Approximately 50 Hard Copies of Controlled Tech Specs-This Can Be Reduce to Less Than 10 Less Time to Make Revisions Each Employee Will Have Access to Tech Specs From Their Desktop Ability to Perform Word Search More Accurately and in Less Time Support NRC Electronic License Submittal=Ability to Submit Electronic Mark-Ups Opposed to Pen and Ink-Ability to Email Final Pages in PDF Format (iQ IS

~i L ELECTRONIC TECH SPECS~Potential Improvement Opportunities:

-Administrative Change to Replace Existing Tech Specs With the Electronic PDF Version-Administrative Change to Re-number Tech Spec Section Pages (Change 3/4 1-1a, 3/4 1-1b, etc.To 3/4 1-1, 3/4 1-2, etc.By Renurnbering the Existing Pages by Section)-Eliminate Blank Pages i

NOTICES OF ENFORCEMENT DISCRETION REVISED STAFF GUIDANCE-PART 9900 gag REgg C~Cy I-o Cl U)0 Yg~O Herb Berkow Division of Licensing Project Management Office of Nuclear Reactor Regulation VS il SIGNIF.ICANT CHANGES TO THE NOED GUIDANCE PART 9900 GUIDANCE WAS REVISED ON JUNE 29, 1999~PROCESS IMPROVEMENTS FOR NOEDs RELATING TO SEVERE WEATHER OR OTHER NATURAL EVENTS reviously an enforcement discretion now an NOED~Prior Commission approval not required~STAFF DOCUMENTATION CHANGES i ih,,

PROCESSES FOR ADDRESSING NONOMPLIANCE WITH REQUIREMENTS

~NOEDS ARE APPROPRIATE ONLY FOR NONOMPLIANCE'WITH TS OR OTHER.LICENSE CONDITIONS

~NOEDS ARE NOT APPROPRIATE FOR NONCOMPLIANCE WITH:-.REGULATIONS-PROCESS EXEMPTIONS

-10 CFR 50.12-CODES-PROCESS RELIEFS-10 CFR 50.55a-UFSAR-CHANGE PER 10 CFR 50.59 OR OPERABILITY DETERMINATION GL 91-18 REV.1 AND PROCESS LICENSE AMENDMENT-10 CFR 50.90 il'0 TWO TYPES OF NOEDs~(1)RADIOLOGICAL SAFETY CONSIDERATIONS (REGULAR NOED)FORCED COMPLIANCE WITH LICENSE WOULD INVOLVE PLANT-RELATED RISKS DUE TO UNNECESSARY TRANSIENT~(2)OVERALL PUBLIC HEALTH AND SAFETY CONSIDERATIONS (A SEVERE EXTERNAL CONDITION-RELATED NOED).FORCED COMPLIANCE WITH LICENSE MAY AFFECT GRID STABILITY, EXACERBATING IMPACTS OF SEVERE WEATHER OR OTHER NATURAL EVENTS ON OVERALL PUBLIC HEALTH AND SAFETY il~Ia SEVERE WEATHER/NATURAL EVENT NOEDS~HISTORY&EVOLUTION~CURRENT GUIDANCE&PRACTICE~government or responsible independent entity makes assessment that need for power and overall public health&safety considerations constitute an emergency situation~.staff must balance public health 8 safety implications with potential radiological risks~~risks must be acceptably small fi~EXAMPLES 4 granted~WEATHER-RELATED VS."REGULAR" NOED compliance issue vs.degraded or inoperable component/system 0 iS 0 PR S GES~ALL NOED-RELATED TELECONFERENCES ARE MADE THROUGH THE NRC HEADQUARTERS EMERGENCY OPERATIONS CENTER RECORDED TELEPHONE LINE (301)816-5100.~LICENSEES ARE NO LONGER REQUIRED TO STATE WHETHER: prior adoption of TS enhancement initiatives (GL 87-09, Line Item Improvements or the Improved Standard TS)would have obviated the need for the NOED the noncompliance involves a USQ i FOR ALL NOEDs (REGIONAL OR NRR)REGION TO OPEN AN UNRESOLVED ITEM (URI).~This will facilitate:

-tracking-verification of resolution activities

-documentation and closure of inspection

-enforcement action deterrriination 0

g P kP o'I STATUS OF DESIGN BASES, UFSAR, and 50.72/73 PROJECTS gp,R REGg po C'g 0 Q Yr@0 Richard P.Correia U.S.NRC 301-415-2024 RPC@NRC.GOV O~0 0 DESIGN BASKS OB JECTIVE~Provide clear guidance on what constitutes design bases information as defined in 10 CFR 50.2 0 0 l DESIGN BASKS BACKGROUND

~Engineering team inspections (late 1980s)~Industry Guidelines (NUMARC 90-12)-design bases reconstitution

~NUREG-1397

-assessment of design control practices and reconstitution programs 0

DESIl" X BASKS BACKGROUND(CONT.)

