NLS2013032, 120-Day Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805

120-Day Response to Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805

ML13080A266
Person / Time
Site:	Cooper
Issue date:	03/13/2013
From:	Limpias O Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2013032
Download: ML13080A266 (41)

Text

N Nebraska Public Power District Always there when you need us 50.90 NLS2013032 March 13, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

Reference:

120-Day Response to Request For Additional Information Regarding License Amendment Request To Adopt National Fire Protection Association Standard 805 Cooper Nuclear Station, Docket No. 50-298, DPR-46

1. Letter from Lynnea E. Wilkins, U.S. Nuclear Regulatory Commission, to Brian J. O'Grady, Nebraska Public Power District, dated November 14, 2012, "Cooper Nuclear Station - Request For Additional Information Re: License Amendment Request To Adopt National Fire Protection Agency Standard NFPA 805 (TAC ME8551)"

2. Letter from Brian J. O'Grady, Nebraska Public Power District, to U.S.

Nuclear Regulatory Commission, dated April 24, 2012, "License Amendment Request to Revise the Fire Protection Licensing Basis to NFPA 805 Per 10 CFR 50.48(c)" (NLS2012006)

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District to provide the 120-day response to a Nuclear Regulatory Commission Request for Additional Information (Reference 1) related to the Cooper Nuclear Station (CNS) License Amendment Request to adopt National Fire Protection Association (NFPA) Standard 805 as the CNS Fire Protection licensing basis per 10 CFR 50.48(c) (Reference 2). This response is attached. There are no commitments made in this submittal.

Should you have any questions concerning this matter, please contact Todd Stevens, CNS NFPA 805 Transition Project Manager, at (402) 825-5159.

COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

1. 1Le

NLS2013032 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on 05/15/13 (Date)

Sincere Oscar

.Limpi Vice President Nuclear and Chief Nuclear Officer OAL/wv

Attachment:

120-Day Response to Cooper Nuclear Station Request For Additional Information Regarding License Amendment Request To Adopt National Fire Protection Association Standard 805 cc:

Regional Administrator w/ Attachment USNRC - Region IV Cooper Project Manager w/ Attachment USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ Attachment USNRC - CNS Nebraska Health and Human Services w/

Department of Regulation and Licensure NPG Distribution w/o Attachment Attachment CNS Records w/ Attachment

NLS2013032 Attachment Page 1 of 39 Attachment 120-Day Response to Cooper Nuclear Station Request For Additional Information Regarding License Amendment Request To Adopt National Fire Protection Association Standard 805 The Nuclear Regulatory Commission Request for Additional Information (RAI) regarding the National Fire Protection Association (NFPA) Standard 805 Transition License Amendment Request (LAR) is shown in italics. The Nebraska Public Power District (NPPD) 120-day responses to the RAI are shown in block font.

Safe Shutdown (SSD)

Request: SSD RAI 01, 02, 03, 04, 05, 06, 07, 08, and 09.

NPPD Response:

These RAIs were addressed in the 60-day and 90-day responses.

Fire Protection Engineering (FPE)

Request: FPE RAI 01, 02, 03, 04, 05, 06, 07, 08, 09, 10, 11, 12, 13, 14, 15, 16, 17, and 18 NPPD Response:

These RAIs were addressed in the 60-day and 90-day responses.

Probabilistic Risk Assessment (PRA)

Request: PRA RAI-01, 02, 03, 04, and 05 NPPD Response:

These RAIs were addressed in the 60-day and 90-day responses.

NLS2013032 Attachment Page 2 of 39 Request: PRA RAI-06 Non-suppression Probability The non-suppression probability (Ps) results reported in NEDC-08-041, Rev. 3 (i.e., Tables 11, 12, 13, 21, 22, and 23) used non-suppression probability values less than 0. 001, contrary to NUREG/CR-6850 Attachment P. Please provide the results of a sensitivity analysis (CDF, LERF, delta (A) CDF, ALERF) using P,s no lower than 1E-03.

NPPD Response:

The following tables document the revised results from Calculation NEDC 08-041 (Tables 11, 12, 13, 21, 22, and 23), replacing all non-suppression probability (Pns) values less than L.OOE-03 with a set value of 1.OOE-03.

Additionally, the response to Fire Modeling RAI 02d identified a calculated normalized parameter in the Main Control Room (MCR) Abandonment Fire Dynamics Simulator (FDS) fire models that was outside the validated range. As such, the FDS models were revised to bring the normalized parameter within the validated range which resulted in changes to the time to abandonment. This revision only applies to the electrical cabinet fires (Cases 2 and 5). The tables below provide the revised non-suppression probabilities based on the new abandonment times.

The following revised tables from Calculation NEDC 08-041 provide the calculated severity factors and probabilities of non-suppression for MCR Abandonment with natural ventilation:

NEDC 08-041 Table 11: Time to Abandonment Probability Analysis for Case 5 (Natural Ventilation)

Electrical Cabinets -.Case 5 REVISE, VALUES Bin HRR [kW]

-SF b

Tim S

Time PSFP.

2 197 1.55E-01 22.7 5.58E-04 8.65E-05 21.3 1.00E-03 1.55E-04 3

337 8.1OE-02 18.7 2.09E-03 1.69E-04 16.3 4.61E-03 3.74E-04 4

475 4.70E-02 16.7 4.04E-03 1.90E-04 14.5 8.35E-03 3.93E-04 5

612 2.90E-02 15.2 6.63E-03 1.92E-04 13.3 1.24E-02 3.60E-04 6

749 1.80E-02 13.5 1.16E-02 2.09E-04 12.2 1.78E-02 3.21E-04 7

886 l.1OE-02 13 1.37E-02 1.51E-04 11.7 2.lOE-02 2.32E-04 8

1024 7.OOE-03 12.7 1.51E-02 1.06E-04 11.0 2.65E-02 1.86E-04 9

1162 5.OOE-03 12.3 1.73E-02 8.63E-05 10.5 3.13E-02 1.56E-04 10 1299 3.00E-03 11.7 2.10E-02 6.31E-05 10.2 3.45E-02 1.04E-04 11 1436 2.00E-03 11.3 2.40E-02 4.80E-05 10.0 3.69E-02 7.38E-05 12 1573 1.00E-03 11 2.65E-02 2.65E-05 9.7 4.07E-02 4.07E-05 13 1710 1.00E-03 10.8 2.83E-02 2.83E-05 9.3 4.65E-02 4.65E-05 14 1847 1.00E-03 10.5 3.13E-02 3.13E-05 10.3 3.34E-02 3.34E-05 15 2276 1.00E-03 9.83 3.90E-02 3.90E-05 9.83 3.90E-02 3.90E-05 Total 1.43E-03 Total 2.51 E-03

NLS2013032 Attachment Page 3 of 39 NEDC 08-041 Table 12: Time to Abandonment Probability Analysis for Case 2 (Natural Ventilation)

Electrical Cabinets, as.2 VISEDVALUESP A.

