ML14079A234
| 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: |
| References | |
| BNP-220, BSEP 14-0029, TAC ME9623, TAC ME9624 BNP-PSA-086, Rev. 1 | |
| Download: ML14079A234 (17) | |
Text
Enclosure 2BNP-PSA-086,BNP Fire PRA -Fire Scenario Data,Attachment 25 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 1 of 16BNP-PSA-086 Revision 1Attachment 25 -Change Package BNP-220 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 2 of 161 of 15Change Control FormlDocument Review Cover SheetChange Number: BNP-220Page I of 15Equipment Tag Number:N/A Cable Number: NIAReason 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, ReactorBuilding 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 InformationEl Circuit Information Dl Cable Construction E- Fire Area informationEl Analysis Input Circuit Drawingsnl TableException Modifications: (attach additional sheets if necessary)E1 GateCAFTA:El Fault Tree ModelMiscellaneous:[E Compliance StrategyEl DescriptionEl FSSPMD El ARCX Other Changes (explain under Description of Change)El Benchmark TestDescription of Change:This change package supports using a 143Kw HRR (98% fire) for transient combustibles in some areasof the plant and in other areas the 317Kw HRR (98% fire) for other areas unless administrativerestrictions are used. The results are to support resolution of F&O 1-19. The conclusion is that somearea will need to use the 317Kw HRR and others are acceptable with the 143Kw HRR and another groupof areas will have to have transient combustible controls installed or an 317Kw HRR will have toevaluated.Prepared by:Rishel, RobertPrepared By2012.04.28 1602:52:-70'-'04'00'Data Input by:---------------------------------------------Reviewed by:Data Input Verified by:
BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 3of 16 2of15Evaluation of Transient HRR in selected areas:Scope: Evaluation of transient combustible loading in Control Building, Reactor Building Unit 1 and Unit2, Diesel Building, Service Water Pump Building and Off-gas facility (AOG). This information will be usedto determine an appropriate/ realistic heat release rate for transient combustibles.Brunswick performs bi-weekly walk-downs of the power block for transient combustibles in accordancewith 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 levelsMethodology: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 procedureis to verify compliance with the Appendix R program and the allowances in combustible loading. Theallowances are documented in calculation 0-89-0001, Combustible Loading (reference 17). The loadingin this calculation is not applicable to this effort in that the calculation basis is to verify total combustibleloading per square foot and ensure the requirements in Appendix R program for High, Medium or Lowtotal combustible loadings are met. The transient combustibles loading in the calculation is determinedby assuming worse case for all potential activities that could occur in a fire area and maximum potentialmaterial at the same time occur. An example of conservatism is assuming that 500 lbs of sheeting isused. The resulting totals are compared to the Appendix R allowances for BTU/square foot foracceptability. This calculation does not attempt to evaluate as found conditions or any realisticconfiguration. Thus the calculation is a bounding effort and not a realistic evaluation. To investigatethe potential for application of the 0-89-0001 calculation to transient loading analysis discussion withsome of the individuals who performed these walk-downs indicate that they identified all transientcombustibles in the areas, not just the transient combustible that are in excess of allowances per theanalysis. 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. Areview of thewalk-down sheets provides evidence that this is correct when it identifies small amount oftrash and other burnable as well as rubber and fiberglass in quantities well below the allowed limits.BNP-220 Attachment 1Page 1 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page4of 16 3of15The completed walk-downs conducted in the past two years were reviewed and 10 were selected for anin-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 beingdocumented and to review the configuration of the material being described in the walk-downsheets. The results of the walk-down sheets were compared with the occupancy and storageidentified as part of the ignition frequency calculation BNP-PRA-0083, looking for inconsistenciesbetween the evaluated occupancy and storage and the walk-down sheets. The comparison didnot identify any discrepancies.2. Interviews of the operators who conducted the walk-downs to confirm the methodology used indocumenting the walk-downs. Additionally discussions with the operators were held on thetypical configuration of some of the identified transient combustibles in selected locations.3. Interviews with the responsible engineer and operators on the background of