ML20106C790
| ML20106C790 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/22/1984 |
| From: | Jens W DETROIT EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| EF2-71994, NUDOCS 8410240300 | |
| Download: ML20106C790 (53) | |
Text
pr"
. , ~
1 F , troyne H. Joni
'- J V20 President -
',3- - Nuclear Operatons S
Fm%2 f~
6400 North Dine Hghway -
. Newport. uenigan 48tes - October 22, 1984 (313) s8s-41w EF2-71994 Mr.; Harold'Denton.
Director, Nuclear Reactor Regulation U. S. Nuclear. Regulatory Commission
. Washington, D. C. 20555
Dear Mr. Denton:
- Referen'ce s ' (1) Fermif2 NRC . Docket No. 50-341 (2)- Detroit 1 Edison' to NRC Letter, " Alternative Shutdown in_the Control Center. complex",
EF2-72718, August 16, 1984 (3)- Detroit Edison to NRC Letter, " Submittal of
~
Deviations from Staff Interpretations of-Fire Protection Features in 10CFR50,
-Appendix R and Justification," EF2-72717, August:3, 1984 (4) -Detroit Edison - to. NRC Region III - Letter,
" Detroit Edison. Response Inspection Report 341/84-16," EF2-70022, October 8,19 84 Subjects -Implementation of Alternative Shutdown
~
.at Fermi 2 During the review of The Detroit Edison Company's applica-
,z ' tion for an operating license for Fermi 2,.the NRC staff has
' insisted that certain modifications to the design would be
~
required.. A number of other concerns in the fire protection area were also identified-by the NRC staff during this-review.-~ Reference-(2) provided Edison's formal agreement to enhance its fire-protection design at Fermi 2 to address the staff's concerns by providing for.an alternative shut-down approach for the Control Center. Complex. The Company is also utilizing this commitment'to an enhanced design in other-areas as-identified in Attachment 1.
Edison believes that the existing design would satisfy the
/ requirements of General Design Criteria 3 of 10CFR Part~ 50, Appendix A and, therefore, would not, if operation were per-mitted, endanger. life or property. However, the Company has agreed to enhance the. design for' Fermi 2. This enhanced
. design represents a difficult and complex task to implement.
"- In a companion letter, the Company describes the approach it i- ) *p 4/
e \h
Mr. Harold Denton October 22, 1984 EF2-71994 Page 2 will use in implementing the Company's agreement with the NRC. Additional information pertinent to this request is also contained in Attachment 3 to this letter.
Therefore, pursuant.to the provisions of 10CFR 50.12, The Detroit Edison Company requests that the Commission grant Edison's request, that for a period not to exceed start-up after_the first fuel cycle, the existing design as tempo-rarily enhanced as described in Attachments 1 & 2 suf-ficiently meets the requirements of 10CFR Part 50, Appendix A, General Design Criteria 3 so as to not endanger life or property or the common defense or security and is otherwise in the public interest.
If-you should have any questions, please contact Mr. O. K.
Earle at (313) 586-4211.
Sincerely, cc: Mr. P. M. Byron /
Mr. B. J. Younglood U Mr. M.' D. Lynch Mr. R. Eberly Mr. R. C. Knop Mr. J. G. Keppler Mr. T. M. Novak USNRC, Document Control Desk-Washington, D.C. 20555
S ATTACHMENT 1 g-Analysis / Measures Showing Adequate Fire Protection Without The _ Alternate Shutdown Design
.1.0.-INTRODUCTION
-The: purpose of this' Attachment is to show that for each
. applicable . fire area listed in Table 1, an adequate level of fire protection exists'to meet.the underlying
. purpose of..the NRC regulations for fire protection for
~
(the intervening period of time until the alternate tahutdown' approach'is implemented.,tTo do.this, the permanent / installed fire' protection features ;are described'for each applicable' fire zone. Analysis is then used to show that for limited fires (discussed in Attachment 2) in the fire area that:
o The integrity of the fission product boundary
, is maintained including fuel clad, primary coolant, and containment.
' Reactor. coolant. process variables a~e main-
~
o tained within those predicted for.a loss of normal AC' power.
o- Safe hot and/or cold shutdown is attained and maintained.
In addition to analysis, certain further temporary measures are provided in some areas to provide added assurance in the intervening period of time that an adequate level _of fire protection exists.
.The general methodology employed in the analysis is
' described in Section-2.0 below. The methodology is implemented on each applicable fire zone listed in Attachment 1-and the results are presented in the
~
attached pages. The detailed analysis supporting.the methodology and results are controlled and available for tutC review. The= methodology used as a starting point the~previously-generated Safe Shutdown Analysis.
This analysis is used to define the circuits which need protection.at Fermi 2 due to required fire protection separation requirements for redundant and associated circuits and spurious operation. The analysis will be maintained' current.
For the fire. areas listed in Table 1, the descriptions in Section 3.0 provide the current fire protection analysis and supercedes'those applicable Sections in FSAR Section 9B. FSAR Section 9B will be amended in a
- i
m V
-G forthcoming' Amendment to the FSAR.to reflect theIfinal plant fire protection design including the Alternative Shutdown approach.
2.0 GENERAL ANALYSIS METHODOLOGY 2.1 .The fire. zones in which the' alternate / dedicated shutdown-approach will be used for accomplishing plant. shutdown.are identified in Table 1.
-2.2 -For'each of the fire zones identified in Table 1,1an analysis has been performed to show that for limited fires, safe shutdown of the plant is~ achieved. The following steps were performed-in each fire zone.
2.2.1 For the fire zone, the major division of equipment and-raceways'was identified.
.The opposite division would then be used for plant shutdown. 'The raceways
~ (conduits and cable trays).which are routed-in this fire zone were then listed for-this shutdown division. The plant systems were.also identified for the circuits which were routed in each raceway.
2.2.2 Each raceway was then reviewed to ,
determine.if it was configured as follows:
- 1. Raceway wrapped completely with one hour protective envelope. -
- 2. Raceway is separated from the redundant safe shutdown division by greater than 20 feet.
- 3. Raceway contains circuits which are '
not required to shutdown the plant for a fire in this area.
For these raceways no further action was required other than disposition in the analysis. :
2.2.3 For raceways which do not meet the criteria in step 2.2.2, the wrap status for each raceway was obtained from field walkdown information. The wrap status information provides the amount of 3-M ,
protective material which has been installed ~on a particular raceway. The L
percentage and number of layers of wrap was listed for each of these raceways.
?
~~$ -e & gm g- e =i wi =9-7w, y's 9 pi, -- er-twe-gev W 9 **
ex. s m my+p-r-gme w r *q ,9ym-~ w=P p me w9-447'igi- ps idie- gw - y w+*=mpM---=9eyyT rr9-y'-'*tv.yepy g,p, c 9 ~mmiype g e-y v,9 M e
e 9
~
2.2.4 -For those raceways which did not have any wrap installed, a review of the circuits in the raceway was performed.
For those circuits where operator manual actions can be accomplished outside of the fire zone identified, a procedure outline is provided to achieve the required shutdown functions for the raceway.
2.2.5 For those remaining raceways, if any, the separation ~ distance was identified to the closest redundant safe shutdown component or raceway. Raceways and components of the opposite division were evaluated for their redundancy to the unprotected raceway.
2.3 A summary of the fire protection features present in the fire zone and the present condition of the raceways is_then provided for each of the fire l zones.
3.0 FIRE PROTECTION ANALYSIS WITHOUT ALTERNATIVE SHUTDOWN The attached pages provide the subject analysis for the applicable fire zones listed in Table 1 in the following format:
- 1. Description - a description is provided of the zone, its current fire protection features and pertinent characteristics, and the important equipment which is located in the room.
