ML14079A234

BNP-PSA-086, Bnp Fire PRA - Fire Scenario Data, Enclosure 2, Attachment 25

ML14079A234
Person / Time
Site:	Brunswick
Issue date:	04/30/2014
From:	Rishel R Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation
Shared Package
ML14079A232	List: BSEP 14-0029, Response to Request for Additional Information Regarding Voluntary Risk Initiative National Fire Protection Association Standard 805 ML14079A234 ML14079A235 ML14079A236 ML14079A237 ML14079A238
References
BNP-220, BSEP 14-0029, TAC ME9623, TAC ME9624 BNP-PSA-086, Rev. 1
Download: ML14079A234 (17)

Text

Enclosure 2 BNP-PSA-086, BNP Fire PRA - Fire Scenario Data, Attachment 25

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 1 of 16 BNP-PSA-086 Revision 1 Attachment 25 - Change Package BNP-220

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 2 of 16 1 of 15 Change Control FormlDocument Review Cover Sheet Change Number: BNP-220 Page I of 15 Equipment Tag Number: N/A Cable Number: NIA Reason for Change:

Develop and provide the determination of the HRR for Transient Fire sources in the AOG Building, Service Water Pump Building, Diesel Generator Building, Control Buildin.i, Rad Waste Building, Reactor Building Unit 1. ReactorBuilding Unit 2.

FSSPM Element(s)!Form(s)/Tables(s) Modified:

E] SSEL Data El Cable Information El Routing Fire Zone (s)

E] SSEL References El Cable Routing EQ Fire Zone Information El Circuit Information Dl Cable Construction E- Fire Area information El Analysis Input Circuit Drawings nl Table Exception Modifications: (attach additional sheets if necessary)

E1 Gate [E Compliance Strategy El Description CAFTA:

El Fault Tree Model El FSSPMD El ARC Miscellaneous:

X Other Changes (explain under Description of Change) El Benchmark Test Description of Change:

This change package supports using a 143Kw HRR (98% fire) for transient combustibles in some areas of the plant and inother areas the 317Kw HRR (98% fire) for other areas unless administrative restrictions are used. The results are to support resolution of F&O 1-19. The conclusion is that some area will need to use the 317Kw HRR and others are acceptable with the 143Kw HRR and another group of areas will have to have transient combustible controls installed or an 317Kw HRR will have to evaluated.

Prepared by: Reviewed by:

Rishel, Robert Prepared By 2012.04.28 1602:52:-70'-'04'00' Data Input by: Data Input Verified by:

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 3of 16 2of15 Evaluation of Transient HRR in selected areas:

Scope: Evaluation of transient combustible loading in Control Building, Reactor Building Unit 1 and Unit 2, Diesel Building, Service Water Pump Building and Off-gas facility (AOG). This information will be used to determine an appropriate/ realistic heat release rate for transient combustibles.

Brunswick performs bi-weekly walk-downs of the power block for transient combustibles in accordance with OFPP-013, Transient Fire Load Evaluation. The walk-downs are conducted for the following areas:

• AOG building, all levels

" Control Building, all levels

• Diesel Generator Building, all levels

• Reactor Building Unit 1, all levels

• Reactor Building Unit 2, all levels

• Service Water Pump Building, all levels

• Radwaste Building, all levels

" Turbine Building Unit 1, all levels

• Turbine Building Unit 1, all levels Methodology:

This determination used the results of periodic test procedure OFPP-013, Transient Fire Load Evaluation, conducted frequently. (Bi-weekly and then changed in 2010 to weekly). The purpose of the procedure is to verify compliance with the Appendix R program and the allowances in combustible loading. The allowances are documented in calculation 0-89-0001, Combustible Loading (reference 17). The loading in this calculation is not applicable to this effort in that the calculation basis is to verify total combustible loading per square foot and ensure the requirements in Appendix R program for High, Medium or Low total combustible loadings are met. The transient combustibles loading in the calculation is determined by assuming worse case for all potential activities that could occur in a fire area and maximum potential material at the same time occur. An example of conservatism is assuming that 500 lbs of sheeting is used. The resulting totals are compared to the Appendix R allowances for BTU/square foot for acceptability. This calculation does not attempt to evaluate as found conditions or any realistic configuration. Thus the calculation is a bounding effort and not a realistic evaluation. To investigate the potential for application of the 0-89-0001 calculation to transient loading analysis discussion with some of the individuals who performed these walk-downs indicate that they identified all transient combustibles in the areas, not just the transient combustible that are in excess of allowances per the analysis. A comparison between the allowances per 0-89-0001 and the actuals found per the walk-down sheet is stark difference and indicates the calculation 0-89-0001 is not applicable to this effort. A review of thewalk-down sheets provides evidence that this is correct when it identifies small amount of trash and other burnable as well as rubber and fiberglass in quantities well below the allowed limits.