OFPP-013procedure 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 wellas expectations on housekeeping standards.Ten of the completed walk-downs were selected for the depth review. These were selected based uponwalk-down occurred in last two years (recent information), the unit was not in an outage, differenttimes 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* 11/28/11Results:The walk-down documents support the use of a lower transient heat release rate for the ControlComplex, AOG Building, Reactor Building Unit 1 and Unit 2, the Diesel Generator Building, RadwasteBuilding 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 controlledareas than a Pressurized Water Reactor. This results in many areas where there are restrictions onBNP-220 Attachment 1Page 2 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 5 of 16 4 of 15combustible material admission for the purpose of limiting generation of radiological contaminatedwaste. 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 RadiationProtection organization at the entrance to the RRA. This requirement exists due to the cost of disposalof radiation contaminated trash has continued to increase and has resulted in significant elimination oftrash in these areas. Thus in the RRA (Reactor Building areas) have lower amounts of trash (transientcombustible 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, grindingdiscs, tie wraps, and consumed contamination control material. Interviews with operators who performthese transient walkdowns stated that most of the trash is in containers of about 5 gallon size. Many ofthese 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 evernoted 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, andDG-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 smallamount 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 thefiberglass 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 inthese 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 andbounding.Service Water Building:4 ft elevation (FC 378) NFPA 805 location: SW-O1B. All walk-downs documented a maximum of 12 lbs ofcellulose material in this area and generally the material was mostly 5 lbs of cellulose material. This isconsistent with bounded by Test #4 and #11 of Table G-7, which was 119Kw.BNP-220 Attachment 1Page 3 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page6of 16 5of15Conclusion: Use of 143Kw 98% HRR for 4 ft elevation of the Service Water Building is reasonablyrealistic and bounding.-13 ft elevation (FC 379) NFPA 805 location: SW-01C. All walk-downs documented a maximumof 2 to 4 lbs of cellulose material in this area 30% of the time and generally the material nocellulose 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 isreasonably realistic and bounding.20 ft elevation (FC 377) NFPA 805 location: SW-O1A. All walk-downs identified between 105 to 131 lbsof cellulose material in this area. Upon inspection of the material in this area this area has beenundergoing concrete repairs for the past few years and the material is bags of grout and concreteaggregate and associated tools. Thus the actual burnable material is much less than the walk-downswould suggest and the material is spread out by the pumps suctions over a long narrow strip. Thus alower HRR is a realistic assessment.Conclusion: A heat release rate of 143Kw is reasonably realistic and bounding for thiselevation.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 combustiblematerial in this area. There was identified a portable ventilation fan on the FC 205. This fan is less thanShp and thus would screen out as a fire ignition source per EPRI 1011989/NUREG-CR-6850. In theseareas there are designated locations where transient combustible are required to be stored. Proceduralcontrols 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 andbounding, 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, andCB-11. All walk-downs but one documents no transient combustible material in this area. The one on6/15/10 identified 7 lbs of cellulose material in this area. This is consistent with a 2.5Kg material andwould also be considered a HRR of 143Kw or less.Conclusion: Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic andbounding.23 ft elevation, Battery Rooms (FC 212, 213, 214, 215): NFPA 805 locations are: CB-07, CB-08, CB-09 andCB-10. All walk-downs documented no transient combustible material in this area. During Fire PRA PeerReview walk-downs a plastic bucket was identified in the battery rooms. These buckets do not qualify asBNP-220 Attachment 1Page 4 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page7of 16 6of15a transient combustible because they are filled with dry caustic power (baking soda), which is a firesuppressor 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 andbounding.