- 2. Analysis - a discussion is provided of the results of the analysis performed as described in Section 2 based on the current configuration of the room.
- 3. Additional Features - a discussion is provided of additional temporary provisions which are provided in the interim before full implementation of the Alternative Shutdown approach.
- 4. Conclusion - a concluding statement is provided demonstrating that the underlying purposes of the fire protection regulations are met for the zone for the intervening period until the Alternate Shutdown approach is implemented.
I
I l TABLE 1
' Fire Areas Taking Credit for Alternate Shutdown Approach Fire
- Area Location Elev.
l' Aux. Bldg. Basement 551'-0" & 562' 0" 2 Aux. Bldg. Mezzanine 603'-6" & 583' 6" 3 -Aux. Bldg. Relay Room 613'-6" 7 Aux. Bldg. Cable Spreading Rm 630'-6" 8 Aux. Bldg. Cable Tray Area 631'-0" 9 -Aux. Bldg. Control Room 643'-6" 11 Aux.. Bldg. 3rd Fir.- 643'-6" 13 Aux. Bldg. 4th Fir. 659'-6"
y; FIRE ZONE 1 Basement Auxiliary Building . ,
Elevations: . 551'-0" and 562'-0" 1' .0- DESCRIPTION
- The following is a summary ' description of this fire zone. This summary includes the design combustible loading, fire protection features available and fire resistance rating of the zone. This section supplements the information provided in FSAR section 9B.4.2.
' NOTE: FSAR'section 9B.4.2_ states wrap will be used to protect redundant trains. .This-document takes into account the fact that wrap activites have been stopped in these areas and the wrap remains
-in a partially complete state.
Combustibles Lubricating Oil 1,520,000 BTU Dessicant 3,890,000 BTU Electrical Insulationl 438,000,000 BTU 444,000,000 BTU Design Basis Fire Fire Loading l 80,000- KrU/sq. ft.
-Fi're Protection (Available)
Suppression: AutomaticLsprinklers/ zone' wide Detection: , Ionization / zone wide (carly warning)
Portable Extinguishers: (2) Dry chemical Hose Stations: (2) Water Fire Resistance Rating
'- Required: 1.0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> Actual: Walls - 3-hour rated Floor / Ceiling - 3-hour rated Fixed Openings - none Sealed Penetrations -
3-hcur rated h
i ,.
Unsealed-
- Penetrations -
none A/ Zone 3 (RB)
- Doors -
A/ Zone 2 (RB)
- NOTE: .. '1. : Based on tirays being 100% visual full. Presently, average trayloading would 'be less than 20%. (Estimated fire Joading of 20,000 BTU /fr 2)- ,
b 4
O d
P v- *.v,, -
p y,, e- v.-w, .g +w-- .-g-w,,- ~.w,y v,me-- n~4,,e -u ,r--,.wne-,,ny-- -,----.w,,,g,+,r.,,eamm--m-- --
-e v a ,. m,v -
The 'following lists all those Appendix R systems that have some
- equipment or circuits located in the fire zone. Ar. 'X' opposite a system indicates th, presence of those divisional components / cabling in' the fire zone.
NOTE: Not all these systems are required for safe shutdown. There are different paths available that the operating procedures utilize
-to acccmplish plant shutdown.
-FIRE ZONE: :1 SYSTEMS DIVISION I DIVISION II Hot Shutdown Only
' E51-RCIC X E41-HPCI X ,
E21-CS X B21-ADS X Ell-RHR X X Cold Shutdown Only Ell-RHR X X B31-Roc ire .
' Hot'and Cold Shutdown
+
B21-MSIV's
.B21-Instrumentation X Ell-RHR SW X Ell-RHR Cooling Towers X
-P44-EECW X.
P45-EESW X R14-ESF AC X R16-ESF AC X X R30-ESF AC X X R32-ESF DC X T41-ESF Fan Coil HVAC X X T41-Control Center HVAC
! T50-Suppression Pool Instr. X X P50-Control Air X X X41-E.D.G. HVAC X R31-ESF AC REFERENCE DRAWINGS: 6E721-2800-15 6E721-2800-16
- r. .
2.0 ANALYSIS Within this predominately Division I area there is Division II circuits and equipment located in the fire zone. The Division II raceways fall into one of the following categories:
- 1) raceways containing circuits that are not required for shutdown.
- 2) raceways that are separated by twenty or more feet from Division I raceways and equipment.
- 3) raceways that are wrapped with oae hour fire barrier.
- 4) raceways that are wrapped with the 3-M material but do not achieve a full one hour rating.
Of those raceways which do not fall into any of the above categories are raceways and equipment for the Control Air System. Although not a short term need, control air is required for Control Center HVAC. If both divisions of the Control Air Systems were lost due to the fire in the zone, the following procedure will be implemented:
On detection of a fire in this fire zone operator actions would be accomplished to restore Control Air to the plant by connecting the Division II Non-Interruptible Air Supply (NIAS) system to the Interruptible Air Supply (IAS) system which will be supplied by Station Air Compressors as follows:
- 1. . Operator will go to the IAS Receiver P5002A003 location in the Turbine Bldg. Elev. 583'6" and manually open bypass manual valve V23-2016. (6M721-4795 ) .
- 2. When fire zone 1 is accessible, operator will go to the fire zone and open manual bypass manual valve V5-2208 (6M721 -4615 ) at the South Control Air Receiver. (Div II)
P5002A002.
- 3. When offsite power is restored (72 hrs), the station Air compressors will be started and will supply air to Division II NIAS. This action will restore Control Center HVAC by restoring control air to the dampers. Without Control Center HVAC, the ambient temperature could rise to 120*F in 4.3 days. (Ref. FSAR Section 9.4.1.3). However , this temperature would not be obtained due to reactivation of the system at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
3.0 ADDITIONAL FEATURES In addition to the features presented in section 1.0 and the procedure in section 2.0, the Detroit Edison Company commits to having a roving u
p fire watch for this fire zone. A roving fire watch will be established who will on an hourly basis check for and report on if necessary:
o Fire hazards o Evidence of fire o Availability of extinguishers.
o Any unsafe practices
4.0 CONCLUSION
The fire protection features for the area are designed to ensure that one train of equipment necessary to achieve and maintain hot shutdown is' unaffected by a fire in'this area. Under the definitions of a limited fire we meet this goal by having fire protection wrap or separation for all necessary system consistent with the size of the fire.
Hot shutdown and cold shutdown can ce achieved and maintained for a limited fire condition.
E -
FIRE ZONE 2 Mezzanine and Cable Tray Area Auxiliary Building Elevations: 583'-6" and 603'-6" 1.0 . DESCRIPTION The following is a summary description of this fire zone. This summary includes the design combustible loading, fire protection features available and fire resistance rating of the zone. This section supplements the information provided in FSAR section 9B.4.2.
NOTE: FSAR section 9B.4.2 states wrap will be used to protect redundant trains. This document takes into account the fact that wrap activities have been stopped in these areas and the wrap remains in a partially complete state.
Combustibles Electrical Insulation 1 424,000,000 BTU Design Basis Fire Fire Loadingl 71,000 BTU /sq . ft.
Fire Protection (Available)
Suppression: Automatic sprinklers / zone wide Detection: Ionization / zone wide (early warning)
Portable Extinguishers: (2) Dry chemical Hose Stations: (1) Water (2) Water / Turbine Building Fire Resistance Rating Required: 1.0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> Actual: Walls - 3-hour rated / north, south, east and west exterior / north and south Floor / Ceiling - 3-hour rated ceiling Fixed Openings - Concrete hatch / Zone 3 (Reactor Building)
Sealed Penetrations -
3-hour rated Unsealed Penetrations -
none
Doors -
A/ Zone 3 (AB)
(2) A/TB NR/Outside Note: Estimated actual fire loading is 35,000 BTU /sq. ft., based on trays being 50% full.