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BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page4of 16 3of15 The completed walk-downs conducted in the past two years were reviewed and 10 were selected for an in-depth review. The in-depth review consisted of the following attributes:

1. A separate walk down of areas where high transient combustible to confirm what is being documented and to review the configuration of the material being described in the walk-down sheets. The results of the walk-down sheets were compared with the occupancy and storage identified as part of the ignition frequency calculation BNP-PRA-0083, looking for inconsistencies between the evaluated occupancy and storage and the walk-down sheets. The comparison did not identify any discrepancies.

2. Interviews of the operators who conducted the walk-downs to confirm the methodology used in documenting the walk-downs. Additionally discussions with the operators were held on the typical configuration of some of the identified transient combustibles in selected locations.

3. Interviews with the responsible engineer and operators on the background of OFPP-013 procedure and validate the basis for the "acceptable levels" of transient combustibles.

4. Verification of plant wide training on material allowed in the radiological controlled areas as well as expectations on housekeeping standards.

Ten of the completed walk-downs were selected for the depth review. These were selected based upon walk-down occurred in last two years (recent information), the unit was not in an outage, different times of year and separated in time between selected walk-downs. The walk-down dates selected were:

" 6/15/10

• 7/7/10

• 12/15/10

• 1/24/11

• 5/17/11

• 7/19/11

• 9/13/11

• 10/11/11

• 11/9/11

• 11/28/11 Results:

The walk-down documents support the use of a lower transient heat release rate for the Control Complex, AOG Building, Reactor Building Unit 1 and Unit 2, the Diesel Generator Building, Radwaste Building and Service Water Building.

General Comments and Applicable Notes:

Brunswick is a Boiling Water Reactor and as such has a larger number of radiation protection controlled areas than a Pressurized Water Reactor. This results in many areas where there are restrictions on BNP-220 Attachment 1 Page 2

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 5 of 16 4 of 15 combustible material admission for the purpose of limiting generation of radiological contaminated waste. The plant access training module provides the requirement to minimize potential trash (transient combustibles) in the Radiological Restricted areas (RRA) and this is enforced by the Radiation Protection organization at the entrance to the RRA. This requirement exists due to the cost of disposal of radiation contaminated trash has continued to increase and has resulted in significant elimination of trash in these areas. Thus in the RRA (Reactor Building areas) have lower amounts of trash (transient combustible material) than non-RRA locations. Typical items that are restricted are: Package material, cardboard, plastic sheeting, and other material not needed at the job site during maintenance activities.

In the RRA and other non-office areas, the trash that is found included paper, discarded parts, grinding discs, tie wraps, and consumed contamination control material. Interviews with operators who perform these transient walkdowns stated that most of the trash is in containers of about 5 gallon size. Many of these trash containers have self-closing lids. In the office areas of the Control Complex and other areas (outside of Radiation Protection Controlled areas) the trash is largely made-up of paper (reference 14).

Augmented Off-Gas Building:

AOG all elevations (FC203) NFPA 805 location AOG-01: No significant combustible loading was ever noted in the OFPP-013, Transient Fire Load Evaluation for any of the weeks selected.

Conclusion:

Use of 143Kw 98% HRR for AOG is reasonably realistic and bounding.

Diesel Generator Building:

-2 ft to 6 ft Elevation (FC238, 256, 257, 258, 259) NFPA 805 locations: DG-01, DG-19, DG-20, DG-21, and DG-22. Only a small amount of Class A combustible once (< 5 lbs on 7/7/10)

EDG Cells (FC 239, 240, 241, 242) NFPA 805 locations are: DG-02, DG-03, DG-04, and DG-05. Only a small amount of Class A combustible once (<2 lbs of class A combustibles on 6/15/10)

EDG 23 ft Elevation (FC 243, 244, 245, 246, 247) NFPA 805 locations are: DG-06, DG-07, DG-08, DG-09, and DG-10. No transient combustibles identified in these areas during walk-downs beyond the fiberglass carts, rubber insulating mats etc.

EDG 50 ft Elevation (FC 248, 249, 250, 251, 252, 253, 254, 255, 260) NFPA 805 locations are: DG-11, DG-12, DG-13, DG-14, DG-15, DG-16, DG-17, DG-18, and DG-13. No transient combustibles identified in these areas during walk-downs beyond the fiberglass carts, rubber insulating mats etc.