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 inthis area.Conclusion: Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic andbounding.49 ft elevation Control Building Offices spaces (FC 221, 222, 223, 224, 225, 226, 229) NFPA 805 locationsare: CB-14, CB-15, CB-16, CB-17, CB-18, CB-19, and CB-22. All walk-downs document transientcombustibles 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 procedurebinders and other similar material and is not all in one burnable pile and thus is consistent with a 3-5 lbsgroupings for a 119Kw HRR. The washrooms (FC 225, 229) similarly contained transient combustiblesthat could be significant. However these areas do not contain cable targets and thus high transientcombustible HRR do not impact results. Many of these areas are also continuously manned and thus alower HRR is more appropriate. 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.Conclusion: Use of 143Kw 98% HRR for these NFPA 805 fire areas is not reasonable and the317Kw 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 changeis required. In the risk significant areas additional procedural controls will be put in place toensure transient combustibles are not located in this area of potential targets and cable traysunless 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 andbounding.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 ofprocedures which are not stacked together is an easily burnable configuration and thus do not changethe 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 basedupon a number of factors:BNP-220 Attachment 1Page 5 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page8of 16 7of151. These sources are not transient in that they are maintained in a fixed location, thusthe placement of these fire fuel package is not moveable to a different worse caselocation2. There are not cable targets in the vicinity of the office desks, chairs, andbookshelves, toilet paper storage locker3. The area where this material is located is continuously occupied and thus any firewould be immediately eliminated.4. The configuration of the material is such that in order for this material to contributeto a fire HRR a damaging fire would have to already have been started by anadditional fuel package of considerable size.5. The material covers has a large amount of floor space and thus the HRR per squarefoot is less much smaller than if the same fuel package was stacked in aconcentrated location.Conclusion: Use of 317Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic andbounding for a random fuel package located in the worse case location. However administrativecontrols will also be put on place to ensure transient combustible will not be located in risksignificant 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 inthese 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 andbounding.Electrical Pipe Tunnel (ET, FC 262): This area had a special review and tours in the area. During thesetours no transient combustible material in this area was noted.Conclusion: Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic andbounding.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# intwo instances) and small amount of trash (5-15#), this trash and cellulose are associated withcontamination control measures (step off-pads, and associated clothing removal at the step off padarea). This is again lower combustible loading and a HRR of 135Kw is a reasonable estimate per EPRI1011989/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 andbounding.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 1Page 6 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page9of 16 8of15O1G(NW), RB1-O1G(SC), RB1-O1G(SE), RB1-01G(SW), RBI-05, RB1-06, RBI-07. RB1-08, R31-010, andRB1-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 wasidentified <12# of cellulose material in this area. This amount is well within low HRR per EPRI1011989/NUREG-CR-6850 Table G-7.* FC 274 (RB1-OIG (NC) Reactor Building 1 North Central): In this area small amount of generictrash and dress out clothing is accumulated and periodically is allowed to accumulate. Thequantity is small (<10#) and is consistent with a lower HRR per EPRI 1011989/NUREG-CR-6850Table G-7 NBS -Lee Clothing test.* FC 297 (RB1-5, HP Field office and Decon room): In this area there is approximately 130# ofclothing in various lockers and cabinets in the changing room. As discussed this dress-outlockers, desks, chairs are in a fixed location supporting changing of clothes, as such a 317Kw HRRshould apply to this specific location. Additionally as discussed earlier, the configuration of thismaterial restricts the ability to be a initiating event fire source, in that a existing damaging firewould have to be in the close proximity of this material before these items would be involvedwith a fire. With these areas are constantly occupied by the Rad. Protection Technicians and nocables of interest this area. Thus no impact on the transient combustible analysis, and no furtheraction.* 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 for98% of the time.