Bin HiRR [kW]

S_______

Time me n

Time 'I P"s, 2

130 2.02E-01 22.7 5.58E-04 1.13E-04 21.3 1.OOE-03 2.02E-04 3

221 1.13E-01 18.7 2.09E-03 2.36E-04 16.3 4.61E-03 5.21E-04 4

310 6.70E-02 18.7 2.09E-03 1.40E-04 16.3 4.61 E-03 3.09E-04 5

400 4.1OE-02 16.7 4.04E-03 1.66E-04 14.5 8.35E-03 3.43E-04 6

490 2.60E-02 15.2 6.63E-03 1.72E-04 13.3 1.24E-02 3.23E-04 7

579 1.60E-02 15.2 6.63E-03 1.06E-04 13.3 1.24E-02 1.99E-04 8

669 1.OOE-02 13.5 1.16E-02 1.16E-04 12.2 1.78E-02 1.78E-04 9

759 6.OOE-03 13 1.37E-02 8.22E-05 11.7 2.10E-02 1.26E-04 10 848 4.00E-03 13 1.37E-02 5.48E-05 11.7 2.1OE-02 8.42E-05 11 938 3.00E-03 12.7 1.51E-02 4.54E-05 11.0 2.65E-02 7.95E-05 12 1028 2.00E-03 12.3 1.73E-02 3.45E-05 10.5 3.13E-02 6.25E-05 13 1118 1.00E-03 12.3 1.73E-02 1.73E-05 10.5 3.13E-02 3.13E-05 14 1208 1.OOE-03 11.7 2.10E-02 2.10E-05 10.2 3.45E-02 3.45E-05 15 1462 1.OOE-03 11 2.65E-02 2.65E-05 9.7 4.07E-02 4.07E-05 Total 1.33E-03 Total 2.53E-03 NEDC 08-041 Table 13: Time to Abandonment Probability Analysis for Case 8 (Natural Ventilation)

Transient Cohbustibies se

,.-__'-E__SEDUS_.

Bin HRR [kW.]

.SF,.-

Tim j

Fr, 7

238 3.50E-02 25 2.61E-04 9.14E-06 1.OOE-03 3.50E-05 8

275 2.OOE-02 21.7 7.76E-04 1.55E-05 1.OOE-03 2.OOE-05 9

312 1.20E-02 20.8 1.04E-03 1.25E-05 1.04E-03 1.25E-05 10 349 7.OOE-03 19.2 1.77E-03 1.24E-05 1.77E-03 1.24E-05 11 386 4.OOE-03 16.3 4.61E-03 1.84E-05 4.61E-03 1.84E-05 12 423 2.OOE-03 15.2 6.63E-03 1.33E-05 6.63E-03 1.33E-05 13 460 1.OOE-03 14.3 8.92E-03 8.92E-06 8.92E-03 8.92E-06 14 497 1.OOE-03 13.8 1.05E-02 1.05E-05 1.05E-02 1.05E-05 15 578 1.OOE-03 12.8 1.46E-02 1.46E-05 1.46E-02 1.46E-05 Total 1.15E-04 Total 1.46E-04 The following revised tables from Calculation NEDC 08-041 provide the calculated severity factors and probabilities of non-suppression for MCR Abandonment with mechanical ventilation:

NLS2013032 Attachment Page 4 of 39 NEDC 08-041 Table 21: Time to Abandonment Probability Analysis for Case 5 (Mechanical Ventilation)

Electrical Cabinets Cse 5 REVISEDVALUES-,,

Bin HRR[KW]

SF Time'

.SFP"Al p

2 197 1.55E-01 N/A 24.5 1.00E-03 1.55E-04 3

337 8.1OE-02 21.8 7.51E-04 6.08E-05 19.7 1.50E-03 1.22E-04 4

475 4.70E-02 18.7 2.09E-03 9.82E-05 17.2 3.43E-03 1.61E-04 5

612 2.90E-02 16.3 4.61E-03 1.34E-04 15.8 5.44E-03 1.58E-04 6

749 1.80E-02 15.2 6.63E-03 1.19E-04 15.3 6.42E-03 1.15E-04 7

886 1.1OE-02 13.5 1.16E-02 1.28E-04 12.8 1.46E-02 1.61E-04 8

1024 7.OOE-03 12.8 1.46E-02 1.02E-04 12.5 1.62E-02 1.13E-04 9

1162 5.00E-03 12.5 1.62E-02 8.08E-05 12.3 1.73E-02 8.63E-05 10 1299 3.00E-03 12.3 1.73E-02 5.18E-05 11.7 2.1OE-02 6.31E-05 11 1436 2.00E-03 11.8 2.04E-02 4.07E-05 11.2 2.48E-02 4.96E-05 12 1573 1.OOE-03 11.3 2.40E-02 2.40E-05 11.2 2.48E-02 2.48E-05 13 1710 1.OOE-03 11.2 2.48E-02 2.48E-05 10.8 2.83E-02 2.83E-05 14 1847 1.00E-03 10.8 2.83E-02 2.83E-05 10.5 3.13E-02 3.13E-05 15 2276 1.OOE-03 10.5 3.13E-02 3.13E-05 10.0 3.69E-02 3.69E-05 Total 9.24E-04 Total 1.31 E-03 NEDC 08-041 Table 22: Time to Abandonment Probability Analysis for Case 2 (Mechanical Ventilation)

,-Electrical Cabin ts -9ase 2 i.