Conclusion:

Use of 143Kw 98% HRR for Diesel Generator Building is reasonably realistic and bounding.

Service Water Building:

4 ft elevation (FC 378) NFPA 805 location: SW-O1B. All walk-downs documented a maximum of 12 lbs of cellulose material in this area and generally the material was mostly 5 lbs of cellulose material. This is consistent with bounded by Test #4 and #11 of Table G-7, which was 119Kw.

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Conclusion:

Use of 143Kw 98% HRR for 4 ft elevation of the Service Water Building is reasonably realistic and bounding.

-13 ft elevation (FC 379) NFPA 805 location: SW-01C. All walk-downs documented a maximum of 2 to 4 lbs of cellulose material in this area 30% of the time and generally the material no cellulose material was found. This is consistent with bounded by Test #4, and #11 of Table G-7, which was 119Kw.

Conclusion:

Use of 143Kw 98% HRR for -13 ft elevation of the Service Water Building is reasonably realistic and bounding.

20 ft elevation (FC 377) NFPA 805 location: SW-O1A. All walk-downs identified between 105 to 131 lbs of cellulose material in this area. Upon inspection of the material in this area this area has been undergoing concrete repairs for the past few years and the material is bags of grout and concrete aggregate and associated tools. Thus the actual burnable material is much less than the walk-downs would suggest and the material is spread out by the pumps suctions over a long narrow strip. Thus a lower HRR is a realistic assessment.

Conclusion:

A heat release rate of 143Kw is reasonably realistic and bounding for this elevation.

Control Building:

23 ft elevation, Cable Spread Rooms (FC 204, 205, 206, 207, 210, 211) NFPA 805 locations are: CB-O1A, CB-O1B, CB-02A, CB-02B, CB-05, and CB-06. All walk-downs documented no transient combustible material in this area. There was identified a portable ventilation fan on the FC 205. This fan is less than Shp and thus would screen out as a fire ignition source per EPRI 1011989/NUREG-CR-6850. In these areas there are designated locations where transient combustible are required to be stored. Procedural controls will be put in place to re-enforce this unless a specific evaluation is provided.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding, and the administrative controls will further re-enforce this.

23 ft elevation, Stairwell, elevator shaft (FC 208, 209, 216) NFPA 805 locations are: CB-03, CB-04, and CB-11. All walk-downs but one documents no transient combustible material in this area. The one on 6/15/10 identified 7 lbs of cellulose material in this area. This is consistent with a 2.5Kg material and would also be considered a HRR of 143Kw or less.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

23 ft elevation, Battery Rooms (FC 212, 213, 214, 215): NFPA 805 locations are: CB-07, CB-08, CB-09 and CB-10. All walk-downs documented no transient combustible material in this area. During Fire PRA Peer Review walk-downs a plastic bucket was identified in the battery rooms. These buckets do not qualify as BNP-220 Attachment 1 Page 4

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page7of 16 6of15 a transient combustible because they are filled with dry caustic power (baking soda), which is a fire suppressor and the hard plastic requires a high energy fire to start any combustion.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

49 ft elevation Control Building Cable access areas (FC 217, 218, 219, 220) NFPA 805 locations are: CB-21A, CB-12B, CB-13A, and CB-13B. All walk-downs documented no transient combustible material in this area.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

49 ft elevation Control Building Offices spaces (FC 221, 222, 223, 224, 225, 226, 229) NFPA 805 locations are: CB-14, CB-15, CB-16, CB-17, CB-18, CB-19, and CB-22. All walk-downs document transient combustibles in these areas. Computer rooms, AO office and briefing rooms (FC 223, 226, 221, 222) had the most with 135# to 190# of cellulose material in these areas. This material was procedure binders and other similar material and is not all in one burnable pile and thus is consistent with a 3-5 lbs groupings for a 119Kw HRR. The washrooms (FC 225, 229) similarly contained transient combustibles that could be significant. However these areas do not contain cable targets and thus high transient combustible HRR do not impact results. Many of these areas are also continuously manned and thus a lower HRR is more appropriate. Additionally per EPRI 1011989/NUREG-CR-6850 Table G-7 tests #5 and

1. 6 (Nowlen) very little of this type configuration burns giving a low HRR.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas is not reasonable and the 317Kw HRR should be applied to the areas where these transient combustibles are located.