* None of the other areas in Reactor Building Unit 1 20 ft elevation has walk-downs identifiedtransient combustibles worthy of note.Conclusion: For the area FC 297 and FC 273 the use of a 317Kw HRR applies, based uponobserved material. Additional procedural controls will be put in place while at power to limitthe transient combustibles in these areas unless a specific evaluation is performed. Thus theuse of 143Kw 98% HRR for these NFPA 805 fire areas in RB1 20 ft elevation are reasonablyrealistic.Reactor Building Unit 1 50 ft elevation (FC 280, 281, 282, 283, 284, 285, 286, 296) NFPA 805 locationsare: 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 transientcombustibles cellulose material and in only one instance (7/19/11 in RB1-1H (NW) and (WC)) was thematerial above the 143Kw HRR quantity. These locations require the use of 317Kw HRR unlessprocedural controls are put in place.Conclusion: Use of 143Kw 98% HRR for these NFPA 805 fire areas in RB1 50 ft elevation will beapplied with procedural controls in place while at power to limit the transient combustibles inthese areas unless a specific evaluation is performed using a 317Kw HRR. Thus no further actionrequired.BNP-220 Attachment 1Page 7 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 10 of 16 9of15Reactor 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 aconsistent significant amount of combustibles, all others had little to none. In all cases there were noflammable 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 combustiblesconsistent with that activity. There are no targets in this area of interest and the transientcombustible 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 transientcombustible loading of cellulose material in this area and the 317Kw HRR would apply to thisarea.a RBI-O1K (FC 289), this is the Reactor Building Unit 1 east the identified cellulose material is inrelatively small amounts (<10#) and is such that the low HRR would be expected based upon thetesting 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 andassociated containers and packaging. The amount of packaging is such that the low HRR wouldbe 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 areapplied. Procedural controls will be place to limit the transient combustibles to less than the143Kw 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 transientcombustible loading as discussed below:* RB1-18 (FC 310) is the Reactor Building Supply Room, no equipment or targets were located inthis area, thus 317Kw HRR should be applied, as would be expected for a supply room, there isno impact and further analysis is not required.* RB1-19 (FC 312) is the Reactor Building Changing Room and as expected contains significantburnable cellulose material in this area. However there also is not equipment or targets in thisarea of concern and thus although the transient HRR of 317Kw HRR should be applied there isno 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 therefueling floor and the material is either contamination prevention dress-out clothing or contaminatedclothing at the step off pads to support spent fuel pool evolutions. This is a large open area with notargets and is in specific areas away for important plant equipment and thus no impact on this largetransient.combustible loading in this area.BNP-220 Attachment IPage 8 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Pagellof16 10of15Conclusion is that although the NFPA 805 area has transient combustible loading could besignificant and the 317Kw HRR applies, this is specific to a certain area for a specific purpose andis 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 damagedunless 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 inthis area.Conclusion: Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic andbounding.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 to34#.This material is associated with contamination control with dress-out material and step-off padsfor exiting contaminated areas. This material is not all located together. Some of the trash isnon-burnable such as discarded metal parts, grinding discs etc. This is a fuel package has a smallHRR per square foot, in that the material is in three or four bins with a step-off pad coveringapproximately 25 square feet. Additionally, during the time this is established work isproceeding on a round the clock bases (short term LCO applies to the RHR system), thus thearea is approximately continuously occupied.Conclusion: Use of procedural controls to limit transient HRR to 143Kw 98% HRR for these NFPA805 fire areas will apply unless a specific evaluation is performed for this location using a 317KwHRR.