I iR,E V A LUES Bin -

HRR [kW][

ýM SF" T

SF.Rrn Tie.n

---"**A 2

130 2.02E-01 N/A 24.5 1.OOE-03 2.02E-04 3

221 1.13E-01 21.8 7.51E-04 8.49E-05 19.7 1.50E-03 1.70E-04 4

310 6.70E-02 21.8 7.51E-04 5.03E-05 19.7 1.50E-03 1.01E-04 5

400 4.10E-02 18.7 2.09E-03 8.57E-05 17.2 3.43E-03 1.41E-04 6

490 2.60E-02 16.3 4.61E-03 1.20E-04 15.8 5.44E-03 1.41E-04 7

579 1.60E-02 16.3 4.61 E-03 7.38E-05 15.8 5.44E-03 8.70E-05 8

669 1.OOE-02 15.2 6.63E-03 6.63E-05 15.3 6.42E-03 6.42E-05 9

759 6.OOE-03 13.5 1.16E-02 6.97E-05 12.8 1.46E-02 8.78E-05 10 848 4.OOE-03 13.5 1.16E-02 4.65E-05 12.8 1.46E-02 5.86E-05 11 938 3.OOE-03 12.8 1.46E-02 4.39E-05 12.5 1.62E-02 4.85E-05 12 1028 2.OOE-03 12.5 1.62E-02 3.23E-05 12.3 1.73E-02 3.45E-05 13 1118 1.OOE-03 12.5 1.62E-02 1.62E-05 12.3 1.73E-02 1.73E-05 14 1208 1.OOE-03 12.3 1.73E-02 1.73E-05 11.7 2.1OE-02 2.10E-05 15 1462 1.OOE-03 11.3 2.40E-02 2.40E-05 11.2 2.48E-02 2.48E-05 Total 7.31 E-04 Total 1.20E-03

NLS2013032 Attachment Page 5 of 39 NEDC 08-041 Table 23: Time to Abandonment Probability Analysis for Case 8 (Mechanical Ventilation) lransgri t~m tb!e Cae.,

-B n-: -,

s

-- a :.

s,.

~...-

12 423 2.OOE-03 22.5 5.96E-04 1.19E-06 1.OOE-03 2.OOE-06 13 460 1.OOE-03 22.5 5.96E-04 5.96E-07 1.OOE-03 1.OOE-06 14 497 1.OOE-03 21.3 8.86E-04 8.86E-07 1.OOE-03 1.OOE-06 15 578 1.00E-03 15.2 6.63E-03 6.63E-06 6.63E-03 6.63E-06 Total 9.31 E-06 Total 1.06E-05 The quantitative impacts on the risk measures (Core Damage Frequency (CDF), Large Early Release Frequency (LERF), ACDF, and ALERF) are minor and have no effect on conclusions.

The results of a sensitivity analysis (CDF, LERF, ACDF, and ALERF) using Pn, no lower than 1.OE-03 and the revised non-suppression probabilities based on the new abandonment times determined in the response to Fire Modeling RAI 02d, are provided in the table below:

Risk with Base Non-Suppression Risk with Revised Non-Suppression Probabilities Probabilities

(/yr)

(/yr)

Total CDF 4.77E-05 Total CDF 4.78E-05 Total LERF 8.71 E-06 Total LERF 8.83E-06 ACDF

-1.18E-05 ACDF

-1.18E-05 ALERF

-1.48E-05 ALERF

-1.48E-05 Request: PRA RAI-07, 08, 09, 10, a1 a

NPPD Response:

These RAIs were addressed in the 60-day and 90-day responses.

Request: PRA 1 lb Transient Fire Modeling at Pinch Points Per Section 11.1.5.6 of NUREG/CR-6850, transient fires should at a minimum be placed in locations within the plant physical access units (PA Us) where critical targets are located, such as where CCDPs are highest for that PA U (i.e., at "pinch points'). Pinch points include locations of redundant trains or the vicinity of other potentially risk-relevant equipment, including the cabling associated with each. Transient fires should be placed at all appropriate locations in a PA U where they can threaten pinch points. Hot work should be assumed to occur in locations where hot work is a possibility, even if improbable (but not impossible), keeping in mind the same philosophy.

NLS2013032 Attachment Page 6 of 39

b.

Relative to the MCR, please provide an assessment of the impact on the PRA results (CDF, LERF, AzCDF, zILERF) ofplacing transients behind the open-back MCBs and back panels.

NPPD Response:

b.

Transient fires were not postulated in the MCR Analysis (NEDC 10-001). Transient fires near the Main Control Board (MCB) and MCR electrical cabinets, whether opened back or closed back, that damage PRA targets are considered very unlikely due to the MCR layout and continuous occupancy.

An assessment of the impact to CDF, LERF, ACDF, and ALERF was performed by developing transient scenarios for potential fires located at the MCB and MCR electrical cabinet "pinch points." It was assumed for these scenarios that all PRA components in the exposed panels fail. Seven transient fire scenarios were developed.

The following table provides the impact on the PRA of this assessment:

Risk without MCR Transient Risk with MCR Transient Fire Scenarios (/yr)

Fire Scenarios (Iyr)

Total CDF 4.77E-05 Total CDF 4.91 E-05 Total LERF 8.71 E-06 Total LERF 1.OOE-05 ACDF

-1.18E-05 ACDF

-1.18E-05 ALERF

-1.48E-05 ALERF

-1.48E-05 The assessment incorporated corrections made to the fire PRA model after LAR submittal for several scenarios in Fire Area TB-A and the correction of the human failure event inconsistencies discussed in the response to PRA RAI-16e. The results of this assessment indicate a small change to total CDF/LERF, and no change in delta risk.

Request: PRA RAI-12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, and 34 NPPD Response:

These RAIs were addressed in the 60-day and 90-day responses.

NLS2013032 Attachment Page 7 of 39 Radioactive Release (RR)

Request: RR RAI 01, 02, and 03 NPPD Response:

These RAIs were addressed in the 60-day and 90-day responses.

Monitoring Program Request: Monitoring Program RAI 01, 02, 03, 04, and 05 NPPD Response:

These RAIs were addressed in the 60-day response.

Programmatic Request: Programmatic RAI 01, 02, 03, 04, 05, 06, and 07 NPPD Response:

These RAls were addressed in the 60-day response.

Fire Modeling Request: Fire Modeling RAI 01 and 02a NPPD Response:

These RAls were addressed in the 60-day and 90-day responses.

Request: Fire Modeling RAI 02 (continued)

Section 4.5.1.2, "Fire PRA" of the Transition Report states that fire modeling was performed as part of the Fire PRA development (NFPA 805, Section 4.2.4.2). Reference is made to Attachment J, "Fire Modeling V& V, "for a discussion of the verification and validation (V& V) of the fire models that were used. Furthermore, Section 4.7.3, "Compliance with Quality Requirements in Section 2.7.3 of NFPA 805," of the Transition Report states that "Calculational models and numerical methods used in support of compliance with 10 CFR 50.48(c) were verified and validated as required by Section 2.7.3.2 of NFPA 805."