L _ __ _ _ ___ __ __ __ _ _ _ _ _ -- __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _
s .,,
, ( .-
' The following l lists all those Appendix R systems that have some equipment or circul_ts located in the fire zone. An "X" opposite a system indicates'the presence of those divisional components / cabling
.in'the fire zone.
. Note: .Not all these systems are required for safe shutdown. There are different paths available that the operating procedures utilize to accomplish plant shutdown.
FIRE-ZONE: 2 NORTH AREA
. SYSTEMS DIVISION I DIVISION II Hot Shutdown Only E51-RCIC. X E41-HPCI X -.
E21-CS- X B21-ADS X Ell-RHR X X
' Cold Shutdown.Only Ell-RRR X X 531-Rec ire .
Hot and Cold Shutdown B21-MSIV's X X B21-Instrumentation X X
. Ell-RHR SW X -X L Ell-RHR Cooling Towers X X P44-EECW X X P45-EESW .X X' R14-ESF AC X X R16-ESF AC X R30-ESF AC X X y R32-ESF DC. X X
-.T41-ESF Fan Coil HVAC X X T41-Control Center HVAC X X T50-Suppresalon Pool Instr. X X P50-Control' Air X. X
_X41-E.D.C. HVAC X X R31-ESF AC l
REFERENCE DRAWINGS: 6E721-2801-15 o
f
)
FIRE ZONE: 2 SOUTH AREA SYSTEMS DIVISION I DIiTISION II l
l LHot Shutdown Only E51-RCIC . X
-E41-HPCI X
-E21,CS:
B21-ADS
' Ell-RHR X X Cold Shutdown Only Ell-RHR X X B31-Rec irc .
Hot and Cold Shutdown B21-MSIV's X B21-Instrumentation X
~ Ell-RHR SW X X Ell-RHR~ Cooling Towers X X P44-EECW X P45-EESW X X R14-ESF AC X X R16-ESF AC X X R30-ESF AC X X R32-ESF DC X X T41-ESF Fan Coil HVAC X T41-Control Center HVAC T50-Suppression Pool Instr.
'P50-Control Air X X41-E.D.G. HVAC X X R31-ESF AC REFERENCE DRAWINGS: 6E721-2801-16 i
M-.. .
4 3
? , i * ~ .I ' - -
, , . W s (i 2.0 ANALYSIS' n . , (
[ =m i North'.HaIf'of Zone 3 u -n- .
,th. 'The north half ofIthe fire tone is a major Division 1 area.
~
Division
. IIJraceways have one of the .following fire protection features.
.yc w Raceways which are wrapped with a one hour protective . envelope.
4 1)-
~
2)' (Raceways which are separated by more than.20 feet from Division 1 raceways.
' ~
- 23) : Raceways which are' wrapped with the 3M material but do not achieve a' full one-hour rating.
E 1 Of those raceways not falling into the above category the following was identified; loss of instrument trays. 2K-029 and 1K-029 would lead to' loss of EECW and loss of reactor pressure indication. The
-following procedure would provide.a means to maintain EECW and to monitor reactor pressure'under.these' circumstances:
'On detection of a fire in;the north halfoof this fire-zone, the
.following operator actions would be required:
1.' Operator .will. go to Instrument Rack H21-P005 Reactor Bldg.
2nd floor E1.~613'-6" and monitor reactor vessel pressure on instrument B21-R004 B (6M721-2090).'
- 2. l Operator will go to EECW Temperature Control Valve P44-F400B -
(V15-2040 ) located in Reactor Bldg. 2nd floor E1. 613' and adjust valve regulator to bleed off . supply air and cause the
~
valve to go full open. '6M721-5444.
South Half of ' Zone
.The south half of the fire zone is a Major Division II area. Division-
- - 'I. raceways have one of the following fire protection features:
1)' Raceways whichiare wrapped with~a one hour protective' envelope.
- 2) Raceways'which are wrapped with the material but do not achieve a full one-hour. rating.
23.0l. ADDITIONAL FEATURES.
! y; Detroit ~ Edison has- installed additional fire stops described below. .
'In addition to the features : presented in section 1.0 and the procedure (outline.in section 2.0, the Detroit Edison' Company' commits to having a g : roving l fire watch for this-fire zone.
>c I ~
,. /
, 7
'I ?
e j'- gl n ;:' s 1
- o 4: r
- v. . _
., 5 .k .
A roving 1 fire watch will-be established who will on an hourly basis check for and report on if necessary:
- o -Fire hazards o Evidence of fire o- Availability of extinguishers
-o Any unsafe practices In a'ddition. the following modifications have been installed in the trays at Lapproximately column line(s). (See Attachment Sketch).
For trays:
Tray ID# FBL OC-617 Break installed approx. 4 feet west of column at Gg.
618 Break installed approx. 4 feet west of column at Gg.
OC-611 Break installed approx. 4 feet west of column at Gg.
OC-614 Break installed approx. 4 feet west of column at Gg.
OC-582 Break installed on east side of column at Gg.
OC-585 Break installed on east side of dolumn at Gg.
OC-640 Break installed approx. 3 feet west of Gg.
OC-636- Break installed approx. 3 feet south of cable _ chase edge.
OC-914 Break installed approx. 3 feet south of cable chase edge.
OC-570 Break installed approx. 3 feet south of cable chase edge.
OC-645 Break installed approx. 3 feet south of cable chase edge.
OC-592 Break installed approx. at column Line 15.
'These breaks in combination with automatic sprinklers will prevent the pro-pagation of fire.
T~- ,
~4.0: CONCLUSION
-.The - fire protection ' feature for the area are designed to ensure that one
~
train of equipment equipment necesary to achieve and maintain hot shutdown
~is unaffected by a fire in this area. Under the definition of,a limited fire we meet this goal by-having fire protection wrap or separation for all necessary system consistent with the . size of the fire.
Hot-shutdown and cold shutdown can be achieved and maintained for a limited fire condition.
{-.
@ @ i .
$ r ,
_ _v v p , g i e i
, usw e y
i i 3 55555555EE51 El REEE
_ _ _ _" E_ Il lEEEEERIE C ,,,,,, ,
f is%lM;m d25
~
- II E I
s,0c.gus
& ql f Yh . 805 5'N-It$L 4 % L 60t a*
L U
""Y h -
y-i ri g g , = 3 fr g ;
\\ r jffMEtW4
- M 295:10% H5att EL60to W I f @j # BB i N g
c g. 5 W i -
"l l _ _
k _ _
g f DC 09' $
oc t35- 4 x
)
V'$tNs[ rd &
l f? sir ** I f '
wa6h - wa, i i EL GOS'4~
8
$& $$$a E3eAttBEAK
$10N bt' G e
I i
i
\ L
-c.,
I, i
I Sketch of Additional Fire Breaks Installed in Fire Zone 2 -
Auxilliary Building
t.-
FIRE ZONE 3 Relay Room Auxiliary Building f
Elevations: 613'-6" d
1.0 DESCRIPTION
f
.Tha-following is_a summary description of this fire zone This summarycincludes.the design combustible loading, fire protection
- . features available and fire resistance rating of the zone. This 1section supplements the information provided in FSAR section 9B.4.2.
NOTE: FSAR section 9B.4.2 states wrap will be used to protect redundant trains. This document takes into account the factLthat wrap E activities have been stopped in these areas and the wrap remains in a partially complete state.
Comb'ustibles Electrical insulation 1* 226,600,000 Wiring insulation -(racks cabinets ) 157,000,000 383,600,000 BTU
- Design Basis Fire Fire Loadingl 83,000 BTU /sq. ft.