* RB2-O1D: This area typically has 10# cellulose material and occasionally small quantities (lessthan 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 padsfor exiting contaminated areas. This material is not all located together. Some of the trash isnon-burnable such as discarded metal parts, grinding discs etc. In interviews with operationspersonal it was noted that in these cases the material is not a random location, but is specificallylocated in the open area to allow easy entrance and egress from radiological controlledcontaminated areas. This is a fuel package has a small HRR per square foot, in that the materialis 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 aBNP-220 Attachment 1Page 9 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 12 of 16 11of 15round the clock bases (short term LCO applies to the RHR system), thus the area isapproximately continuously occupied.Conclusion: Use of procedural controls to limit transient HRR to 143Kw 98% HRR for these NFPA805 fire areas will apply unless a specific evaluation is performed for this location using a 317KwHRR.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, andRB2-08: 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 wasidentified <15# of cellulose material in this area." FC 323 (RB2-OIG (NC) Reactor Building 2 North Central): In this area small amount of generictrash and dress out clothing is accumulated and periodically is allowed to accumulate. Thequantity 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 smallamount of cellulose material (<10#). This would be consistent with an HRR of 143Kw for 98% ofthe time.* FC 347 (RB2-5, HP Field office and Decon room): In this area there is approximately 180# ofclothing in the dress out material is located in multiple lockers and cabinets in the changingroom this is also similar to EPRI 1011989/NUREG-CR-6850 Table G-7 (Cline) test. This results inthe application of the higher HRR of 317Kw for this area. However since there are no cables ofinterest this area and thus no impact on the transient combustible analysis, and no furtheraction." 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 for98% of the time." None of the other areas in Reactor Building Unit 1 20 ft elevation has walk-downs identifiedtransient combustibles worthy of note.Conclusion: For the areas (FC 322, 323, 347 and 348) the 317Kw HRR applies in the other areasthe 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 specificevaluation 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 805locations 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 transientcombustibles identified on this elevation. The specific location of those areas where burnable transientcombustibles were found is:BNP-220 Attachment 1Page 10 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 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 notedon 11/9/11.Conclusion: Use of 143Kw 98% HRR for these NFPA 805 fire areas in RB2 50 ft elevation will beapplied with procedural controls in place while at power to limit the transient combustibles inthese areas unless a specific evaluation is performed using a 317Kw HRR. Thus no further actionrequired.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 hadidentified burnable transient combustibles. The material was in locations designed and dedicated to thestorage of this material and are detailed below:* FC 349 (RB2-12 Control Rod Drive Repair Room), in this case there was consistently about 20# ofcellulose 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 tolimit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR iscompleted.* FC 336 (RB2-011 RWCU Access Room), which had various amounts of cellulose material notedranging from 20# to a high of 65#. In this case the material was to support dress out (clothing inlockers) and not typically of an open trash can full of burnable material. The amount ofmaterial means the 317Kw HRR would be applied. Administrative controls will be put in place tolimit the HRR of transient combustibles unless a specific analysis using the 317Kw HRR iscompleted.* 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 significantamount 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 binswith a step-off pads covering approximately 25 square feet or more. Administrative controlswill be put in place to limit the HRR of transient combustibles unless a specific analysis using the317Kw HRR is completed.Conclusion: Use of 143Kw 98% HRR for these NFPA 805 fire areas in RB2 80 ft elevation will beapplied with procedural controls in place while at power to limit the transient combustibles inthese areas unless a specific evaluation is performed using a 317Kw HRR. Thus no further actionrequired.BNP-220 Attachment 1 Page 11BNP-220 Attachment 1Page 11 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 14 of 16 13of 15Reactor 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 whichwere 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 wouldbe expected in a supply room thus in this location the 318Kw HRR would apply. Administrativecontrols will be put in place to limit the .H.RR of transient combustibles unless a specific analysisusing the 317Kw HRR is completed.