NLS2013032 Attachment Page 8 of 39 Regarding the V& V offire models:

b.

For V& V of the aforementioned algebraic models, reference is made to NUREG-1824, "Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications." Please provide technical details to demonstrate that the algebraic models have been applied within the validated range of input parameters, or to justify the application of the equations outside the validated range reported in NUREG-1824.

NPPD Response:

b.

In most cases, the Detailed Fire Modeling Workbooks have been applied within the validated range reported in NUREG-1824. In cases where the models have been applied outside the validated range reported in NUREG-1824, these have been justified as acceptable, either by qualitative analysis, or by quantitative sensitivity analysis.

Technical details demonstrating the models are within range, as well as any justification of models outside the range, are documented below:

Validation of NUREG-1805 Fire Dynamics Tool (FDT) Models The following NUREG-1805 fire models were used at Cooper Nuclear Station (CNS):

" Flame Height (Method of Heskestad)

Plume Centerline Temperature (Method of Heskestad)

" Radiant Heat Flux (Point Source Method)

" Hot Gas Layer (Method of MQH)

" Hot Gas Layer (Method of Beyler)

Hot Gas Layer (Method of Foot, Pagni and Alvares [FPA])

" Ceiling Jet Temperature (Method of Alpert)

" Smoke Detection Actuation Correlation (Method of Heskestad and Delichatsios)

" Fixed Temperature Heat Detection Response Time Correlation

" Sprinkler Response Time Correlation To demonstrate that the analyses using the Detailed Fire Modeling Workbooks (based on the NUREG-1 805 FDTs) were performed within the validated range of NUREG-1 824, as shown in Table 2-4 and 2-5 of the aforementioned document, a discussion is provided below to analyze each relevant normalized parameter. The parameters below, where applicable, show that these models were used within the range of its validity as described in NUREG-I1824, or the use of the models outside the verification and validation range is justified.

NLS2013032 Attachment Page 9 of 39 Fire Froude Number

1) Within the validated range (0.4-2.4):

a. 211 kW Fixed Source: The calculated Fire Froude Number for a typical 211 kW fixed source electrical fire postulated at CNS using a fire diameter of 0.57 meters is 0.76. This calculated value is within the validated range of NUREG-1824.

b. 317 kW Transient Source: The calculated Fire Froude Number for a 317 kW transient fire postulated at CNS using a fire diameter of 0.69 meters is 0.73. This calculated value is within the validated range of NUREG-1824.

2) Below the validated range (<0.4):

a. The Fire Froude Number is predominately used to validate the use of a model to calculate plume temperatures and flame heights of a given fire scenario (NUREG-1934, "Nuclear Power Plant Fire Modeling Analysis Guidelines (NPP FIRE MAG)," November 2012, Section 2.3.7.1). For fires below the validation range, the plume temperature and flame height may be under-predicted. At CNS, fixed ignition sources using a 69 kW heat release rate (HRR), 7 5 th percentile HRR (142 kW) transient fires, and transient fires modeled as 69 kW fires, result in Fire Froude Numbers below the validated range. Conservatisms have been identified for these cases, including the screening criteria used with respect to damage temperatures and heat fluxes (i.e., 330'C temperature damage and 11 kW/m2 heat flux damage):

i. 69 kW Fixed Source: A 69 kW fire with a fire area of 2.78 ft2 yields a Fire Froude Number slightly below the validated range. To calculate a Fire Froude Number that is within the validated range, the fire area can be decreased. For a 69 kW fire, the fire area must be less than or equal to 1.89 ft2 to be within the validated range. Decreasing the fire area to 1.89 ft2 results in an 11% (4.1 inch) increase in the plume zone of influence (ZOI) and a 15% (4.1 inch) increase in flame height.

To compensate for this increase, safety margin is built into the plume calculation by utilizing a 0.7 convective HRR fraction. The recommended value for convective HRR fraction is between 0.6 and 0.65 per the Society of Fire Protection Engineers (SFPE) Handbook of Fire Protection Engineering.

Calculating the plume ZOI with a 0.6 convective HRR fraction using FDT 09 reduces the plume ZOI by 6.6% (2.4 inches).

The 69 kW fixed ignition source fires that employed the plume ZOI or flame height correlations were, in all cases, transformers, motors, and small electrical panels such as distribution panels and switches containing limited quantities of cable insulation. The 69 kW fire is the 9 8 th percentile HRR from

NLS2013032 Attachment Page 10 of 39 NUREG/CR-6850 for the transformers and motors, and the 7 5th percentile fire for electrical panels. This is considered a conservative HRR for these ignition sources and provides safety margin. Additional safety margin is provided in scenarios of this type by selecting the fire elevation as the top of the ignition source. This is considered conservative, since the combustion process will occur where the fuel mixes with oxygen, which is not always at the top of the highest vent. Furthermore, conservative screening damage criteria were used with respect to damage temperatures and heat fluxes (i.e., 330'C temperature damage and 11 kW/m2 heat flux damage). The multiple sources of safety margin are significant enough to offset the possible 4.1 inch under-prediction resulting from analyzing a fire outside the validation range for the Fire Froude Number parameter.

ii.

142 kW Transient Fire: Transient fires in Fire Zones 8B, 8C, 8E, 8F, 8G and 8H, analyze a 142 kW fire with a fire area of 4.0 ft2, which yields a Fire Froude Number slightly below the validated range. To calculate a Fire Froude Number that is within the validated range, the fire area can be decreased. For a 142 kW fire, the fire area must be less than or equal to 3.36 ft2 to be within the validated range. Decreasing the fire area to 3.36 ft2 results in a 4.4% (2.3 inch) increase in the plume ZOI and a 6.1% (2.4 inch) increase in flame height.

To compensate for this increase, safety margin is built into the plume calculation by utilizing a 0.7 convective HRR fraction. The recommended value for convective HRR fraction is between 0.6 and 0.65 per the SFPE Handbook of Fire Protection Engineering. Calculating the plume ZOI with a 0.6 convective HRR fraction using FDT 09 reduces the plume ZOI used in the fire modeling by 6.5% (3.4 inches). Therefore, using a convective HRR fraction of 0.7 provides 6.5% margin of safety in the output to the plume ZOI calculation, enough to compensate for an increase of 4% when the Fire Froude Number is brought into the validated range.