Howeverthis area is continuously manned and no targets have been identified, thus no change is required. In the risk significant areas additional procedural controls will be put in place to ensure transient combustibles are not located in this area of potential targets and cable trays unless a specific evaluation is provided. Thus no further action is currently required.

49 ft elevation Control Building back panel areas (FC 227, 228) NFPA 805 locations are: CB-20 and CB-

21. All walk-downs document no transient combustible material in these areas.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

49 ft elevation Control Building Main Control Room area (FC 230): NFPA 805 location is: CD-23. Walk-downs identified approximately 82# of cellulose material in this area. This consist of binders of procedures which are not stacked together is an easily burnable configuration and thus do not change the conclusion that a 143Kw HRR is a reasonable estimate. Additionally per EPRI 1011989/NUREG-CR-6850 Table G-7 tests #5 and #6 (Nowlen) very little of this type configuration burns giving a low HRR.

These fire sources in the Main Control Room area are not risk significant transient combustibles based upon a number of factors:

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BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page8of 16 7of15

1. These sources are not transient in that they are maintained in a fixed location, thus the placement of these fire fuel package is not moveable to a different worse case location

2. There are not cable targets in the vicinity of the office desks, chairs, and bookshelves, toilet paper storage locker

3. The area where this material is located is continuously occupied and thus any fire would be immediately eliminated.

4. The configuration of the material is such that in order for this material to contribute to a fire HRR a damaging fire would have to already have been started by an additional fuel package of considerable size.

5. The material covers has a large amount of floor space and thus the HRR per square foot is less much smaller than if the same fuel package was stacked in a concentrated location.

Conclusion:

Use of 317Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding for a random fuel package located in the worse case location. However administrative controls will also be put on place to ensure transient combustible will not be located in risk significant locations without a specific evaluation.

70 ft elevation Control Building (FC 231,232, 233, 234, 235): NFPA 805 locations are: CB-24, CB-25, CB-26, CB-Roofl, and CB-Roof2. All but two walk-downs document no transient combustible material in these areas. The cellulose material identified in this area was of very small quantity <10# (4kg).

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

Electrical Pipe Tunnel (ET, FC 262): This area had a special review and tours in the area. During these tours no transient combustible material in this area was noted.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

Reactor Building Unit 1 -17 ft elevation (FC 267, 268, 269, 270, 294) NFPA 805 locations are: RB1-O1A, RB1-O1B, RB1-01C, RB1-O1D, and RBI-02: Walk-downs show small amount of cellulose material (5# in two instances) and small amount of trash (5-15#), this trash and cellulose are associated with contamination control measures (step off-pads, and associated clothing removal at the step off pad area). This is again lower combustible loading and a HRR of 135Kw is a reasonable estimate per EPRI 1011989/NUREG-CR-6850 Table G-7 NBS - Lee Clothing test.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

Reactor Building Unit 1 20 ft elevation (FC 271, 273, 274, 275, 276, 277, 278, 279, 292, 293, 297, 298, 299, 300) NFPA 805 locations are: RBI-O1E, RB1-O1F, RB1-O1G(EC), RB1-O1G(NC), RB1-O1G(NE), RB1-BNP-220 Attachment 1 Page 6

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page9of 16 8of15 O1G(NW), RB1-O1G(SC), RB1-O1G(SE), RB1-01G(SW), RBI-05, RB1-06, RBI-07. RB1-08, R31-010, and RB1-O1N: Walk-downs of these areas only those listed below identified combustible material of note.

• FC 273 (RBI-O1G (EC) Reactor Building 1 East Central): In this area in one instance there was identified <12# of cellulose material in this area. This amount is well within low HRR per EPRI 1011989/NUREG-CR-6850 Table G-7.

• FC 274 (RB1-OIG (NC) Reactor Building 1 North Central): In this area small amount of generic trash and dress out clothing is accumulated and periodically is allowed to accumulate. The quantity is small (<10#) and is consistent with a lower HRR per EPRI 1011989/NUREG-CR-6850 Table G-7 NBS - Lee Clothing test.

• FC 297 (RB1-5, HP Field office and Decon room): In this area there is approximately 130# of clothing in various lockers and cabinets in the changing room. As discussed this dress-out lockers, desks, chairs are in a fixed location supporting changing of clothes, as such a 317Kw HRR should apply to this specific location. Additionally as discussed earlier, the configuration of this material restricts the ability to be a initiating event fire source, in that a existing damaging fire would have to be in the close proximity of this material before these items would be involved with a fire. With these areas are constantly occupied by the Rad. Protection Technicians and no cables of interest this area. Thus no impact on the transient combustible analysis, and no further action.