~Commission Policy Statement (August 1992)>Acknowledged industry efforts~Emphasized importance of understanding and maintaining design bases-Plant physical and functional characteristics are maintained and are consistent with the design bases as required by regulation

-SSCs can perform their intended functions-Plant is operated in a manner consistent with design bases~Millstone and Maine Yankee Lessons Learned~10 CFR 50.54(Letters~Enforcement issues 0 0 0 DESIGN BASES RELEVANCE OF DESIGN BASES~Design Bases used iri the following regulations:

~50.34 (FSAR content)~50.59 (Changes-effective 2000)~50.72, 50.73 (Reporting)

>Appendix A to part 50 (GDC)~Appendix 8 to part 50 (QA)~Used to evaluate degraded and nonconforming conditions 0 iS 0 DESIGN BASKS NRC ACTIVITIES

~Interact with Industry on NEI 97-04~Publish draft Regulatory Guide (RG)endorsing revised NEI 97-04 (11-17-99)

~Consider changing 10 CFR 50.2 definition 0

DESIGN BASES STAFF ACTIVITIES and TENTATIVE SCHEDULES~Draft Commission Paper under Management review (Jan.2000)I Publish draft RG after Commission approval (Feb.2000)h~Resolve comments on draft RG (June 2000)~ACRS and CRGR briefings July 2000)~Commission Paper with final RG (Aug, 2000) 0 IO 1 0 or il iS iS UFSARs BACKGROUND

~FSAR updates required by 10 CFR 50.71(e)~Guidance contained in:~RG 1.70, rev.3 (November 1978)~Generic letter 80-110 (December 1980)~NRC determined additional guidance was needed Millstone Lessons Learned-February 1997~Ensure UFSARs updated to reflect changes to design bases>Reflect effects of other analyses performed since original licensing ik il UFSARs BACKGROUND (cont.)~Commission Direction (June 1998)>Disapproved staff recommended Generic letter~Continue to work with Industry on NEI 98-03>Establish enforcement discretion period for 6-to 18-month period after final guidance issued, depending on risk significance Ik 0 UFSARs MORE RECENT ACTIVITIES

~NRC Staff and Industry public meetings to resolve differences

~DG-1083 and SECY 99-001~DG-1083 published for comment endorsing NEI 98-03, rev.0 0 0 UFSARs PUBLIC COMMENTS ON DG-1083~Incorporation by reference>Position: Part of UFSAR, therefore, docketed and subject to 50.59 and 50.71(e)~Resolution:

reference materials on file, but not on docket~Information retention for safety significant SSCs>Position: NEI 98-03 not to be used to remove information on safety significant SSCs~Resolution:

NEI 98-03 clarified consistent with staff position ggi 15 UFSARs PUBLIC COMMENTS ON DG-1083 (CONT.)~Removal of drawings~NEI 98-03 added guidance on conditions for removal of drawings~Removal of commitments

~NEI 98-03 change:d to clarify that only obsolete or less meaningful commitments may be removed 0

SECY 99-203 and REGULATORY GUIDE 1.181~Endorses NEI 98-03, rev.1 as acceptable to meet 10 CFR 50.71(e)~NEI 98-03, rev.1 acceptable for allowing improvements and simplification of content and format of UFSARs~Does not supersede any prior commitments

UFSARs SRM-SECY-99-203 I Commission approved publication of RG 1.181~Inform Commission on results of FSAR updates monitoring efforts=Whether guidance for UFSAR updates or design bases needs revision Whether additional regulatory oversite is warranted-Ensure a representative sample of FSARs is examined~Clarified certain RG language~Ensure consistency with regulatory guide for design bases il il 0 Staff Activities

~Developing monitoring program per Commission direction I Enforcement discretion for risk-significant matters expires March 31,2000~Enforcement discretion for less risk significant matters expires March 31, 2001

~i 10 IS J 0 10CFR50.72,50.73 RULEMAKING BACKGROUND

~SECY-98-036 (March 4, 1998)~Proposed rulemaking plan~SRM-98-036 (May 14, 1998)~Commission approved plan~ANPR published (July 23, 1998)~Requested public comments~Public meetings~NEI".table top exercises" It It 10CFR50.72,50.73 RULEMAKING PROPOSED RULES OBJECTIVES

~Better align reporting requirements with NRC needs for information

~Reduce reporting burden~Clarify.reporting requirements where needed~Maintain consistency with NRC actions to improve integrated plant assessments ll 10CFR50.72,50.73 RULEMAKIXG COMMISSION DIRECTION~SRM 99-119 (June 15, 1999)~Commission approved staff recommendations to publish proposed rules~Invite comment and determine need for reports.on historical problems~Seek comment on new requirement to report component problems:-Significantly degrade ability to fulfill safety function-Could affect similar components 0 IS 10CFR50.72,50.73 RULKMAKING RECENT ACTIVITIES

~Proposed Rule published (June 25, 1999)for 75 day comment period~Staff currently preparing final rule 0

FR 50.59 RULEMAKIN LEN WIENS NRC/FP8 LlFPC LICENSING WORKSHOP il I 0 0 HEQULE~FINAL RULE ISSUED IN FR ON 10/4/99~NEI SUBMITTED NEI 96-07, REV I IN DECEMBER 1999~NRC REG GUIDE TO BE ISSUED IN LATE 2000~IMPLEMENTATION IS 90 DAYS AFTER RG ISSUED 0'I