Additional safety margin is provided in scenarios of this type by selecting a fire elevation as 2.0 ft above the fixed floor when many transient fires occur at floor level. The safety margin with respect to fire elevation alone is sufficient to compensate for a 2.4 inch increase in plume or flame ZOI. Another item adding to the safety margin for transient fires is the use of a large bounding transient zone that assumes all targets within its ZOI are affected by a fire.

Time to damage is calculated based on the most severe (closest) target. This is considered conservative, since a transient fire would actually have a much smaller ZOI and varying damage times. Further safety margin is provided by using screening criteria with respect to damage temperatures and heat fluxes (i.e., 330'C temperature damage and 11 kW/m2 heat flux damage). The multiple sources of safety margin are significant enough to offset the possible

NLS2013032 Attachment Page 11 of 39 under-prediction of 2.4 inches resulting from analyzing a fire outside the validation range for the Fire Froude Number parameter.

iii. 69 kW Transient Source: Transient fires in Fire Zones 8A and 9A analyze a 69 kW fire with a fire area of 4.0 ft2, which yields a Fire Froude Number slightly below the validated range. To calculate a Fire Froude Number that is within the validated range, the fire area can be decreased. For a 69 kW fire, the fire area must be less than or equal to 1.89 ft2 to be within the validated range. Decreasing the fire area to 1.89 ft2 results in a 27% (8.6 inch) increase in the plume ZOI and a 38% (8.6 inch) increase in flame height.

To compensate for this increase, safety margin is built into the plume calculation by utilizing a 0.7 convective HRR fraction. The recommended value for convective HRR fraction is between 0.6 and 0.65 per the SFPE Handbook of Fire Protection Engineering. Calculating the plume ZOI with a 0.6 convective HRR fraction using FDT 09 reduces the plume ZOI used in the fire modeling by 7.9% (2.5 inches).

Added safety margin is provided in scenarios of this type by selecting a fire elevation at 2.0 ft above the fixed floor when many transient fires occur at floor level. The safety margin with respect to fire elevation alone is sufficient to compensate for an 8.6 inch increase in plume or flame ZOL. Another item adding to the safety margin for transient fires is the use of a large bounding transient zone that assumes all targets within its ZOI are affected by a fire.

Time to damage is calculated based on the most severe (closest) target. This is considered conservative, since a transient fire would actually have a much smaller ZOI and varying damage times. Further safety margin is provided by using screening criteria with respect to damage temperatures and heat fluxes (i.e., 330'C temperature damage and 11 kW/m2 heat flux damage). The multiple sources of safety margin are significant enough to offset the possible under-prediction of 8.6 inches resulting from analyzing a fire outside the validation range for the Fire Froude Number parameter.

3) Above the validated range (>2.4):

a. Fires which propagate to secondary combustibles: For all fires that propagate to secondary combustibles, fire conditions are calculated assuming a nominal base area which is smaller than the area of the ignition source. This created a scenario where flames emanate from a small spot on top of the cabinet. The "base" serves as the area of the fire for the full duration of the fire scenario. This assumption results in a higher value for the Fire Froude Number than would be calculated if it were assumed that the fire bums over the actual surface area of the ignition source and associated secondary combustibles (e.g., cable trays or adjacent cabinet sections). The use of this approach results in a more severe fire plume and subsequently a conservative estimation of the ZOI for the fire conditions.

NLS2013032 Attachment Page 12 of 39 Therefore, a Fire Froude Number above the validated range leads to more conservative results.

Flame Length Relative to the Ceiling Height The primary application of this parameter is to determine if the flame length exceeds the ceiling height. The fires at CNS are within the validated range of NUREG-1824 (0.2-1.0) or justified otherwise:

1) Below the validated range (<0.2): When the ratio of flame length relative to the ceiling height is less than 0.2, the flame length does not exceed the ceiling height.

For models of this nature at CNS (i.e., small fires in fire zones with high ceilings) target impact sets are determined to fail based on plume temperatures, radiant heat, and hot gas layer (HGL) formation. These modes of failure are used in lieu of ceiling jet. The high ceiling mitigates any substantial ceiling jet from forming because, by nature of being below the validated range, a small fire is being considered:

a. Plume temperatures and radiant heat: Failure of targets based on these criteria is considered regardless of ceiling height. Ceiling height does not factor into determining the plume or radiant heat ZOI and, therefore, use of this parameter below the validated range is justified.

b. HGL formation: Although the HGL formation does consider ceiling height, by nature of being below the validated range, the fire being considered to calculate the ratio is not large enough to create a damaging HGL.

2) Above the validated range (>1.0): NUREG-1934, states that if the HGL temperature is not a significant source of heat flux to a target, then the significance of this parameter could decrease in the case of a target temperature calculation, provided the target distance is within the validated parameter space (i.e. not too close). For fire modeling at CNS, the HGL is not a significant source of heat flux to targets. Heat fluxes to determine target impacts are calculated using the point source model. The radiant heat flux ZOI calculated using this point source model extends horizontally further than the flame length extends horizontally on the ceiling. This ZOI calculated using the point source model was applied to determine target damage from the floor to the top of the flame. Because the horizontal ZOI calculated by the point source model extends further than the flames on the ceiling for fire scenarios at CNS, using the point source model bounds the potential for heat flux emanating from an HGL affecting a target set.

Ceiling Jet Radial Distance Relative to the Ceiling Height Ceiling jet temperature and velocity correlations use this ratio to express the horizontal distance from a target to the plume. Most of the ratio's applications include determination of time to detection and sprinkler activation in which the ceiling jet

NLS2013032 Attachment Page 13 of 39 velocity is a sub-model in the analysis. At CNS, the Alpert ceiling jet correlation was used to calculate detection and suppression timing. Visual inspections were performed during fire modeling walkdowns to ensure that this correlation was applied for detection and suppression timing when there were no major obstructions (e.g., beam pockets, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector or sprinkler being credited.

Detection activation times were calculated for a number of fire scenarios using FDT 10 of NUREG-1805. The FDT 10 calculation uses the Alpert ceiling jet correlation in addition to a correlation that accounts for the time required for the detector to respond. The ceiling jet velocity is a sub-model in the analysis.