• FC 298 (RB1-6, ECCS mini-tunnel): In this area there is some trash at times (about half the time) of a limited amount. (0# material to <30#). This would be consistent with an HRR of 143Kw for 98% of the time.

• None of the other areas in Reactor Building Unit 1 20 ft elevation has walk-downs identified transient combustibles worthy of note.

Conclusion:

For the area FC 297 and FC 273 the use of a 317Kw HRR applies, based upon observed material. Additional procedural controls will be put in place while at power to limit the transient combustibles in these areas unless a specific evaluation is performed. Thus the use of 143Kw 98% HRR for these NFPA 805 fire areas in RB1 20 ft elevation are reasonably realistic.

Reactor Building Unit 1 50 ft elevation (FC 280, 281, 282, 283, 284, 285, 286, 296) NFPA 805 locations are: RB1-O1H(EC), RB1-01H(NC), RB1-O1H(NE), RB1-O1H(NW), RB1-Q1H(SE), RB1-O1H(SW), RB1-O1H(WC),

and RBl-04: In these areas only two NFPA 805 locations were any significant amount of transient combustibles cellulose material and in only one instance (7/19/11 in RB1-1H (NW) and (WC)) was the material above the 143Kw HRR quantity. These locations require the use of 317Kw HRR unless procedural controls are put in place.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas in RB1 50 ft elevation will be applied with procedural controls in place while at power to limit the transient combustibles in these areas unless a specific evaluation is performed using a 317Kw HRR. Thus no further action required.

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BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 10 of 16 9of15 Reactor Building Unit 1 80 ft elevation (FC 287, 288, 289, 304, 305, 313, 314) NFPA 805 locations are:

RB1-011, RBI-01J, RBI-O1K, RB1-012, RB1-13, RB1-20, and RB1-21: In these areas some areas showed a consistent significant amount of combustibles, all others had little to none. In all cases there were no flammable liquids in the elevation ever identified. The results are detailed below:

0 RB1-13 (FC 305), this is the reactor building CRD repair room with transient combustibles consistent with that activity. There are no targets in this area of interest and the transient combustible loading has no impact on results and the 317Kw HRR would apply to this area.

• RB1-011 (FC 287), this is the RWCU access room and typically has significant transient combustible loading of cellulose material in this area and the 317Kw HRR would apply to this area.

a RBI-O1K (FC 289), this is the Reactor Building Unit 1 east the identified cellulose material is in relatively small amounts (<10#) and is such that the low HRR would be expected based upon the testing results described in EPRI 1011989/NUREG-CR-6850 Table G-7 results apply.

0 RB1-21 (FC 314), this is the resin storage room and the transient combustibles are the resin and associated containers and packaging. The amount of packaging is such that the low HRR would be expected based upon the testing results described in EPRI 1011989/NUREG-CR-6850 Table G-7.

Conclusion:

Use of 317Kw 98% HRR for these NFPA 805 fire areas in RB1 80 ft elevation are applied. Procedural controls will be place to limit the transient combustibles to less than the 143Kw HRR or a specific evaluation is performed. Thus no additional actions are required.

Reactor Building Unit 1 98 ft elevation (FC 310, 311, 312) NFPA 805 locations are: RB1-18, RB1-18GA, and RB1-19. On this elevation RB1-18 and RB1-19 consistently had significant high transient combustible loading as discussed below:

• RB1-18 (FC 310) is the Reactor Building Supply Room, no equipment or targets were located in this area, thus 317Kw HRR should be applied, as would be expected for a supply room, there is no impact and further analysis is not required.

• RB1-19 (FC 312) is the Reactor Building Changing Room and as expected contains significant burnable cellulose material in this area. However there also is not equipment or targets in this area of concern and thus although the transient HRR of 317Kw HRR should be applied there is no impact and no further action or analysis is required.

Reactor Building Unit 1 117 ft elevation (FC 291, 301, 303, 306, 308, 309) NFPA 805 locations are: RB1-01M, RB1-09, RB1-11, RB1-14, RB1-16, and RB1-17. The walk-downs indicate that only FC 291 (RB1-01M) has any transient combustible loading. This material is associated with RBl-O1M being the refueling floor and the material is either contamination prevention dress-out clothing or contaminated clothing at the step off pads to support spent fuel pool evolutions. This is a large open area with no targets and is in specific areas away for important plant equipment and thus no impact on this large transient.combustible loading in this area.