~REMOVAL OF REFERENCE TO USQ~TERM"SAFETY EVALUATION" CHANGED TO"10 CFR 50.59 EVALUATION"~ADDED DEFINITION OF"CHANGE" AND"FACILITY AS DESCRIBED IN THE FINAL SAFETY ANALYSIS AS UPDATED" 0 0 MAJOR HANGES continued~WILL ALLOW FOR MINIMAL CHANGES, WITHOUT REQUIRING PRIOR NRC APPROVAL~CHANGED"PROBABILITY" TO"INCREASE IN FREQUENCY" OR"LIKELIHOOD OF OCCURRENCE"~MALFUNCTION OF A DIFFERENT TYPE IS BEING REPLACED WITH"MALFUNCTION WITH A DIFFERENT RESULT"

~i)0 MAJ R CHAN E continued~MARGIN OF SAFETY EVALUATION CRITERIA IS REPLACED WITH 2 NEW CRITERIA:~CRITERIA (vii)-EVALUATION OF INTEGRITY OF FISSION PRODUCT BARRIERS i CRITERIA (viii)-CHANGES TO APPROVED EVALUATION METHODS cl 0 IMPA T AND BENEFIT~IMPACTS i WILL REQUIRE MAJOR REVISION TO 50.59 PROCEDURES i WILL REQUIRE NEW TRAINING STANDARDS TO BE DEVELOPED~BENEFITS i OVERALL IMPROVEMENT OVER PREVIOUS RULE LANGUAGE i AGREED UPON INDUSTRY/NRC GUIDANCE

Submitting Relief Requests to the NRC Kahtan Jabbour, NRC Project Manager 10 CFR 50.55a Subjects Subjects 10 CFR 50.55a Paragraph Reactor Coolant Pressure Boundary 50.55a(c)Quality Group B Components 50.55a(d)Quality Group C Components 50.55a(e)Inservice Testing Items 50.55a(f)Inservice Inspection (examination)

Items 50.55a(g)Protection Systems 50.55a(h)

Ik>Discuss why complying with the specified requirement would result in hardshi or unusual~difficult without a compensating increase in the level o quality and safety.~For IST items: Discuss why the proposed alternative provides reasonable assurance that the component or system is operationally ready.~For ISI items: Discuss why the proposed alternative provides reasonable assurance of pressure boundary integrity.

~Specify the duration of the proposed alternative.

~Do not mention im racticalit

.

t Ia'll Table 4 lnservice Testing-Granting Relief in Accordance with 10 CFR 50.55a(f)(6)(i)

Purpose Grant relief and'impose alternative requirements in accordance with 10 CFR 50.55a(f)(6)(i) for inservice~testin items.Dt l tlth d~l tl Necessary eterminations Determine if the proposed testing provides reasonable assurance that the com onent is o erationall read (capable of performing its intended function).

Guidance~Indicate the applicable Code edition and addenda.~Describe the utility's proposed alternative (if any)and bases.D lh hyltl~idi I l th tithyt ply with the specified requirement.

~Describe the burden on the utility created by imposing the requirement (e.g., having to replace a component, redesign the system or shutdown the plant).~Discuss why the proposed testing provides reasonable assurance that the component is operationally ready.~Note: 10 CFR 50.55a(f)(6)(i) allows the NRC to~irn ose additional requirements without having the utility first commit to them.10 CFR 50.55a(a)(3) does not allow this.~Specify the duration of the alternative.

~Do not mention hardshi or unusual difficult.

Table 5 Inservice Inspection

-Granting Relief in Accordance with 10 CFR 50.55a(g)(6)(i)

Purpose Necessary eterminations Guidance Grant relief and impose alternative requirements in accordance with 10 CFR 50.55a(g)(6)(i) for inservice ins ection examination

.Dt t tfth d qt tt Determine if the proposed inservice ins ection examination provides reasonable assurance of com onent or structure ressure bounda inte rit.~Additional guidance in Generic Letter 90-05~Indicate the applicable Code edition and addenda, and describe the Code requirement.

~Describe the proposed alternative (if any)and bases'fh hyttt~gati It Pty tthth specified requirement.

~>>Describe, the burden created by imposing the requirement (e.g., having to replace a component, , redesign the system or shutdown the plant).~Describe why the proposed inspection (examination) provides reasonable assurance of component or structure pressure boundary integrity.

~Note: 10 CFR 50.55a(f)(6)(i) allows the NRC to~im ose additional requirements without having the utility first commit to them.~Specify the duration of the alternative.

~Do not mention hardshi or unusual difficult m Note: For augmented reactor vessel shell weld examination reliefs we authorize a proposed alternative IAW 10 CFR 50.55a(g)(6)(ii)(A)(5) if we determine that the alternative provides an acce table level of gua~lit (rather than the code requirement being impractical).