Fire Protection (Available)
A
-Suppression: Halon/ zone wide Detection: ' Ionization / zone wide-(early warning)
Portable. Extinguishers: (1) Dry chemical (2) CO2 (2) Halon Hose Stations: -(1) CO2-(3) Water--
Fire-Resistance Ra' ting
- 1 Required: 1.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> Actual: Walls - 3-hour rated / east, south, and west walls Non-rated / exterior north wall I2-hour rated / northeast stairwell 3-hour rated / stairwell to 603'-6" mezzanine Floor / Ceiling '- 3-hour rated
o
~
1 Fixed Openings - ' none Sealed
__ Penetrations -
3-hour rated Unsealed
, . Penetrations -
= none Doors- -
l'A/ Corridor to miscellaneous rooms (Zone 6) 1 B/ northeast stairwell 1 A/ stairwell to 603'-6" mezzanine (Zone 2)
NOTE: 1. - Based on trays being 100% visual. Presently estimated tray fill 1 si approximately 45% which equates to 56,000 Btu /f t2, Additionally, there is a significant amount of cabling which has been fire wrapped, which effectively reduces the con-bustible loading of the zone..
A s- r e n ,v,---,e rm,- -m sm--g-,..-,-n-ven,-- r~, ,r--- , ,----y e ,. - -- -r.-,,ew-,-e-- --rro.-- --v~,g~ - - -
S The following lists all those Appendix R systems that . have some equipment or circuits located in the fire zone. An 'X' opposite a
. system: indicates the presence of those divisional components / cabling in the fire zone.
- NOTE: Not all these systems are required for safe _ shutdown. There are
'different paths available that the operating procedures utilize to accomplish P? e shutdown.
FIRE ZONE: 3 SYSTEMS DIVISION I DIVISION II Hot. Shutdown Only E51-RCIC X E41-HPCI X E21-CS X X E21-ADS X X Ell-RHR X X Cold Shutdown Only Ell-RHR X X B31-Rec ir e . X X Hot and-Cold Shutdown B21-MSIV's X X B21-Instrumentation X X Ell-RHR SW X X Ell-RHR Cooling Towers X X P44-EECW X X P45-EESW X X R14-ESF AC X X R16-ESF' AC X X R30-ESF AC X X R32-ESF DC X X T41-ESF' Fan Coil HVAC -X X T41-Control' Center HVAC X X T50-Suppression Pool Instr. X X P50-Control Air X X X41-E.D.G. HVAC X X R31-ESF AC' X X REFERENCE DRAWINGS: 6E721-2800-15 6E721-2800-16
7 ,,
d '
l2.0 ANALYSIS
!This fire zone has no major. division; but is segregated such that the
- northern part of the room' is mostly Div. I while the southern part is
.. mos tly l Div.- II. The raceways fall into one of the following categories:
- 1)_ LWithin the northern.(Div.'I) area the Division II raceways routed
. within 10 ' feet and north of 13.1 column line are wrapped with a one hour protective ~ envelope.
~
- c- , ~2) "Within' the southern- (Div. 'II) area the Division I raceways routed within 10' feet and south -of column line 13.1 are either:
a) ' wrapped.with'a'one hour' fire barrier or b) Lwrapped with' the 3-M material but do not achieve a full one hour rating :
- 3) Raceways containing - circuits which are not required for shutdown.
-4) ' Division I andLDivision II panels are physically separated by at least 20 feet. A Relay . Room layout sketch showing the Appendix R Jrequired panels is attached.
.The fire wrap and separation discussed above provide adequate protection for a limited fire.
/3.0 ' ADDITIONAL FEATURES ~
In. addition to - the features presented in section' 1.0, the Detroit Edison Company commits to having a continuous fire watch for this fire
- soce.
A fire watch'will be established who will check for and report on if necessary:
o ' Fire hazards-
'o Evidence of' fire o' Availability of extinguishers o Any ~ unsafe ' practices t
! 4'.0 J CONCLUSION F
! The firec protection features for the area are designed to ensure that one' train of equipment necessary to achieve and maintain hot shutdown is unaf fected by a. fire in this area. Under the definitions of a
. limited fire _we meet'this goal by having fire protection wrap or
~
~
< separation for all necessary system consistent with the size of the fire.
r Hot shutdown and cold shutdown can be achieved and maintained for a limited fire condition.
i
o.. .
- %8-.ti" .%8 t3'l 6- ' 9 . ,9'
~,etu.9] ;358' ~ %,33 ] l ~. _
i-- ._. ~~] , -
u.. 1 , - ,
i 1 8e i
l a $
- ~ ~
i nl : _ _ as y al _ -]
I" -
r - . ;
4 -
- f"lMI 3 "g y ]
'j E -- '- E 1g g ,
l l h E
l
=
I E 5
~
il .t -
M M
!1
- g .
G ;. y w 33
< -a . , _.* a o a
- 2=
f .-. f s ~3 2 S .
E g
d h ! ,E 5 ~~
~~
I ! _ #~Ch .S~I!E l 3 iE E! Tj C --
~g .p',b} fSD D4 G
) (
4$
t - -
H
~.e .4 ' a.S ~.e- A 'J-K 'A .S '
.L*K
? 55 ~.a.,1 ' #J _
8 5-s,
- 2 -
l t i _ 34 ~
Ik 5 - - . E 2 __
g -,
-
- 3 l . . -
s
' ~
4 -
- I -
<s e*
~ -
- lj 5 -.
Ei 3 e:
f L
' il -
- t i;,p.
m
! g 2-M*
l -
1
it ,
t
/ ~
FIRE ZONE 7 Cable Spreading-Room - Auxiliary' Building Elevation: :630'-6"
. 1.0 ' DESCRIPTION
- The following in a summary description of this fire zone. This summary includes the -design combustible loading,- fire protection
' features 'available and fire resistance rating of the zone. This
.section supplements the information provided in FSAR section 9B.4.2.
NOTE: FSAR section 9B.4.2 states wrap will be used to protect redundant trains. This document takes into account the fact.that wrap activities have been stopped in these areas and the wrap remains in~a partially complete' state.
' Combustibles t . Electrical Insulationl' 318,000,000 BTU Design Basis Fire Fire Loadingl 67,000 NIU/sq. ft.
Fire Protection (Available)
Suppression: Halon/ zone wide Manual fusible link sprinkler system
- Detection
- Ionization / zone wide (early warning)
', Ionization / zone wide (halon system actuation)
Portable Extinguishers: (2) Dry chemical (1) CO2.
Hose Stations: (1) Water Fire Resistance. Rating 1 Required: 1.0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br />
. Actual: Walls -- 3-hour rated Non-rated / exterior north wall 2-hour rated / northeast stairwell Floor / Ceiling -
3-hour rated
' Fixed Openings --- none Sealed
. Penetrations -
3-hour rated
Unsealed
- Penetrations -
none-Doors -
1 A/below stairwell to control room (zone 9)
~1 B/ northeast stairwell
.1 A/ stairwell to control room (zone 9)
. Note: : 1. . Based on crays being 100% . visual full. . Presently, average tray loading would be less- than 50%. (Estimated fire
. loading of 30,000 BTU /ft2). Additionally,.there is a signi -
ficant amount of cabling which has been fire wrapped, which effectively reduces ~ the combustible loading of the zone, w.
o 2 v
l
. The following'. lists 'a11 ' those Appendix R systems that have some
~
equipment or circuits located in the fire zone. An 'X' opposite a
' system" indicates the-presence of those divisional components / cabling in' the fire, zone.
JNOTE: Not all these systems are required for safe shutdown. There are
- different. paths available 'that the operating procedures utilize to accomplish plant shutdown..