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BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Pagellof16 10of15 Conclusion is that although the NFPA 805 area has transient combustible loading could be significant and the 317Kw HRR applies, this is specific to a certain area for a specific purpose and is not a load that will be relocated to areas where damage to plant equipment could occur.

Administrative controls will be put in place to ensure risk significant targets cannot be damaged unless a specific evaluation is preformed. Thus no further action is required.

Reactor Building Unit 1 133 ft elevation (FC 307, 315) NFPA 805 locations are: RB1-14, and RB1-Roof.

Walk-down of these areas over the time period did not identify any significant transient combustibles in this area.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

Reactor Building Unit 2 -17 ft elevation (FC 316, 317, 318, 319) NFPA 805 locations are: RB2-O1A, RB2-01B, RB2-01C, and RB2-01D. The walk-downs only identified significant transient combustibles in RB2-O1C and RB2-O1D some of the time. The results are discussed below in detail.

• RB2-01C: This area typically has 25# of trash and 15# cellulose material, a few occasions up to 34#.

This material is associated with contamination control with dress-out material and step-off pads for exiting contaminated areas. This material is not all located together. Some of the trash is non-burnable such as discarded metal parts, grinding discs etc. This is a fuel package has a small HRR per square foot, in that the material is in three or four bins with a step-off pad covering approximately 25 square feet. Additionally, during the time this is established work is proceeding on a round the clock bases (short term LCO applies to the RHR system), thus the area is approximately continuously occupied.

Conclusion:

Use of procedural controls to limit transient HRR to 143Kw 98% HRR for these NFPA 805 fire areas will apply unless a specific evaluation is performed for this location using a 317Kw HRR.

• RB2-O1D: This area typically has 10# cellulose material and occasionally small quantities (less than I gallon) of lubricating oil in an approved fire resistant, spill resistant container.

This material is associated with contamination control with dress-out material and step-off pads for exiting contaminated areas. This material is not all located together. Some of the trash is non-burnable such as discarded metal parts, grinding discs etc. In interviews with operations personal it was noted that in these cases the material is not a random location, but is specifically located in the open area to allow easy entrance and egress from radiological controlled contaminated areas. This is a fuel package has a small HRR per square foot, in that the material is in three or four bins with a step-off pads covering approximately 25 square feet or more.

Additionally while the higher transient combustible area is established, work is proceeding on a BNP-220 Attachment 1 Page 9

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 12 of 16 11of 15 round the clock bases (short term LCO applies to the RHR system), thus the area is approximately continuously occupied.

Conclusion:

Use of procedural controls to limit transient HRR to 143Kw 98% HRR for these NFPA 805 fire areas will apply unless a specific evaluation is performed for this location using a 317Kw HRR.

Reactor Building Unit 2 20 ft elevation (FC 320, 321, 322, 323, 324, 325, 326, 327, 328, 341, 344, 347, 348, 349, 350, ) NFPA 805 locations are: RB2-O1E, RB2-O1F, RB2-O1G(EC), RB2-01G(NC), RB2-01G(NE),

RB2-O1G(NW), RB2-O1G(SC), RB2-01G(SE), RB2-01G(SW), RB2-O1N, RB2-02, RB2-05, RB2-06, RB2-07, and RB2-08: Walk-downs of these areas only those listed below identified combustible material of note.

• FC 322 (RB2-O1G (EC) Reactor Building 2 East Central): In this area in one instance there was identified <15# of cellulose material in this area.

" FC 323 (RB2-OIG (NC) Reactor Building 2 North Central): In this area small amount of generic trash and dress out clothing is accumulated and periodically is allowed to accumulate. The quantity is generally small (<10#*).. In one instance the amount of cellulose material was large (165#), this was all in multiple locker(s) with doors used to store for dress out material.

• FC 333 (RB2-OIG (SE) Reactor Building 2 South East): In this area there was occasionally a small amount of cellulose material (<10#). This would be consistent with an HRR of 143Kw for 98% of the time.

• FC 347 (RB2-5, HP Field office and Decon room): In this area there is approximately 180# of clothing in the dress out material is located in multiple lockers and cabinets in the changing room this is also similar to EPRI 1011989/NUREG-CR-6850 Table G-7 (Cline) test. This results in the application of the higher HRR of 317Kw for this area. However since there are no cables of interest this area and thus no impact on the transient combustible analysis, and no further action.

" FC 348 (RB2-6, ECCS mini-tunnel): In this area there is some trash at times (about half the time) of a limited amount. (0# material to <20#). This would be consistent with an HRR of 143Kw for 98% of the time.