II~i A EN IDE D UMENT MANA E MENT ACCE SYSTEM ADAM NRClFP8 L/FPC WORKSHOP FEBRUARY 1-2, 2000 LEN WIENS 0 0 WHAT I IT?~MAINTAIN READ-ONLY RECORDS THAT CAN BE READ FROM MULTIPLE SITES~FULL TEXT SEARCH CAPABILITY BY NRC AND PUBLIC~ELECTRONIC DOCUMENTS BECOME OFFICIAL RECORD~REPLACES NUDOCS if 0 TATU~11/1/99-STEPPED IMPLEMENTATION STARTED WITH SCANNING OF DOCUMENTS INTO ADAMS-PAPER COPIES REMAINED OFFICIAL RECORD~I/1/00-NRC STAFF COMMENCED ENTERING INTERNAL DOCUMENTS INTO ADAMS-PAPER COPIES REMAIN OFFICIAL RECORD ik;!k TAT U cont~TBD-TERMINATE PAPER RECORDKEEPING-ADAMS DOCUMENTS ARE OFFICIAL RECORDS i TERMINATE PAPER DISTRIBUTION OF INCOMING DOCUMENTS, WITH LIMITED EXCEPTIONS

~LIVING DOCUMENTS (TECH SPECS, UFSAR)WILL CONTINUE TO HAVE PAPER DIST.

i0 0 ELE TR Nl INF RMATI N EXCHANGE EIE~FUTURE SYSTEM TO PROVIDE ELECTRONIC DOCUMENT EXCHANGE TO AND FROM NRC~PARTICIPATION IS VOLUNTARY 0 il PARTI IPATI N IN EIE~MUST HAVE ACCESS TO INTERNET VIA INTERNET EXPLORER OR NETSCAPE~APPLY FOR AND BE GRANTED A"DIG ITAL CERTI F I CATE".~5 MEG 1000 PAGES LIMIT.LARGER DOCUMENTS WITH PRIOR NOTICE.

~'

PARTICIPATI N INEIE cont~DOCUMENT SUBMITTALS:

i PDF NORMAL w PDF i WORD i WordPerfect

~MAY BE EXPANDED LATER ASCII 0 0 EIE PR E~ELECTRONICALLY SIGN DOCUMENT~PLACE ON EXTERNAL SERVER~SEND EMAIL TO RECIPIENT~NO PUBLIC ACCESS TO EIE

<0 e EXTERNAL A CES~ACCESS NRC EXTERNAL WEB NRC.GOV~CLICK ON"PUBLIC ELECTRONIC READING ROOM" AT BOTTOM OF PAGE~FOLLOW INSTRUCTIONS OR CALL LISTED NUMBERS FOR HELP ib Ib 0ENSITIVE INF RMATIGN~PROPRIETARY, SECURITY, PRIVACY INFORMATION PROTECTED BY ADAMS PROCEDURES AND SOFTWARE~SAFEGUARDS INFORMATION WILL NOT BE INCLUDED IN ADAMS

~i NUD~DOCUMENTS PRIOR TO 11/1/99 WILL CONTINUE TO BE KEPT IN MICROFICHE

~WILL NOT BE CONVERTED TO ADAMS~CAN SEARCH FOR DOCUMENT BY TITLE IN ADAMS LEGACY LIBRARY

<a I LICENSE AMENDMENT REVIEW PROCEDURES NRR OFFICE LETTER 803, REV 3 BOB MARTIN NRR PROJECT MANAGER 0 0 0 Policy~Atomic Energy Act Section 182a~10 CFR 50.36, Technical Specifications

~10 CFR 50.90, Application for Amendment of License I10 CFR 50.91, Notice for Public Comment;State Consultation

~10 CFR 50.92, Issuance of Amendment if 4 IO r 0 Objectives of OL 803~Ensure public health and safety~Promote consistency in processing of license amendments

~Improve internal and external communications

~Increase technical consistency for similar licensing actions~Reduce delays in issuance of license amendments I Ensure that staff RAls are adding value to the regulatory process I Provide NRR staff with an improved framework for processing license amendment applications

0 initial Processing

~Amendments

~Acceptance review~Work planning i Prioritization ih Acceptance Review I Oath 8 Affirmation, State copy~Clear description of change~Safety analysis and justification INSHC and EA (or exclusion)

~Approval and implementation schedules~Is it risk-informed?

0~I Work Planning~PM and technical staff i Search for precedents

~Review method (PM or tech staff)~Scope&.depth of review>Resource planning and schedule~Priority iS l0

~Priority 1 i Highly risk-significant safety concern>Issue involving plant shutdown, derate, or restart~Priority 2~Significant safety issue~Support continued safe plant operations i Risk-informed licensing action i Topical report with near-term or significant safety benefit 0<5 Priority~Priority 3 i Moderate to low safety significance i Cost beneficial licensing actions~Generic issue or multi-plant action~Topical report with limited benefit iS NSHC Determination

~NSHC Based on 50.92 (51 FR 7751)~Significant increase in probability or consequences of an accident~Possible new or different accident i Significant reduction in margin of safety~If proposed NSHC, hearing can be after amendment~If SHC or no determination, any hearing would precede amendment

'1i 0 0

~"Normal" amendments, 50.91(a)(2)

>Bi-weekly or individual Federal Register notices-30 day comment period~Notice of proposed amendment, proposed NSHC, hearing opportunity i Notice of issuance~If a proposed NSHC determination is not made, use individual notices~Can't be handled as an exigent or emergency 0 0 Noticing-Exigent Amendment~Notice in Federal Register (FR)if amendment is to be issued after 15 days but before 30 days i Individual FR notice i Repeat in bi-weekly FR notice~Notice in local media if amendment is to be issued after 6 days but before 15 days~Repeat in bi-weekly FR notice~Amendments require a final NSHC determination 0

Noticing-Emergency Amendment~Emergency amendments noticed after issuance for comment and an opportunity for hearing iS Reviewer Assignments