FIRE ZONE: 7-SYSTEMS DIVISION I- DIVISION II
-Hot Shutdown Only E51-RCIC X E41-HPCI- X
~E21-CS X X B21-ADS X X
- Ell-RHR X X Cold Sh'utdown Only- -
. Ell-RHR ' X X
~ B31-Recire. X X Hot.and Cold' Shutdown
.B21-MSIV's X X B21-Instrumentation X- X Ell-RHR SW X X-
- Ell-RHR Cooling Towers ^ X: X P44-EECW X X P45-EESW X X R14-ESF AC X X
'R16-ESF AC X X R30-ESF AC X X R32-ESF DC X X
'T41-ESF Fan Coil HVAC X X T41-Control Center HVAC X X
-T50-Suppression Pool Instr. .X X
' ~
P50-Control Air X X X41-E.D.G. HVAC X X R31-ESF AC X X 4
4
REFERENCE:
DRAWINCS: . 6E721-2802-15
- 6E721-2802-16 6E721-2802-17 L 6E721-2802-18 i
L _ ._. _ . _ . . . . _ _ _ _ _ _ ._ _ _ . _ _. . _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _
- p. ,
y.. 2.0(ANALYSIS
'Pg Within this predominantly Div. I area there are Div. II circuits.
These circuits are in raceways that fall into one of the following
' categories:
1)_ Raceways which are wrapped with a one-hour fire barrier.
2)I Raceways that are separated by twenty or more feet from Division I unwrapped raceways.
- 3 )' Raceways containing circuits that are not required for shutdown.
- 4) Raceways that are wrapped with the 3-M material but do not
~
-achieve a full one-hour rating.
5)_ In a few cases there are raceways which have a separation of less than 20 feet from redundant Division I raceways, (Closest dis-tance 4 feet) but these raceways have metal tray covers. These tray covers provide additional separation in the form of a barrier and radiant heat shleid.-
3.0 ADDITIONAL FEATURES LIn addition to.the features presented in section 1.0 and 2.0, the Detroit Edison Company commits to having a roving fire watch for this fire zone who will cm an hourly basis check for and report on if necessary:
o' Fire hazards o Evidence of fire
- o. Availability of extinguishers o Any unsafe practices
4.0 CONCLUSION
The fire protection features for the area are designed to ensure that one train of equipment necessary to achieve and maintain hot shutdown is unaffected by a ' fire in this area. .Under the definitions of a limited fire we meet this goal by having fire protection wrap, separation, or metal tray covers for all necessary, system consistent a with ' the size of ' the fire.
Hot i shutdown and cold shutdown can be achieved and maintained for a ilmited fire condition.
h
? .
i-FIRE' ZONE 8 r .
Cable Tray Area Auxiliary Building Elevation: 631'-0"
- 1. 0 ' DESCRIPTION The following is ,a . summary description of this fire' sone. This summary includes ~the design combustible loading, fire protection features available and . fire resistance rating 'of the zone. This
- section supplements the;information provided in FSAR section 95.4.2.
NOTE: FSAR section.98.', 2 states wrap will be used to protect. redundant trains this Ldocument takes into, account the fact that wrap activities have been stopped in these areas and the wrap remains in a partially complete state.
Combustibles
' Electrical Insulationl ' 117,000,000 FrU Desian' Basis Fire Fire Loading I 24,000 KrU/sq . f t .
_ Fire Protection (Available)~ l Suppression: Automatic carbon dioxide system / sone wide Detection: ' Ionization / sone wide (early warning)
Ionization / sone wide (carbon dioxide system actuation)
Portable' Extinguishers: (1) CO2 (1) Drywell chemical ,
Hose Stations: (1) Wateri
' Fire Resistance Rating-Required: .50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> Act* al: Walls - exterior / south wall
- 3-hour rated / north, west, and east 2-hour rated / stairwell enclosure Floor /Cel'1 Lng -
.3-hour rated Fired Openings - none Scaled Penetrations -
3-hour rated ,
.w2'-
- Unsealed
... Penetrations -
none Doors -
B/ stairwell NOTE: - 1. Based on trays being 100% visual full. Presently estimated tray fill:is approximately 55% which equates to 13,000 BTU /ft2, l
k
--w- _ - _ _ _ .__ ___-___.m_ _ _ _ _ . _ _ _ . _ . _ _ _ _ . _ _ _ _ _ . - - . _ _ _ _ . _ _ _ . _ _ _ . _ _ - _ _ . _ _ _ _ . . _ . . _ _ . _ _ _ _ _ _____...___.._____..-_.__.__.____.-...m __.,
y 4
. The following lists all those Appendix R systems that have some equipment or circuits located-in the fire zone. - An 'X' opposite a system indicates the. presence of those divisional component s/ cabling in the fire zone.
Note: Not all these systems are. required for safe shutdown. There Lare dif ferent paths available that the operating procedures utilize to -
accomplish. plant' shutdown.
FIRE ZONE: 8=
. SYSTEMS DIVISION I DIVISION II Hot Shutdown Only E51-RCIC X E41-HPCI X E21-CS X B21-ADS X X Ell-RHR X Cold Shutdown Only Ell-RHR X 531-Rec ire . X Hot and Cold Shutdown B21-MSIV's B21-Instrumentation X X Ell-RHR SW X X Ell-RHR Cooling Towers X X P44-EECW X P45-EESW X R14-ESF AC X X R16-ESF AC X X R30-ESF AC X R32-ESF DC X X T41-ESF Fan Coll HVAC X X T41-Control Center HVAC X X
'T50-Suppression Pool Instr.
P50-Control Air X X41-E.D.C. HVAC X- X R31-ESF AC REFERENCE DRAWINCS: 6E721-2802-19
2.0 ANALYSIS Within the predominately Div II area there are some Div I cables. the cabling is in raceways that fall into one of the following categories:
t 1). raceways that contain circuits not required for shutdown.
2)- raceways that are separated by- twenty feet or more distance from Div II raceways.
- 3) conduit which is wrapped with a one hour protective envelope.
- 4) one cable tray that has 13 feet of separation from a Div II raceway.
Under limited fire condition this 13 feet of separation provide adequate protection.
The fire wrap.and separation discussed above provide adequate protec-tion for a limited fire.
3.0 ' ADDITIONAL FEATURES In addition to the features presented in section 1.0, the Detroit Edison Company commits to having a roving fire watch for this fire zone.
A roving fire watch will be established who will on an hourly basis
-check for and report on if necessary:
o Fire hazards o Evidence of fire o Availability of extinguishers
- o. Any unsafe practices
4.0 CONCLUSION
The fire protection features for the area are designed to ensure that one train of equipment necessary to achieve and maintain hot shutdown is unaf fected by a fire in this area. Under the definitions of a limited fire we meet this goal by having fire protection wrap or separation for all necessary system consistent with the size of the fire.
Hot shutdown and cold shutdown can be achieved and maintained for a limited fire condition.
p.
FIRE ZONE 9 Control Room Auxiliary Building Elevation: 64 3'- 6 "
1.0 DESCRIPTION
The following is a summary description of this fire zone. This summary includes the design combustible loading, fire protection features available and fire resistance rating of the zone. This section supplements the information provided in FSAR section 9B.4.2.
NOTE: FSAR section 9B.4.2 states wrap will be used to protect redundant trains this document takes into account the fact that wrap activities have been stopped in these areas and the wrap remains in a partially complete state.
Combustibles Control Room:
Electrical insulation 134,000,000 BTU Paper 95,000,000 BTU Transients (in computer room) 102,000,000 BTU 444,000,000 BTU Peripheral Rooms:
Paper, wood, plastic 222,000,000 BTU Fire Protection (Available)
Suppression: none Detection: Some detection (early warning) above drop ceiling and in Control Room panels Portable Extinguishers: (2) Dry chemical Hose Stations: (2) CO2 (3) llalon Fire Resistance Rating Actual: Walls - Reinforced concrete Floor / Celling - Reinforced concrete Fixed Openings - none Scaled Penetrations -
Penetrations sealed consistent with fire rating of walls, floor and ceiling
r.