" None of the other areas in Reactor Building Unit 1 20 ft elevation has walk-downs identified transient combustibles worthy of note.

Conclusion:

For the areas (FC 322, 323, 347 and 348) the 317Kw HRR applies in the other areas the use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

Use of procedural controls will be used to limit the transient combustibles unless a specific evaluation is performed using a 317Kw HRR for these areas.

Reactor Building 2 50 ft elevation (FC 329, 330, 331, 332, 333, 334, 335, 343, 346, 352) NFPA 805 locations are: RB2-O1H (EC), RB2-O1H (NC), RB2-01H (NE), RB2-O1H (NW), RB2-O1H (SE), RB2-O1H (SW),

RB2-O1H (WC), RB2-010, RB2-04, and RB2-10). There was very little in the way of burnable transient combustibles identified on this elevation. The specific location of those areas where burnable transient combustibles were found is:

BNP-220 Attachment 1 Page 10

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 13 of 16 12 of 15

• FC 333 (RB2-01H (SE) South East Corner) had 20# of cellulose material once noted on 7/7/10.

" FC 330 (RB2-O1H (NC) North Central) had 20# of cellulose material once noted on 1/24/11.

" FC 335 (RB2-O1H (WC) West Central) had 10# of trash and 20# of cellulose material once noted on 11/9/11.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas in RB2 50 ft elevation will be applied with procedural controls in place while at power to limit the transient combustibles in these areas unless a specific evaluation is performed using a 317Kw HRR. Thus no further action required.

Reactor Building 2 80 ft elevation (FC 336, 337, 338, 354, 355, 363, 364) NFPA 805 locations are: RB2-011, RB2-O1J, RB2-O1K, RB2-12, RB2-13, RB2-20, and RB2-21. On this elevation only four areas had identified burnable transient combustibles. The material was in locations designed and dedicated to the storage of this material and are detailed below:

• FC 349 (RB2-12 Control Rod Drive Repair Room), in this case there was consistently about 20# of cellulose material. This material is located in technical manuals and other similar configurations, which are not in a easy burnable configuration. Administrative controls will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

• FC 336 (RB2-011 RWCU Access Room), which had various amounts of cellulose material noted ranging from 20# to a high of 65#. In this case the material was to support dress out (clothing in lockers) and not typically of an open trash can full of burnable material. The amount of material means the 317Kw HRR would be applied. Administrative controls will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

• FC 363 (RB2-20 Resin Storage Room), which had small amount of cellulose material (3# to 10#)

and large quantities (190# to 280#) of resin material in storage.

" RB2-O1K (Reactor Building 2 80 elevation East), on one occasion (5/17/11) had significant amount of cellulose material (40#) and some trash (10#). This is typically dress out material (locker with dress out material and step off pad) to support maintenance activities in that area.

This is a fuel package has a small HRR per square foot, in that the material is in three or four bins with a step-off pads covering approximately 25 square feet or more. Administrative controls will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas in RB2 80 ft elevation will be applied with procedural controls in place while at power to limit the transient combustibles in these areas unless a specific evaluation is performed using a 317Kw HRR. Thus no further action required.

Page 11 Attachment 11 BNP-220 Attachment Page 11

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 14 of 16 13of 15 Reactor Building 2 98 ft elevation (FC 351, 360, 361, 362) NFPA 805 locations are: RB2-09, RB2-18, RB2-18GA, and RB2-19. In this case two areas had noted burnable transient combustible, both of which were set-up to handle the material. These two areas are discussed below:

• FC 360 (RB2-18, Reactor Building Supply Room) has significant transient combustibles as would be expected in a supply room thus in this location the 318Kw HRR would apply. Administrative controls will be put in place to limit the .H.RR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

• FC 362 (RB2-19, Reactor Building Clothing Change Room) also has significant transient combustible as would be expected in the main dress out changing area thus in this location the 318Kw HRR would apply. Administrative controls will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas in RB2 98 ft elevation will be applied with procedural controls in place while at power to limit the transient combustibles in these areas unless a specific evaluation is performed using a 317Kw HRR. Thus no further action required.

Reactor Building 2 117 ft elevation (FC 340, 353, 356, 358, 359) NFPA 805 locations are: RB2-O1M, RB2-11, RB2-14, RB2-16, and RB2-17. Of these areas only RB2-O1M (Reactor Building Refueling Floor) has any transient combustible noted. This was cellulose material to support refueling operations and contained in lockers designed for the material. At times during refueling/ fuel activities in progress there was also significant trash and thus does not apply to Fire PRAs for at power operations.