The ceiling jet correlation is valid for an r/H value in the range of 1.2 to 1.7 in NUREG-1824. Consistent with NUREG-1805, the "r" value is the radial distance to the detector, while "H" is the height of the ceiling above the top of the fuel source (i.e., the fire elevation). NUREG-1934 cautions that the ceiling jet application must be carefully evaluated in commercial nuclear power plants for possible obstructions near the ceiling (e.g., cable trays, HVAC ducts, piping, etc.) that may disrupt the ceiling jet and invalidate the model. Otherwise, NUREG-1934 suggests a sensitivity analysis may be performed by moving the fire location to distances that fall within the validated range. However, the guidance in NUREG-1934 acknowledges that this may not be possible in certain fire scenarios involving fixed ignition sources or critical target locations.

For detection activation, Heskestad and Delichatsios determined that an increase in temperature of 10°C (18°F) above ambient temperature corresponded to a significant enough increase in optical density to cause smoke detector activation. The method of Alpert is used to determine the temperature within the ceiling jet. The temperature to smoke obscuration correlation is discussed and detailed within Chapter 4-1 of the 4 th edition of the SFPE Handbook of Fire Protection Engineering, NUREG-1805, Chapter 11, as well as NUREG-1934, Appendix B. The correlation was used within the following limitations:

0 The fires analyzed are steady state.

0 The forced ventilation system is not considered when calculating detection times using this method.

• Walkdowns were performed to ensure that the overhead area is not highly obstructed.

• The correlation was applied when detectors are located at or very near to ceiling.

Very near to the ceiling included code compliant detectors mounted on the bottom flange of structural steel beams, where applicable. This method is not applied to detectors mounted well below the ceiling in free air.

The table below presents the ceiling jet radial distance relative to the ceiling height normalized parameter for each scenario that employs the NUREG-l1805 FDT 10 detection correlation. The parameter, where applicable, shows that the correlation was

NLS2013032 Attachment Page 14 of 39 used within the range of its validity (1.2-1.7) as described in NUREG-1824, or the use of the correlation outside of the verification and validation range is justified.

Fir e I

ign!t"°.Sou e..

(ft lH" n

A RB 1A CS-P-A (Large Oil) 6 22 0.3 The ratios calculated for the scenarios in Fire Zone 1-A are below the validated range. However, RB 1A CS-P-A (Small Oil) 6 22 0.3 detection activation time is not critical to the analyses. Automatic detection timing was RB 1A CS-P-A (Electrical) 6 12.42 0.5 calculated, however, it is not credited to prevent RCIC-TU-TURB damage to any targets in these scenarios and (Large Oil) further evaluation is not required.

RB 1A RCIC-TU-TURB 3

22 0.1 (Small Oil)

RB 1A RCIC-TU-TURB 3

16.09 0.2 (Electrical)

RB 1A Transient 8

20 0.4 RB 1B CS-P-B (Large Oil) 6 22 0.3 The ratios calculated for the scenarios in Fire Zone 1B are below the validated range. However, RB 1 B CS-P-B (Small Oil) 6 22 0.3 detection activation time is not critical to the analyses. Automatic detection timing was calculated, however, it is not credited to prevent RB 1B CS-P-B (Electrical) 6 12.25 0.5 damage to any targets in these scenarios and I further evaluation is not required.

RB 1 D RHR-P-B (Large Oil) 6 22 0.3 The ratios calculated for the scenarios in Fire Zone 1D are below the validated range. However, RB 1 D RHR-P-B (Small Oil) 6 22 0.3 detection activation time is not critical to the analyses. Automatic detection timing was RB 1D RHR-P-B (Electrical) 6 12.42 0.5 calculated, however, it is not credited to prevent 1D R

D (Large_ Oil) 6 22 0.3damage to any targets in these scenarios and RB 1 D RHR-P-D (Large Oil) 6 22 0.3 further evaluation is not required.

RB 1D RHR-P-D (Small Oil) 6 22 0.3 RB 1D RHR-P-D (Electrical) 6 12.42 0.5 RB 1D Transient 8

20 0.4 RB 1G CRD-P-A, -B (Large 11.6 21.8 0.5 The ratios calculated for the scenarios in Fire Zone Oil) 1 G are below the validated range. However, RB 1G CRD-P-A, -B (Small 11.6 21.8 0.5 detection activation time is not critical to the Oil) analyses. Automatic detection timing was calculated, however, it is not credited to prevent RB 1G CR0-P-A, -B 11.6 17.9 0.6 damage to any targets in these scenarios and (Electrical) further evaluation is not required.

The ratio calculated for Scenario HPI-CS-RB3 in Fire Zone 2C is below the validated range.

However, detection activation time is not critical to RB 2C HPI-CS-RB3 16.5 20.2 0.8 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further I_

evaluation is not required.

Scenario EE-SWGR-4160F (15a) in Fire Zone 3A falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, EE-SWGR-4160F HVAC ducts, piping, etc.) located in the ceiling jet (15a) between the plume and the detector being credited.

Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 6 feet and the vertical distance measuring 8 feet. Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use

NLS2013032 Attachment Page 15 of 39 Fire Fire

'ignition §ou r

't" Compartment r (ft)

.(ft)

H Justification of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

The ratio calculated for Scenario EE-SWGR-4160F (15b) HEAF in Fire Zone 3A is below the validated EE-SWGR-4160F range. However, detection activation time is not RB-J 3A (1W5b)

HEAF 6

8 0.8 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario EE-SWGR-480F (15a) in Fire Zone 3A is below the validated range.

EE-SWGR-480F However, detection activation time is not critical to RB-J 3A (I15a) 5.33 8

0.7 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario EE-SWGR-480F

-(15b) HEAF in Fire Zone 3A is below the validated EE-SWGR-480F range. However, detection activation time is not RB-J 3A (15b) HEAF 5.33 8

0.7 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

Scenario EE-XFMR-480F in Fire Zone 3A falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

RB-J 3A EE-XFMR-480F 5.33 8

0.7 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 5.33 feet and the vertical distance measuring 8 feet. Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

The transient scenarios in Fire Zone 3A fall below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

Additionally, the worst case (i.e., farthest unoccupied floor area from the detector) transient fire location was used to calculate detection time. A RB-J 3A Transient 15 14 1.1 horizontal distance (r) measuring 15 feet and a vertical distance measuring 14 feet was conservatively assumed for all transient scenarios.

Considering the horizontal distance will be closer to the detector than the assumed 15 feet, the calculated time to detection is conservative for the transient scenarios. Due to proximity of the detectors to the transient fire crediting detection and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H values are slightly below the validated range.