~Reviews can be performed by PM or technical staff, considerations include: Technical complexity 8 risk significance PM technical expertise~Conformance to improved Standard Technical Specifications (STS)guidance Conformance to precedents

~Resource availability 8 schedule needs i5<f!5' 0 Review Process and Documents Preparation

~Review process~Precedents i Requests'for additional information (RAls)>Regulatory commitments

~Document preparation

~Safety evaluation i Concurrence review>Amendment issuance i1 0 Review Process and Documents Preparation

~Precedents

>Ensure request meets current expectations

-Format-Guidance to industry-Technical content 0

Review Process and Documents Preparation L 7<<A g W'E+lg~~&kl8444&o I 4444k Al 4&I Wg,'I4 4 04 v, P 4--4.~Requests for additional information

~Staff goal: 1 RAI per reviewing technical branch i Notify the licensee-Discuss questions-Resolve minor issues-Answers needed to make regulatory finding are placed on the docket-Establish reasonable response date-Document conversation on cover letter~Questions should be developed with consideration of regulatory basis of the request 0 0]pi Commitments

~Regulatory commitments are information relied on by the staff in making its conclusion but are not included in the TS~Current staff practice outlined in SECY-98-224, NRC guidance on commitment management

~Office letter 900 to be issued Spring 2000>Will provide further guidance i

0 Commitments

~Hierarchy of licensirig basis information

>Obligations

-license, TS, Rules, orders i Mandated licensing-basis information

-UFSAR, QA/security/emergency plans i Regulatory Commitments

-docketed statements agreeing or volunteering to take specific actions i Non-licensing basis information iS i~~

Commitments

~Commitments stated in the safety evaluation are considered art of the licensing basis but are not legally binding requirements

~Safet evaluation should clearly state what actions are considered regulatory commitments

~Control of commitments is in accordance with licensees'rograms IS iS~i Commitments

~Escalation to license conditions reserved for safety-significant matters (e.g., those that meet 10 CFR 50.36 criteria for inclusion)

~Staff is continuing to include license conditions for relocation of information to UFSAR or other controlled documents in amendment implementation 0 I Safety Evaluation

~Routinely included i Staff evaluation

-why the request satisfies regulatory requirements

~State consultation

~Environmental considerations

~As needed i Regulatory commitments i Emergencylexigent provisions

>Final NSHC determination 0 e Concurrence

~Licensing Assistant i Format and revised TS pages~Technical Branch i Technical adequacy~Technical Specifications Branch i Significant deviations from ISTS guidance or changes consistent with ISTS i Use of 10 CFR 50.36 criteria~Office of the General Counsel~Legal defensibility and completeness il 0)gi Amendment Issuance~Ensure that we'e addressed all comments from public and state~Transmitted to licensee via letter>Issued after associated EA>Standard distribution (cc)list-Notify NRC staff of licensee s organization changes to list via docketed letter-Federal Register notice of issuance Ik ENVIR NMENTAL A E MENT gpR REGS (gp 0@n p 0 r+LEN WIENS 0,

ENVIRONMENTAL A SE SMENTS~REQUIREMENTS i 10 CFR 51.21-ALL LICENSING ACTIONS UNLESS-REQUIRE EIS-MEETS CATEGORICAL EXCLUSION OTHER ACTIONS PER 51.22(d)-SPECIAL CIRCUMSTANCES NRC DISCRETION DUE TO UNIQUE, UNUSUAL OR CONTROVERSIAL CIRCUMSTANCES II ATEGORI AL EX LUSI NS 10 CFR 51.22~C.8 OPERATOR LICENSING~C.9 OPERATING REQUIREMENTS

~C.10 ADMINISTRATIVE PROCEDURES

~C.12 SAFEGUARDS

~C.21 TRANSFERS 0 il FR 51.22.9~PROVIDED: i NSHC,AND i NO SIGNIFICANT CHANGE IN TYPES OR SIGNIFICANT INCREASE IN AMOUNT OF EFFLUENTS, AND i NO SIGNIFICANT INCREASE IN INDIVIDUAL OR CUMULATIVE EXPOSURE 10~APPLIES TO: i REQUIREMENTS WITHIN THE RESTRICTED AREA AS DEFINED BY 10 CFR 20, OR i CHANGES TO INSPECTIONS OR SURVEILLANCE REQUIREMENTS 0 IS 10 10 FR 51.22~CHANGES TO SURETY, INSURANCE ANDlOR INDEMNITY REQUIREMENTS

~CHANGES TO RECORDKEEPING, REPORTING, OR ADMINISTRATIVE PROCEDURES OR REQUIREMENTS

~GENERALLY APPLIES TO ADMINSTRATIVE CONTROLS SECTION OF TS>DOES NOT INCLUDE CHANGES TO CORRECT TYPOGRAPHICAL ERRORS OR EDITORIAL CHANGES 0 0 0 PR EDURAL UIDAN E~NRR OFFICE LETTER 906~TYPES OF ACTIONS REQUIRING EA i EXEMPTIONS i AMENDMENTS WHICH INCREASE SFP STORAGE CAPACITY NRC DISCRETION i POWER UPRATES (IF INCREASED POWER NOT COVERED UNDER ORIGINAL FES)i LICENSE RENEWAL i DECOMMISSIONING i EPP CHANGES g~i RESP NSIBiiiyy~NRC STAFF RESPONIBLE FOR PREPARATION