Conclusion:

Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

Reactor Building 2 133 ft elevation (FC 357) NFPA 805 location is: RB2-15. There were no transient combustibles noted in this area at any time.

Conclusion:

. Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic and bounding.

RadWaste Building -3 ft elevation (FC 367) NFPA 805 location is: RW-O1A. This area is the Rad Waste Tank Room. The transient combustibles identified are liquid cartons of processed oily waste (mixed liquid waste after processing 1 to 100 gallons). The material is stored in one location and no targets are in the area. The other transient combustible materials in this location are some cellulose material in multiple locations (25# to 45#) and some trash typically 40#. In this location a 317Kw HRR would be applicable. Administrative controls will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

Conclusion:

Use of the 317Kw 98% HRR is applicable for this area. Administrative controls will be put in place to limit the HRR of transient combustibles to 143Kw HRR unless a specific analysis using the 317Kw HRR is completed.

BNP-220 Attachment 1 Page 12

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 15 of 16 14 of 15 RadWaste Building 23 ft elevation (FC 368, 373) NFPA 805 locations are: RW-O1B, RWDL. This is the RadWaste Building CFD Area. This area has filters and resin storage in the area and the loading dock.

The transient combustibles associated with these items. This is also the area where processed oily waste is moved through to the loading dock outside of this area. The combustibles in this area are resin (up to 1761#), charcoal filters (192#), trash and cellulose material. In this location a 317Kw HRR would be applicable. Administrative controls will be put in place to limit the 143Kw HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

Conclusion:

Use of the 317Kw 98% HRR is applicable for this area, but no changes are required based upon the administrative controls that will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

Rad Waste Building 35 ft elevation (FC 369) NFPA 805 location is: RW-01C. This is the 35 ft elevation of the Rad Waste Processing Building. There are some smaller amounts of cellulose material on two occasions (6/15/10 (30#) and 7/7/10, (15#)) located in this area.

Conclusion:

Use of the 317Kw 98% HRR is applicable for this area, but no changes are required based upon the administrative controls will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

RadWaste Building 47 ft elevation (FC 370, 371, 372) NFPA 805 locations are: RW-O1D, RW-O1E, and RW-01F. In this area RW-O1D did consistently contain transient combustibles in larger amounts (55# of cellulose and 20# of trash). The 55# of cellulose exceeds the 143Kw HRR. In this location a 317Kw HRR would be applicable; however administrative controls will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

Conclusion:

Use of the 317Kw 98% HRR is applicable for this area, but no changes are required based upon the administrative controls will be put in place to limit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR is completed.

References:

1. EPRI 1011989/NUREG-CR-6850 Table G-7

2. OFPP-013 Transient Fire Load Evaluation, Completed 06/15/10

3. OFPP-013 Transient Fire Load Evaluation, Completed 07/7/10

4. OFPP-013 Transient Fire Load Evaluation, Completed 12/15/10

5. OFPP-013 Transient Fire Load Evaluation, Completed 01/24/11

6. OFPP-013 Transient Fire Load Evaluation, Completed 05/17/11

7. OFPP-013 Transient Fire Load Evaluation, Completed 07/19/11

8. OFPP-013 Transient Fire Load Evaluation, Completed 09/13/11

9. OFPP-013 Transient Fire Load Evaluation, Completed 10/12/11

10. OFPP-013 Transient Fire Load Evaluation, Completed 11/09/11

11. OFPP-013 Transient Fire Load Evaluation, Completed 11/28/11 BNP-220 Attachment 1 Page 13

BNP-PSA-086 Rev. 1 5 - Change Package BNP-220 Page 16 of 16 15 of 15

12. NUREG/CR-4680, Heat and Mass Release for Some Transient Fuel Source Fires: A Test Report, October 1986

13. NBSIR 88-3733, Cone Calorimeter Evaluation of Flammability of Composite Materials, March 1988

14. Operator interviews on 3/24/12

15. ASTM E-84, and use Polyester resins Class A, for fiberglass materials. The resin will be a flame retardant, promoted thixotropic polyester resin designed for use in hand lay-up and sprayup processes. This resin is specifically formulated for use in applications that require an ASTM E-84, Class I flame spread rating, without the use of fillers or antimony trioxide, with an ASTM E-84 flame spread rating of less than 25 unfilled and smoke density under 450.

16. FIR-NGGC-0009, NFPA 805 Transient Combustibles and Ignition Source Controls Program

17. 0-89-0001, Combustible Loading, Rev 5 Page 14 BNP-220 Attachment 11 BNP-220 Attachment Page 14