* FC 362 (RB2-19, Reactor Building Clothing Change Room) also has significant transientcombustible as would be expected in the main dress out changing area thus in this location the318Kw HRR would apply. Administrative controls will be put in place to limit the HRR oftransient 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 beapplied with procedural controls in place while at power to limit the transient combustibles inthese areas unless a specific evaluation is performed using a 317Kw HRR. Thus no further actionrequired.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) hasany transient combustible noted. This was cellulose material to support refueling operations andcontained in lockers designed for the material. At times during refueling/ fuel activities in progressthere 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 andbounding.Reactor Building 2 133 ft elevation (FC 357) NFPA 805 location is: RB2-15. There were no transientcombustibles noted in this area at any time.Conclusion:. Use of 143Kw 98% HRR for these NFPA 805 fire areas are reasonably realistic andbounding.RadWaste Building -3 ft elevation (FC 367) NFPA 805 location is: RW-O1A. This area is the Rad WasteTank Room. The transient combustibles identified are liquid cartons of processed oily waste (mixedliquid waste after processing 1 to 100 gallons). The material is stored in one location and no targets arein the area. The other transient combustible materials in this location are some cellulose material inmultiple locations (25# to 45#) and some trash typically 40#. In this location a 317Kw HRR would beapplicable. Administrative controls will be put in place to limit the HRR of transient combustibles unlessa specific analysis using the 317Kw HRR is completed.Conclusion: Use of the 317Kw 98% HRR is applicable for this area. Administrative controls will beput in place to limit the HRR of transient combustibles to 143Kw HRR unless a specific analysisusing the 317Kw HRR is completed.BNP-220 Attachment 1Page 12 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 15 of 16 14 of 15RadWaste Building 23 ft elevation (FC 368, 373) NFPA 805 locations are: RW-O1B, RWDL. This is theRadWaste 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 wasteis moved through to the loading dock outside of this area. The combustibles in this area are resin (up to1761#), charcoal filters (192#), trash and cellulose material. In this location a 317Kw HRR would beapplicable. Administrative controls will be put in place to limit the 143Kw HRR of transient combustiblesunless 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 requiredbased upon the administrative controls that will be put in place to limit the HRR of transientcombustibles 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 ofthe Rad Waste Processing Building. There are some smaller amounts of cellulose material on twooccasions (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 requiredbased upon the administrative controls will be put in place to limit the HRR of transientcombustibles 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# ofcellulose and 20# of trash). The 55# of cellulose exceeds the 143Kw HRR. In this location a 317Kw HRRwould be applicable; however administrative controls will be put in place to limit the HRR of transientcombustibles 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 basedupon the administrative controls will be put in place to limit the HRR of transient combustibles unless aspecific analysis using the 317Kw HRR is completed.References:1. EPRI 1011989/NUREG-CR-6850 Table G-72. OFPP-013 Transient Fire Load Evaluation, Completed 06/15/103. OFPP-013 Transient Fire Load Evaluation, Completed 07/7/104. OFPP-013 Transient Fire Load Evaluation, Completed 12/15/105. OFPP-013 Transient Fire Load Evaluation, Completed 01/24/116. OFPP-013 Transient Fire Load Evaluation, Completed 05/17/117. OFPP-013 Transient Fire Load Evaluation, Completed 07/19/118. OFPP-013 Transient Fire Load Evaluation, Completed 09/13/119. OFPP-013 Transient Fire Load Evaluation, Completed 10/12/1110. OFPP-013 Transient Fire Load Evaluation, Completed 11/09/1111. OFPP-013 Transient Fire Load Evaluation, Completed 11/28/11BNP-220 Attachment 1Page 13 BNP-PSA-086 Rev. 1Attachment 25 -Change Package BNP-220Page 16 of 16 15 of 1512. NUREG/CR-4680, Heat and Mass Release for Some Transient Fuel Source Fires: A Test Report,October 198613. NBSIR 88-3733, Cone Calorimeter Evaluation of Flammability of Composite Materials, March198814. Operator interviews on 3/24/1215. ASTM E-84, and use Polyester resins Class A, for fiberglass materials. The resin will be a flameretardant, promoted thixotropic polyester resin designed for use in hand lay-up and sprayupprocesses. 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-84flame spread rating of less than 25 unfilled and smoke density under 450.16. FIR-NGGC-0009, NFPA 805 Transient Combustibles and Ignition Source Controls Program17. 0-89-0001, Combustible Loading, Rev 5BNP-220 Attachment 1 Page 14BNP-220 Attachment 1Page 14