Unsealed Penetrations in barriers -
Ventilation ducting Doors -
2 bulletproof doors to Turbine Building (A)
I bulletproof door to northeast stair tower M
The following lists all those Appendix R systems that have some equipment or circuits located in the fire zone. An 'X' opposite a system indicates the presence of those divisional components / cabling in the fire zone.
Note: Not all these systems are required for safe shutdown. There are different paths available that the operating procedures utilize to accomplish plant shutdown.
FIRE ZONE: 9-SYSTEMS DIVISION I DIVISION II Hot Shutdown Only E51-RCIC X E41-HPCI' X E21-CS X X B21-ADS X X Ell-RHR X X
- Cold Shutdown Only Ell-RHR X X B31-Rec ire . X X Hot and Cold Shutdown B21-MSIV's X X B21-Instrumentation X X Ell-RHR SW X X Ell-RHR Cooling Towers X X P44-EECW X X P45-EESW X X R14-ESF AC X X R16-ESF AC X X R30-ESF AC X X R32-E*7 DC X X T41-ESF Fan Coll HVAC X X T41-Control Center HVAC X X T50-Suppression Pool Instr. X X F50-Control Air X X X41-E.D.G. HVAC X X R31-ESF AC X REFERENCE DRAWINGS: 6E721-2803-8
2.0 ANALYSIS
- 1. The control room is constantly manned, ensuring that potential fires are quickly detected and suppressed.
- 2. Control room operating panels each consist of a low combustible load and contain only low energy cables such as for control, indication and low power circuitry for control room instrumentation.
- 3. The conduits routed through the Control Room have been analyzed as not required for shutdown.
- 4. Safe shutdown panels in the control room have been protected to minimize exposure fire damage by the following additional actions:
a) Holes or gaps between the panels 601 and 602, 809 and 810, and 808 and 817 will be sealed with a fire retardant sealant or barrier (in particular, the bus bar penetration and the air gaps between the separating bulkheads and the Control Room floor).
b) Small fitup gaps in the front corners of the above referenced panels will be sealed with a fire retardant sealant or barrier.
c) Two additional portable Halon fire extinguishers will be located in convenient locations near the Control Room Operating Panels.
- 5. An analysis was performed on each control room panel to determine adverse affects on safe shutdown capability. The analysis results indicate that a fire in any single panel will not adversely af fect safe shutdown capability. For fires in panels H11-P601 and H11-P807 manual operator action will be taken to eliminate possible spurious actuations. Those procedures follow:
l
E Fire in Control Operating Panel H11-P807 in Fire Zone 9 p Control Room Elev. 643'6" For a fire in the Control lRoma in panel Hil-P807, the following actions may be required to restore Mechanical Draft Cooling Tower functionality (long term shutdown cooling).
- 1. Operator'will go to the RHR Complex and manually open the Cooling Tower Bypass Valve E1150F603B (V15-2083).
When a Cooling Tower Fan requires operation:
- 2. Operator will go to the RHR Complex and manually open the Cooling Tower I A inlet valve Ell 50F604A.
- 3. Operator will go to Termination Cabinet Hil-P868 in the relay roors. Lift the leads on cable no. 221233-1C from Terminal Strip
' D' , terminal points D10, D13, D15.
- 4. Operator will go to Remote Shutdown Panel H21-P100/C35-P001.
Operate Transfer Switch 100C53, turn CMC-R switch for Mech. Draft Cooling Tower Fan ' A' to "High Speed" position.
l
Fire in Control Operating Panel Hil-P601, Fire Zone 9, Control Room For a fire in Panel Hil-P601 it will be necessary to take operator action to maintain or restore torus water level indicat , and to prevent inadvertent opening of the SRV's.
To maintain or restore torus water level indication the following operator
-actions are required: (long term action)
- 1. Locate Panel H11-P915 (DIV. II) in the Relay Room
- a. 5
- b. 6
- c. 7
- d. 85
- e. 86
- f. 87
- 3. Locate TB D in Hil-P915. Place a jumper between the following pairs of terminals:
- d. TB D, Terminal 52 and TB C. Terminal 78 The above listed actions will energize the open solenoid coils of valves E41-F400, -F402, -F412A, -F4128 and open the valves.
(Ref. DWG's 61721-2671-11, R. A; 61721-2225-13, R.0; 61721-2674-4, R.L)
To prevent inadvertent opening of the SRV's the following operator actions are required: (short term act ions )
- 1. Open the position #1 disconnect switch in Cabinet R32005064A (DIV. II) in the Relay Room.
- 2. Open the position #11 disconnect switch in Cabinet R3200S064B (DIV. II) in the Relay Room.
- 3. Open the position #1 disconnect switch in Cabinet R3200S061A (DIV. II) in the Relay Room.
m !
- 4. Open the position #1 disconnect switch in Cabinet R3200S061B
. (DIV. II) in the Relay Room.
The above listed actions will take power away from the SRV's and prevent spurious operation due to the effects of a fire. (Ref.
DWG's 6SD721-2530-10; 6SD721-2530-11) 3.0 ADDITIONAL FEATURES
. With the features presented in section 1.0 and the procedure outlines
.in section 2.0, no additional features would significantly enhance the fire protections provided by the current configuration.
l
4.0 CONCLUSION
- The fire protection features for the area are designed to ensure that one train of equipment necessary to achieve and maintain hot shutdown is unaf fected by a fire in . this area. Under the definition of a limited fire, we meet thia goal by having adequate fire protection provided for all necessary systems consistent with the size of the fire. The procedures specified in section 2.0 ensures long term action is also achieved and short term spurious action is mitigated.
Hot shutdown and cold shutdown can be achieved and maintained for a limited fire condition in this zone.
T k
I P
FIRE ZONE 11 Miscellaneous Rooms Auxiliary Building Elevation: 643'-6"
1.0 DESCRIPTION
The following is a summary description of this fire zone. This summary includes the design combustible loading, fire protection features available and fire resistance rating of the zone. This section supplements the information provided in FSA section 9B.4.2.
NOTE: FSAR section 9B.4.2 states wrap will be used to protect redundant trains. This document takes into account the fact that wrap activities have been stopped in these areas and the wrap remains in a partially complete state.
Combustibles Flectrical InsulationI 76,200,000 BTU 444,000,000 BTU Design Basis Fire Fire Loading l 37,000 BTU /sq . ft.
Fire Protection (Available)
Suppression: CO2 / zone wide (DIV I only)
Detection: (2) Ionization detection systems / zone wide (one actuates Halon system)
Portable Extinguishers: (2) Dry chemical (1 in corridor)
(1) CO2 Hose Stations: (1) water - corridor (1) CO2 Fire Resistance Rating Required: .50 hour5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> Actual: Walls - 3-hour rated / north, east, west, south Floor / Ceiling -
3-hour rated Fixed Openings - metal hatch / Zone 13 Scaled Penetrations -
3-hour rated
~
l Unsealed .
Penetrations - none j t
Doors' -
(2) A/12 AB (2) A/ Zone 10 (AB)
A/ Turbine Building
~
NOTE'It. Estimated actual fire loading is 18,000 BTU /sq. ft. based on the trays being found to be approximately 50% full during <l.sual i inspection. !
l t
[
h 1
1 I
i 1 i f
i
The following lists all those Appendix R systems that have some equipment or circuits located in the fire zone. An 'X' opposite a system indicates the presence of those divisional components / cabling in the fire zone.