~MAY REQUEST INFORMATION FROM LICENSEE IN ORDER TO MAKE FINDING 0

t ENERALLY, IF IN D UBTA TO WHETHER AN ENVIRONMENTAL A ES MENT WILL BE RE UIRED, A K THE PR JE T MANAGER 0

FPC I FP&L I NRC LICENSING WORKSHOP LICENSING PROCESSES Presented by: Sid Powell February 1, 2000 I 0 II LICENSING PROCESSES~LICENSE AMENDMENT REQUEST (LAR)PREPARATION

~LICENSE AMENDMENT IMPLEMENTATION ll!5, rgmPe LICENSE AMENDMENT REQUEST~INITIATION and EVALUATION

~RESOURCES a Recent History a Future Plan e DEVELOPMENT a.Technical Resources a Licensing Engineer~TRACKING i~..10 CgmcP e 0 LICENSE AMENDMENT REVIEW BOARD itLARB}I CONCEPT~QUORUM a Chairman (MNL or Designee)o Operations a Engineering a Licensing (not the responsible Licensing Engineer)o Others as designated

~RESPONSIBILITIES a.Technical content a Workability a Schedule o Implementation Plan 0.II e~i~APPROVAL PACKAGE (THE RED FOLDER)~CONTENTS+Cover Form a.Draft Submittal a Support Organization ReviewlConcurrence Form Includes Peer Review a Commitment Identification Form a Applicable Regulatory and Internal Correspondence

+Validation Package~RESPONSIBILITIES a Licensing Engineer o Technical Lead 0 ih APPROVAL PATH~LARB o PLANT REVIEW COMMITTEE o One Week Prior to Meeting~TECHNICAL and MANAGEMENT REVIEW~ADMINISTRATIVE REVIEW (Parallel Process)~NUCLEAR GENERAL REVIEW COMMITTEE+Quarterly Meetings a.Briefings and Telecon Votes~FINAL SIGNATURE 0 IS LICENSE AMENDMENT APPROVAL 0 I~

~mc LICENSE AMENDMENT IMPLEMENTATION

~IMPLEMENTATION PLAN a Developed and Approved by the LARB a Input to Corrective Action System by Licensing Engineer Precursor Card (PC)a Actions Assigned to Responsible Organizations Completed Actions Approved by Responsible Organizations PC Closure Approved by Licensing I LICENSE AMENDMENT REVIEW a Licensing Engineer a LARB a Administrative

~DOCUMENT CONTROL DISTRIBUTION

~BULBAR P'&+PT LI E I PR E Presented by: Steve Franzone February 1, 2000 II PT L E I ENCLOSURE I (Page I of I)PROPOSED LICENSE AMENDMENT FLOWCHART PLA REQUEST (tschmcnt I)Prepare PLA Package Pnwidc PLA Pachsgc for I Review Feedback Loop Attachment 2 Review and Comment Identify Affcctcd Documents (I)Resolve and incorporate Comments le%0)Review PLA h pprovc PLA QQR 0)Approve PLA 5JIKXl (I)Approve PLA Subnut PLA to the NRC Notify Affected Depatmeuts of PLA Submittal and R<<toast lo prcpsrc Changes to Affected Documents, (Attachment 3)IIX'0 Review and ksuance ofhmcndmcot-Verify Amendmcnt vs PLA Transmit Amcndmcat aad Nolify A ffcctcd Cpestmcnts to Chsagc Affected Doe umcnts b kmcntstion Dale Attschmcnt 4 Provide Itst ol'alfectcd docmnents to Lkcnsin~gc Affcclcd Documents obtain PNSC snd POM Approval (if applicable-Provide Compktion Documentation to Liccnsin Ensure sffcacd denancnts are revisedby impkmcntstion date.unkss othctwisc specie<<L Coordinate Distribution of Liccasc Amcndmcnl and issuance of affected documents that incorporate chsagcs (IITPcID: If PLA is canccllcd, all sffcclcd Departments shall bc notified accordingly.

Attachment 5 or simikr lbrm.

ih IN 0 PT LI I P E SUBJECf: SITE LICENSING CORRESPONDENCE REVKW SHEET i 20bD41$SITE VP DUE DATE I/26/00 NRC DUE DATE: 28loo Pleas<<identify on the attached copy those action items, which are your responsibility, aud have aot been complctcd/implemented.

Licensing will track the idcntiTied items oa CI'RAG Note: Nuclear Policy NP409 states that the person whose sigaature or iaitiah have been applied to this document acknowledges personal knowledge of aad accepts full responsibility for the correctncss of the inlormation contamcd ia the document.If a person is only initialing a particular dement of this document, that ia turn is the extent of his responsibility, and shall be idcntilicd as such.PLEASE REFER ALL QUESIIONS TO RESPONSIBLE UCENSINO ENO lEQIERKlKYIEE PNSC REVIEW: PNSC htEETDIO Na scat Gcacrcl at soccer tec ptctitcct CNRB REVIDVt/(~DOCIIMENI'NOTARIZED

/I ace epcscC ccl'oc ctcol Oc accc rmcct Sloe h CtttAO CIRAC CLOSED: Cf RAC OPKNXDi~22L8920 DOCUMEhT DATE STAhtPED INttocj~~tine is~