NLS2013032 Attachment Page 16 of 39

• Fire Fire stfcio Compartment ZoFe Ignition Source r (ft)

H (ft) rlH JurStifiCation Scenario EE-SWGR-4160G (15a) in Fire Zone 3B falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet EE-SWGR-4160G between the plume and the detector being credited.

RB-K 3B (11 5a) 6 8

0.8 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 6 feet and the vertical distance measuring 8 feet. Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

The ratio calculated for Scenario EE-SWGR-4160G (15b) HEAF in Fire Zone 3B is below the validated EE-SWGR-4160G range. However, detection activation time is not RB-K 3B (15b) HEAF 6

8 0.8 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

Scenario EE-SWGR-480G (15a) in Fire Zone 3B falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet EE-SWGR-480G between the plume and the detector being credited.

RB-K 3B (11R5a) 5.33 8

0.7 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 5.33 feet and the vertical distance measuring 8 feet. Considering the dose proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

The ratio calculated for Scenario EE-SWGR-480G (15b) HEAF in Fire Zone 3B is below the validated EE-SWGR-480G range. However, detection activation time is not RB-K 3B (15b) HEAF 5.33 8

0.7 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario EE-XFMR-480G in Fire Zone 3B is below the validated range.

However, detection activation time is not critical to RB-K 3B EE-XFMR-480G 5.33 8

0.7 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further I_

I I evaluation is not required.

The ratio calculated for the transient scenarios in Fire Zone 3B is below the validated range.

However, detection activation time is not critical to RB-K 3B Transient 15 14 1.1 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the transient scenarios and further evaluation is not required.

NLS2013032 Attachment Page 17 of 39 Fire Fire Ignition Source r (ft)

H (ift) rlH Justification

'Compartment Zon e I..

The ratios calculated for the transient scenarios in Fire Zone 3C are below the validated range.

However, detection activation time is not critical to RB 3C Transient 20 24 0.8 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the transient scenarios and further evaluation is not required.

RB 4

RWCU-P-PP (Large 10.8 18 0.6 The ratios calculated for the scenarios in Fire Zone Oil) 4C are below the validated range. However, RWCU-P-PP (Small detection activation time is not critical to the Oil) analyses. Automatic detection timing was RWCU-P-PP calculated, however, it is not credited to prevent RB 4C Rlctrcl 10.8 15.5 0.7 damage to any targets in these scenarios and (Electrical) further evaluation is not required.

RRLO-P-The ratios calculated for the fixed ignition source RB 4D A1,A2,A3,B1,B2,B3 10 18 0.6 scenarios in Fire Zone 4D are below the validated (Large Oil) range. However, detection activation time is not RRLO-P-critical to the analyses. Automatic detection timing RB 4D A1,A2,A3,B1,B2,B3 10 18 0.6 was calculated, however, it is not credited to (Small Oil) prevent damage to any targets in these scenarios RRLO-P-and further evaluation is not required.

RB 4D A1,A2,A3,B1,B2,B3 10 18 0.6 (Electrical)

The transient scenarios in Fire Zone 4D fall below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

Additionally, the worst case (i.e., farthest unoccupied floor area from the detector) transient fire location was used to calculate detection time. A RB 4D Transient 16 16 1.0 horizontal distance (r) measuring 16 feet and a vertical distance measuring 16 feet was conservatively assumed for all transient scenarios.

Considering the largest horizontal distance a transient impacting FPRA components could occur is approximately 10 feet for the detector, the calculated time to detection is conservative. Due to close proximity of the detector to the transient fires crediting detection and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H values are slightly below the validated range.

The ratio calculated for Scenario LRP-PNL-02-184-A in Fire Zone 5B is above the validated range.

Automatic detection timing was calculated, RB 5B LRP-PNL-02-184-A 8.75 4.25 2.1 however, only automatic suppression timing is critical to the analysis and the smoke detection system is not credited to prevent damage to any targets in the scenario. Further evaluation is not required.

The ratio calculated for Scenario LRP-PNL-02-184-B in Fire Zone 5B is above the validated range.

Automatic detection timing was calculated, RB 5B LRP-PNL-02-184-B 33.4 4.25 7.9 however, only automatic suppression timing is critical to the analysis and the smoke detection system is not credited to prevent damage to any targets in the scenario. Further evaluation is not required.

NLS2013032 Attachment Page 18 of 39 Fire Fire-C prment Ze Ignition Source r (ft)

H (ft)

'/H Justifi.cation Compartment Zone The ratio calculated for Scenario LRP-RACK-LIR-HV-R-FP in Fire Zone 5B is above the validated LRP-RACK-LIR-HV-range. However, detection activation time is not RB 5B R-FP 26 6

4.3 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario RMV-RM-3 in Fire Zone 5B is above the validated range. However, detection activation time is not critical to the RB 5B RMV-RM-3 20 6.58 3.0 analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

RRMG-GEN-MGA The ratios calculated for Scenario RRMG-GEN-(Large Oil)

MGA in Fire Zone 5B are below the validated range. Automatic detection timing was calculated, RB 5B RRMG-GEN-MGA 0

13.7 0.0 however, only automatic suppression timing is (Small Oil) critical to the analysis and the smoke detection RRMG-GEN-MGA

_system is not credited to prevent damage to any RB 5B RRMG(GEN-MGA 0

3.83 0.0 targets in the scenario. Further evaluation is not (Electrical) required.

RRMG-GEN-MGB The ratios calculated for Scenario RRMG-GEN-RB 5B Rrge 8.75 12.7 0.7 MGB in Fire Zone 5B are outside the validated (Large Oil) range. Automatic detection timing was calculated, RRMG-GEN-MGB however, only automatic suppression timing is RB SB (Small Oil) 8.75 12.7 0.7 critical to the analysis and the smoke detection system is not credited to prevent damage to any RB 5B RRMG-GEN-MGB 8.75 2.87 3.0 targets in the scenario. Further evaluation is not (Electrical) required.

The transient scenarios in Fire Zone 5B fall below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

Additionally, the worst case (i.e., farthest unoccupied floor area from the detector) transient fire location was used to calculate detection time. A RB 5B Transient 16.7 23 0.7 horizontal distance (r) measuring 16.7 feet and a vertical distance measuring 23 feet was conservatively assumed for all transient scenarios.

Considering the horizontal distance will be closer to the detector than the assumed 16.7 feet, the calculated time to detection is conservative for the transient scenarios. Due to proximity (detection is provided directly above Transient Scenario 5) of the detector to the transient fire crediting detection and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H values are slightly below the validated range.