Note: Not all these systems are required for safe shutdown. There are different paths available that the operating procedures utilize to accomplish plant shutdown.
Division 1 Area FIRE ZONE: 11 SYSTEMS DIVISION I DIVISION II Hot Shutdown Only E51-RCIC X E41-HPCI X E21-CS X B21- ADS X X E ll-RHR X X Cold Shutdown Only Ell-RHR X 831-Rec irc .
Hot and Cold Shutdown B21-MSIV's 521-Instrumentation X X Ell-RHR SW X Ell-RHR Cooling Towers P44-EECW P45-EESW R14-ESF AC X R16-ESF AC X X R30-ESF AC R32-ESF DC X X T41-ESF Fan Coil HVAC X X T41-Control Center HVAC X X T50-Suppression Pool Instr.
P50-Control Air X41-E.D.C. HVAC R31-ESF AC X X REFERENCE DRAWINCS 6E721-2803-9
Division II' Area
.. FIRE ZONE: 11
. SYSTEMS DIVISION I DIVISION II Hot Shutdown Only E51-RCIC E41-HPCI E 21-CS .
B21-ADS Ell-RHR Cold Shutdown Only Ell-RHR B31-Rec ire .
Hot and Cold Shutdown B21-MSIV's B21-Instrumentation Ell-RRR SW Ell-RHR Cooling Towers P44-EECW P45-EESW R14-ESF AC.
R16-ESF AC R30-ESF AC R32-ESF DC X T41-ESF Fan Coil HVAC X
.T41-Control Center.HVAC T50-Suppression Pool Instr.
P50-Control Air X41-E.D.C. HVAC R31-ESF AC e
. REFERENCE - DRAWINGS : 6E721-2803-9 1
~ , -.,- ,,,,n, ...n . . . - -,.,-,.,n,, .,m .
--,,,,,.--e ,
v.,., ,.- ,-
V s
2.0 ANALYSIS
- 1. The Division I battery charger area has Division II (Train B)
- / J raceways and equipment which have one of the following fire N protection features
- r. i 1
0' -a. Raceways and equipment which are not required for shutdown.
.b. Two cable trays which have separation less than 20 feet from Division I but have their major portions wrapped with a single layer of 3-M protective material.
s
'Under the limited fire, the wrap and separation combination above will ensure at least one train of shutdown equipment is avail-able.
3.0 ADDITIONAL FEATURES In addition to the features presented in section 1.0 and in section 2.0, the Detroit Edison Company commits to having a roving fire watch for this fire zone.
A roving fire watch will be established who will on an hourly basis check for and report on if necessary:
o Fire hazards
_; o Evidence of fire o Availability of extinguishers o Any unsafe practices-4.0 CONCL USION The fire protection features for the area are designed to ensure that one train of equipment necessary to achieve and maintain hot shutdown is unaf fected by a fire in this area. Under the definitions of a limited fire we meet this goal by having fire protection wrap or separation for all necessary system consistent with the size of the fire.
Hot shutdown and cold shutdown can be achieved and maintained for a limited-fire condition.
4
/
/
r
/ '
t
FIRE ZONE 13 Ventilation Equipment Area Auxiliary Building Elevation: 659'-6"
1.0 DESCRIPTION
The following is a _ summary description of this fire zone. This
- summary includes the design combustible. loading, fire protection features available and fire resistance rating of the zone. This s
- ion supplements the information provided in FSAR section 9B.4.2.
NOTE: FSAR section 9's. .2 states wrap.will be used to protect redundant trains ' this ' document takes into account the fact that wrap activities have been stopped in these areas and the wrap remains in a partially complete state.
Combustibles
. Electrical-Insulation 9,400,000 NIU Desian Basis Fire i Fire Loading . ' Northeast corner 14,000 KrU/sq. ft.
' Total Zone Loading 1,190 NIU/sq. ft.
Fire Protection (Available)
Suppression: none Detection: Ionization / zone wide (early warning)
Portable Extinguishers: (1) Dry chemical-north stairwell
~
-Hose Stations: -(2) Water
'_ Fire Resistance Rating Required: .25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />
' Actual: Walls - 3-hour rated / east, north, and west 3-hour rated / northwest stairwell.
exterior / south concrete block enclosure, 3-hour dampered pipe chase Floor / Ceiling ' . 50 inches reinforced concrete floor 12 inches reinforced concrete ceiling Fixed Openings -- Metal hatch / Zone 11 AB.and 15 AB m
. Seal'd e
Penetrations ~ -
3-hour rated /tF ough rated walls in unrated -
Fire stops / cab.o tray penetrations through
- barriers unrated barriers
. Unsealed
. Penetrations piping conduit Doors -
A/ northwest stairwell A/ Turbine Building k
9 i .
[ _'; . . .>c
r 4
The following lists all those Appendix R systems that have some equipment or circuits located in the fire zone. . An 'X' opposite a 7 system indicates.the presence of those divisional components / cabling in the fire zone.
Not all these systems are required for safe shutdown. There
~
Note:
are different paths available that the operating procedures utilize to accompitsh plant' shutdown.
FIRE. ZONE: 13 SYSTEMS DIVISION I DIVISION II Hot Shutdown Only E51-RCIC X E41-HPCI X E21-CS X X B21-ADS X X Ell-RHR - X X Cold Shutdown Only.
Ell-RHR X X B31-Recire.
Hot and Cold Shutdown.
B21-MSIV's B21-Instrumentation- X X Ell-RHR SW Ell-RHR Cooling Towers P44-EECW-P45-EESW R14-ESF' AC X R16-ESF f AC X. X R30-ESF AC
'R32-ESF DC X T41-ESF Fan Coil HVAC X T41-Control-Center HVAC X X T50-Suppression Pool Instr.
i.
P50-Control Air
~ REFERENCE DRAWINGS: 6E721-2804 6E721-2804-11 6E721-2804-12 B
t
' 2.0 : ANALYSIS Fire sene 13 is a major Division I area. Division II raceways have f one . of . the following . fire protection features :
L1) Raceways which are analyzed as not required for shutdown.
2), Raceways which-are wrapped with a one hour protective envelope.
3)s Raceways that are wrapped with the 3-M material but do not achieve a full one hour rating.
, 4) A radiant heat' shield floor to ceiling as shown on the attached sketch is also being added to separate the Div I and Div II equipment 'from a common heat source.
Based:on the above discussion there is adequate protection for a
. limited fire.
- 3.0 ADDITIONAL FEATURES In. addition to the features presented in section 1.0 and section 2.0,
- the Detroit Edison Company commits to having a roving fire watch for
- this fire zone. -
A roving. fire watch will be established who will on an hourly basis check for and report on if.necessary:
o- Fire hazards
- o. Evidence of fire
-o - Availability of extinguishers Any unsafe-practices
~
o.
4 '. 0 CONCLUSION
~ The fire protection features for the area are designed to ensure that one ' train of equipment necessary to achieve and maintain hot shutdown is unaffected by a fire in this area. Under the definitions of a
' limited fire we meet this goal by' having fire protection wrap or 6 ' separation ;for. all necessary system consistent with the size of the fire.
Hot' shutdown and cold'shutdova'can be-achieved.and maintained for a limited fire condition.
T M
N 9 T-- 1 9 Yrv* Ytww -y*v--- F f-7-r-g-N-'-wyf gwy T-79 y '-77-'$ T- yg--Nw-tm--yw' M+t'?ve'--'wmvMT-Nwtv W 9 -'-y6r "* - e- ery c p py-g- g -we--ww-mgrq---r-.ya--9, --
i . um-- l l ,
h! M M
i EEEEEEssassal !