0 0 0 Procedure No.: Procedure Title'.Page: 13 0-AD M-024 Facility Operating License Amendments Approvel Dete 9/16/99 PLA REQUEST (Attachment I)II F RT Prepare PLA Package I I F I DFP RT F Provide PLA Package for De artmental Review Feedback Loop Attachment 2'NCLOSURE 1 (Page I of I)PROPOSED LICENSE AMENDMENT FLOWCHART Review and Comment Identify Affected Documents I I F I DF RTMF (I)Resolve and Incorporate Comments~P (I)Review PLA ()Approve PLA~NRB (I)Approve PLA~tT VP (I)Approve PLA Submit PLA to the NRC Notify Affcctcd Departments of PLA Submittal and Request to prepare Changes to Affected Documents, (Attachment 3)LJKEBC (I)Review and Issuance of Amendment II I DF R F-Verify Amendment vs PLA-Transmit Amendmcnt and Notify Affcctcd Departments to Change Affected Documents b Im lementation Date Attachment 4 F TFD DF Provide list of affected documents to Licensing FFF TF.D DFP RTMF'I'Change Affected Documents-Obtain PNSC and PGM Approval (if applicable-Provide Completion Documentation to Licensing F I DF RTMF T Ensure affected documents are revised by implementation date, unless otherwise specified.

Coordinate Distribution of License Amendment and issuance of affected documents that incorporate changes/AWT/bsc/evAr T~FI: If PLA is cancelled, all affected Departments shall bc notified accordingly.

Attachment 5 or similar form.

0 SITE LICENSING CORRESPONDENCE'REVIEW SHEET L-2000-xxx

SUBJECT:

Reactor 0 erator-License Renewal SITE VP DUE DATE I/26/00 NRC.DUE DATE: 2/3/00 Please identify on the attached copy those action.items, which,are;your responsibility, and have not been completed/implemented.

Licensing will track the identified items on CTRAC.Note: Nuclear Policy NP-309 states that the person whose signature or initials have been applied'to this document acknowledges personal knowledge of and accepts full responsibility for the correctness of the information contained in the document..If a person is only initialing a particular element of this document, that in turn is the extent of his responsibility, and shall be identified as such.PLEASE REFER ALL QUESTIONS TO,RESPONSIBLE LICENSING ENG.: OI.GA A K X-6607 DOC MF T REVIEW~RE VIBWE TITLE/DFPARTMFNT S ATURFJDATF T, O.Jones S, M.ranzone 0 erations Mana e PNSC REVIEW:/A PNSC CHAIRMAN PNSC MEETING No./A Plant General Manager See Attached Vice President Proofread: (Name)CNRB REVIEW: N/A (ecting umber ate)DOCUMENT NOTARIZED N/A (arne)DOCUMENT DATE STAMPED (Name)I have opened and/or closed the items listed below in CTRAC: ynator te CTRAC CLOSED: 980273 940217 CTRAC OPENED: Letter mailed to NRC.(Name/date)

Emailed to PCC (Name/date) 0 II is-n orme e G IYI les uao pe REGS 0@Cg Q)~0 (6 Q Y/~O Ik Risk-informed re Ulation PRA results/insights

+deterministic insights 0 0 SECY-95-126 NRC Policy Statement on use of PRA~PRA should be used in regulatory matters to the extent supported by the state of the art~PRA should be used to reduce unnecessary conservatism

~PRA evaluations should be as realistic as possible~PRA uncertainties need to be considered in applying Commission's safety goals 0 0' Major Areas of Risk-Informed Regulation

~Licensing~Inspection

~Enforcement

~Performance Assessment il l0 0 Si nificant Licensin Documents~RG 1.174 Changes to licensing basis~RG 1.175 Inservice Testing~RG 1.176 Graded Quality Assurance~RG 1.177 Technical Specifications

~RG 1.178 Inservice Inspection il Principles

• Risk-informed Integrated Decisionmaking

~Meets current regulations

~Defense-in-depth

~Maintain safety margin~Increased CDF or risk is small~Monitoring 0 ik 3s RG 1.174 Figure 3!@'e.REGION II eggmyl1<ahgn e-"<go~a'hlejjbj

""th'e'j'elf,:.:,:~~'.-',:.';

REGION III&.t io-'0 4 CDF~Acceptance Guidelines for Core Damage Frequency (CDF) 0 C 0 U Risk-Informed Licensing Action...any activity that uses risk assessment insights or techniques to provide a key component for determining acceptability of the pl oposecl action

Risk-Informed Licensing Actions~Special administrative handling i Unique identifier i Priority 2~Management review~Technical review~Traditional deterministic review i Assessment of strengths and weaknesses of risk evaluation i Balance between deterministic and risk components I~

Risk-Informed Licensin Actions~Most common types i Diesel generator allowed outage time extension i ECCS allowed outage time extension i Risk-informed ISI, IST~Statistics

~Total RILA:-110 i Approved to date:-70 0

Mana ement versi ht~Risk-Informed Licensing Panel~Resolution of conflicts~Improved timeliness and efficiency

~SECY 99-246 10/12/99 i Requested approval of proposed interim guidelines

~SRM-99-246 1/5/00~Commission approved staff approach 0 i5 Risk-Informed Technical Specifications

~LCO required action end states~Mode change flexibility

~Missed surveillances

~Risk-informed completion times~LCO 3.0.3~Operability definition

~Surveillance requirements coordinated with Maintenance Rule 0

Risk-Informed Part 50~SECY-98-300:

Options for Risk-informed Revisions to 10 CFR Part 50, December 23, 1998~"Option 1"-Current rulemaking activities

-10 CFR 50.59-10 CFR 50.72, 50.73-10 CFR 50.55a 0

Risk-Informed Part 50 cont.~SECY-99-256,"Rulemaking Plan for Risk-Informing Special Treatment Requirements" i Modified scope of SSCs subject to special treatment requirements such as EQ i Reduce unnecessary burden for large number of low safety-significant SSCs i Pilot plant exemptions:

South Texas, others i Final rule planned for early 2002 i5 Risk Categorization and Regulatory Treatment"RISC-1" SSCs"RISC-2" SSCs Safety-Related Safety Significant Non-Safety-Related Safety Significant o j L Special Treatment+Reliability Assurance"RISC-3" SSCs Safety-Related Low Safety Significant Reliability Assurance Out of Scope SSCs Non safety-Related Low Safety Significant Maintain Functions Commercial Treatment ,-ti.,)Deterministic 0 ilk Risk-Informed Part 50 cont.~SECY-99-264,"Proposed Staff Plan For Risk-Informing Technical Requirements in 10 CFR Part 50"~Office of Nuclear Regulatory Research study underway iS' DIVISION OF LICENSING PROJECT MANAGEMENT ROLE OF PROJECT MANAGER~G~p,R REg+Wp,+0 Cy ()0 e Yr o Gy++~r@pQ KAHTAN JABBOUR 0

DLPM FUNCTIONS~LICENSING A UTHORITY~~Licensing Actions~~Mandated Controls~Other Licensing Tasks~INTERFACES

~~Licensees/Owners Groups~~Regions~.Headquarters

~.Public REGULA TORY IMPROVEMENTS TOTAL OF 75 SPECIFIC TASKS iN EXAMPLES OF LICENSING AUTHORITY TASKS LICENSING ACTIONS MANDATED CONTROLS OTHER r Amendmenfs (TS&USQ)r Exemptions

~Reliefs r License Transfers~NOEOs r Lead Planf Reviews r Bases Changes r UFSAR Reviews~50.59 Reviews r QA, Security, EP Reviews~TIAs~2.206s r Backfifs r Plant Sp-ecific MPAs r Commitmenf Management r Hearing Support lN'fi EXAMPLES OF INTERFACE TASKS LICENSEES/

OWNERS GROUPS NRC REGIONS~ROUTINE COMMUNICA TIONS~SITE VISITS/DROP-INS

~LEAD ON TECH ISSUES (MPAs, GSls, USls)~MORNING CALLSMGMT.OVERSIGHT PANELS~ROUTINE COMMUNICA TIONS~TS INTERPRETA TIONS~ENFORCEMENT SUPPORT~EVENT FOLLOWUP NRC~H~MGT.INFO.8 STATUS REPORTS~MISC.LICENSEE REPORTS~INCIDENT RESPONSE~LIC.RENEWAL.SUPPORT~GENERAL SUPPORT TO.OTHER OFFICES~SURVEYS PUBLIC!CONTROLLED CORRESPONDENCE r ALLEGATIONS

~FOIAs~PLANT INFO WEB PAGE SUPPORT 0 0'k XAMPLES OF REGULA TORY IMPROVEMENTS TASKS~LATFOWNERS GROUP INTERACTIONS

+NRR OF'FICE LETTERS r REDEFINITION EFFORT~DLPM HANDBOOK~RULEMA KINGRISK INFORMED EFFORTSLICENSING WORKSHOPS ik il't' TASK EVALUA TiON~PERFORMANCE MEASURES INCLUDE: Timeliness

~Effectiveness

~Efficiency

~Quality~~Quantity TASKS PRIORITIZED VYITH RESPECT TO STRA TEGIC OUTCOMEGOA, LS~~Maintain Safety~~Reduce Unnecessary Regulatory Burden~~Increase Public Confidence

~~Increase Infernal Efficiency 8 Effectiveness RESOURCE ES TIMA TES 4b iS' FP8 L/FPC/NRC LICENSING WORKSHOP St.Lucie site Jensen Beach, Florida Februa 1-2, 2000 On a scale of 1 to 10, please provide an overa//rating for workshop effectiveness Excellent Very Good Good Fair Unsatisfactory 1 0----9--8----7--6----5--4----3---2---1-1.COMMENT ON FORMAT AND CONTENT OF THE WORKSHOP.2.WHAT WERE THE WORKSHOP'S STRENGTHSV 3.WHAT WERE THE WORKSHOP'S WEAKNESSES'P 45' 4.WHAT WOULD YOU CHANGE FOR FUTURE WORKSHOPS?

5.HOW WILL YOU USE WHAT YOU'E LEARNED AT THE WORKSHOP?6.SHOULD THESE WORKSHOPS BE HELD PERIODICALLY AND, IF SO, AT WHAT FREQUENCY?

7.OTHER COMMENTS?

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