M M
I -
8 E
N m t
, E e
8 n w i a a
m Q z N =%=
E k t h S -
! f h
= l ll ia (hP
=
=
e ro
! m b E Q s
m , s
- s E V i e i e E ,
" EEEEEEEEEEEEEER_Ejl e
o l :
'Y4 ATTACHMENT 2
/
DISCUSSION OF LIMITED FIRE CONCEPT-
. .The areas where the limited fire concept is used are areas thatlhave strict access control. These areas contain only cable,-control cabinets or ventilation equipment. The iintroduction.of large amounts of transient. combustibles is not anticipated nor is it~ allowed in accordance with Fermi 2 administrative controls. Therefore the predominate com-bustible in all of.these areas are cables of EPR/Hypalon
. construction.
EPRI tests have. demonstrated that an electrical short will
+
'not prop' agate.a fire in this type'_of cable. Therefore an exposure fire would be required for propagation of the cable fire. :EPRI test "NP 1881" documents that a minimum of four
- gallons of a necessary flammable liquid, burning for 10
~ minutes was-necessary to cause the fire to slowly propagate.
The cable l fire self extinguished after approximately 30 minutes. This indicates the.EPR/Hypalon jacket cable has a
- high resistance to fire.-
' Additionally in six of the eight auxiliary building areas,
~
automatic suppressionsystems are. installed. They are as (follows:
Zone 1 Automatic sprinklers Zone'2
. Automatic sprinklers zone'3 Automatic Halon 1301 Zone 7 . Automatic Halon 1301/ manual sprinklers
- Zone 8 ~ Automatic carbon dioxide Zone 11. Automatic carbon dioxide i.
All eight zones contain ionization detection systems. A
. transient' combustible exposure fire of the large magnitude
. described previously'(4 gallon of flammable liquid),
is expected to actuate the various suppression systems in
, - 'the rooms in less than'10 minutes. Actuation times of 10 minutes or'less compare favorably to.the time required for
_ .. cable fire propagation.
W: Upon sprinkler: actuation, the water.will provide a positive means for cooling the area and fire control / extinguishment.
In addition,=Sandia Report "SANDI 81-1785" shows that upon factuation-of Halon 1301 systems, the fire is permanently extinguished _and room temperature drops. Detroit Edison's CO2 systems are. designed with extended discharge times (20 min),-which allow for-fire extinguishment. Upon extinguish-sment room: temperature drops.
Theitwo areas where no suppression systems exist are zones 9
'and 13. ' Zone 13 contains a very low combustible loading.
JZone.9 is the Control' Room which is continuously manned.
]$
All these. zones are large volume rooms where heat buildup would be slow should a limited fire occur. The heat buildup would be less than an E119 fire.
On certain raceways, a less than E119 fire rated one hour
. fire barrier has been installed. These barriers have approximate Ell 9 ratings ranging from 10 minutes to 15 Eminutes. _These raceway protective systems will provide protection beyond that E119 rating because of the room
' volume, suppression systems and slow growth of EPR/Hypalon cable fire. These less than one hour barriers will provide the necessary protection to maintain electrical circuit
' integrity during a limited fire in any of these areas.
t-
v -
A.
k ATTACHMENT 3-I I
4 - Additional Information Showing
~
Compliance with 10CFR50.12 L
The';NRC- staff reque'sted ~ Edison file -this ' request due to the tim'e~ required to implement installation for the alternate Lshutdown' approach. The . granting of, this request is
' authorized by law andiwill not present an undue risk to the
' ~
_ public health and safety, is consistent with the common '
' defense and security, and is in the public. interest as spec-ified below.
-o Will not present'an undue risk to public health and l safety and is consistent with the common defense and security: Appendix 9B of.the FSAR, Reference.(.3) and (4),. Supplement 2 to the NRC's Safety Evaluation Report
-for Fermi.2, and numerous other submittals of record -
- . 1d ocument Detroit Edison's ef fort towards implementing a proper and effective fire protection program at Fermi 2.
These efforts not only arise out of a corporate commit-
- ment to good fire protection practices and meeting ap-propriate. regulations, especially.as it pertains to-nuclear power, but also out of good faith efforts to
-respond to NRC ' staff . concerns, interpretations , and
. - guidance. The commitment to the alternative shutdown approach for-affected fire areas.(see Attachment 1) arose earlier this year out of discussions with the staff over such1 interpretations. Detroit. Edison is implementing the alternative shutdown approach expeditiously consistent w!.th proper design control, review,.and implementation procedures. Until the ,
design.is implemented, Detroit Edison-is showing, by analysis,Lthat'the existing design serves the underlying purpose of the regulation. In addition,
-Detroit Edison is further enhancing'the fire. protection measures for-the areas of: interest in the intervening
[
period by eidploying additional compensatory measures.
These measures along with the existing fire protection i ~
features and the analysis are described in detail in
' Attachment-l'and'2. This information documents that '
granting of this exemption will not present an undue Lrisk to public health and safety, and is consistent with the common defense and security.
e d
4 - sr s , m,c,,r,2,.- m,. . , , . .w...#.- -. _ - - -y,-, y__-, -.,. .e., .,-m9.,%,,y---,--,,y,w-m.c--e- --. ----wy--y-, ,-,,yec.9-.,,
,, , - - - - - . - . , ~ .. - - . - . _.. .- _. . . -
t ATTACHMENT 3
, ol Is'in the Public Interest: The commitment to the alter-
. native shutdown approach was formally made to the NRC inl August , '19 84 (Reference 2) and arose from discus-
, sions with NRC-staff beginning approximately in March
'1984. Fermi 2 is. scheduled to load fuel before the end
.of 1984. - To not grant . this request would place an Lundue financial and economic hardship on Detroit Edison and-its; customers due to.the-late stage or plant completion. The- denial would lead to a commensurate
. delay.in the project schedule until implementation of
'the alternative . shutdown concept were complete. This
- 'is not warranted since there is no undue risk to public
- health and' safety. As stated to the NRC staff, the
~ concept is'a complex one and we must satisfy ourselves of its safety and acceptability prior to formal
- implementation. Edison believes this can be safely done prior to.startup after,the first refueling outage.
. However, to ensure"the period of time is minimized prior to-implementation, Edison commits to implement th'e approach as' feasible.during available outages after detailed-design is completed, and materials and proced-
. ures for.impleme'ntation are-available.
j' ' Additional. considerations are as follows:
'o Alternative or compensatory means exist to achieve the underlying purpose of the regulation: Attachment 1 to this . letter describes in detail for .each applicable fire' area the existing fire protection features, and
- t. ~ alternative- or compensatory measures to- achieve the L
~
. underlying purpose of the regulation. These measures ,
include summaries of analyses of possible limited fire situations showing'how safe shutdown is achieved.
o The exemption would provide only temporary relief from the applicable regulations:- As stated previously, this request.-is temporary and will~only remain in force until the alternate. shutdown approach is implemented.
Detroit Edison ~is-proceeding. expeditiously to. implement
, .this approach consistent with proper engineering design practices and proper respect for safety. Furthermore,
<. Detroit Edison has committed to a reasonable date for-implementation of the approach which is well within -
' prior ~ precedent and~within Edison's ability to properly U commit . Notwithstanding, Edison committed, in Laddition, to not. delay until this calendar date but implement the approach as soon as practically feasible within the operating constraints of the plant after the design is.-completed and the material is received, and implementation procedures developed.
v 1
i
~-
a . . ,
w fI'- >g,,--i-M. pgggs,.--sqrw-egryg9,p,,,,c. ys.,,s.,i..+ gyp.ym.e,q9q--ryp..g>ay,mw- amsg4,9<sw'p 9p qgg9.m p pge w yq q91p _.,vg y-q ,s 99 ag w o w= -- y- g g w- N-ggey 9 y 9.g-up. 9