SA-CPSR-A (Large 1.0 The ratios calculated for the scenarios in Fire Zone oil) 7A are below the validated range. However, GB-A 7A SA-CPSR-A (Small 20 20.25 1.0 detection activation time is not critical to the Oil) analyses. Automatic detection timing was SA-CPSR-B (Large calculated, however, it is not credited to prevent oil) damage to any targets in these scenarios and GB-A 7A SA-CPSR-B (Small 20 20.25 further evaluation is not required.

Oil)

CB-A 7A SA-CPSR-C (Large 20 20.25 1.0 Oil)

__0

NLS2013032 Attachment Page 19 of 39

..Fire Fire Ignition Source ir (ft)

H (ft) rH JUtification Compartment Zone CB-A 7A SA-CPSR-C (Small 20 20.25 1.0 Oil)

CB-A 7A SW-P-BPA (Large 16.33 20.25 0.8 Oil)

CB-A 7A SW-P-BPA (Small 16.33 20.25 0.8 Oil)

CB-A 7A SW-P-BPA 16.33 15.17 1.1 (Electrical)

CB-A 7A SW-P-BPB (Large 16.33 20.25 0.8 Oil)

CB-A 7A SW-P-BPB (Small 16.33 20.25 0.8 Oil)

CB-A 7A SW-P-BPB 16.33 15.17 1.1 (Electrical)

CB-A 7A SW-P-BPC (Large 16.33 20.25 0.8 Oil)

CB-A 7A SW-P-BPC (Small 16.33 20.25 0.8 Oil)

CB-A 7A SW-P-BPG 16.33 15.17 1.1 (Electrical)

CB-A 7A SW-P-BPD (Large 16.33 20.25 0.8 Oil)

CB-A 7A SW-P-BPD (Small 16.33 20.25 0.8 Oil)

CB-A 7A SW-P-BPD 16.33 15.17 1.1 (Electrical)

CB-A 7A Transient 15 18 0.8 Scenario LRP-PNL-C22 in Fire Zone 8A falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-G 8A LRP-PNL-C22 5.2 6.5 0.8 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 5.2 feet and the vertical distance measuring 6.5 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

Scenario RPS-CC-RPSB in Fire Zone 8B falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-C 8B RPS-CC-RPSB 5.75 5.2 1.1 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 5.75 feet and the vertical distance measuring 5.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

The calculated normalized parameter for this G

B Ts 1

1 1

scenario is within the validated range.

NLS2013032 Attachment Page 20 of 39 Fire Fire Compartment Zone Ignition Source (ft),

(ft) 'H Jusficfion Scenario RPS-CC-RPSA in Fire Zone 8C falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-A 8C RPS-CC-RPSA 5.75 5.2 1.1 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 5.75 feet and the vertical distance measuring 5.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

The ratios calculated for the transient scenarios in Fire Zone 8C are below the validated range.

However, detection activation time is not critical to CB-A 8C Transient 11.3 11 1.0 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the transient scenarios and further evaluation is not required.

The calculated normalized parameter for this GB-A 8D EE-CHG-125 10 7.6 6.1 1.2 scenario is within the validated range.

The calculated normalized parameter for this scenario is within the validated range.

Scenario EE-BAT-125 1A in Fire Zone 8E falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-A-1 BE EE-BAT-125 1A 6.58 8.75 0.8 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 6.58 feet and the vertical distance measuring 8.75 feet.

Considering the close proximity of the detector to the.fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

The ratio calculated for Scenario EE-BAT-250 1A in Fire Zone BE is below the validated range.

However, detection activation time is not critical to CB-A-1 8E EE-BAT-250 1A 8

8.75 0.9 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The calculated normalized parameter for this GB3-A-i BE EE-PNL-A 10 6.75 1.5 scenario is within the validated range.

The calculated normalized parameter for this scenario is within the validated range.

NLS2013032 Attachment Page 21 of 39 Fire Fire.':"si

£f '"'t

" 'i C prten Ze Ignition Source r (ft)

'H (ft) r/H ustifcation Compartment Zone

) - :.,".

. -,.:1'.'. ;

ý.g*,:,S

-*.,,*, ;,y

J

..- *',h::"*.*';

Scenario EE-SW-A in Fire Zone 8E exceeds the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g.,

beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited. Additionally, this CB-A-1 8E EE-SW-A 11 6.08 1.8 ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring 11 feet and the vertical distance measuring only 6.08 feet. Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly above the validated range.

The ratios calculated for the transient scenarios in Fire Zone 8E are above the validated range.

However, detection activation time is not critical to CB-A-1 8E Transient 24 11 2.2 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the transient scenarios I__

IIand further evaluation is not required.

Scenario EE-BAT-125 1B Rack 1 in Fire Zone 8F falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet EE-BAT-125 1B between the plume and the detector being credited.

CB-B 8F Rack 1 6.58 8.75 0.8 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 6.58 feet and the vertical distance measuring 8.75 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

Scenario EE-BAT-1 25 1 B Rack 2 in Fire Zone 8F falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet EE-BAT-125 1B between the plume and the detector being credited.

CB-B 8F Rack 2 0.58 8.75 0.1 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 0.58 feet and the vertical distance measuring 8.75 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is below the validated range.

The ratio calculated for Scenario EE-BAT-250 1B Rack 1 in Fire Zone 8F is below the validated EE-BAT-250 1B range. However, detection activation time is not CB-B 8F Rack 1 8

8.75 0.9 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

NLS2013032 Attachment Page 22 of 39 m

eFire oeFire Ignition Source r, t(

H (ft) riH 4s Jtification Compartment jZone The ratio calculated for Scenario EE-BAT-250 1B Rack 2 in Fire Zone 8F is below the validated EE-BAT-250 1B range. However, detection activation time is not CB-B 8F Rack 2 1

8.75 0.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

IB-B3 8F EE-PNL-B 10 6.75 1.5 The calculated normalized parameter for this scenario is within the validated range.

The calculated normalized parameter for this scenario is within the validated range.

Scenario EE-SW-B in Fire Zone 8F exceeds the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g.,

beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited. Additionally, this CB-B 8F EE-SW-B 11 6.08 1.8 ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring 11 feet and the vertical distance measuring only 6.08 feet. Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly above the validated range.

The ratios calculated for the transient scenarios in Fire Zone 8F are above the validated range.

However, detection activation time is not critical to CB-B 8F Transient 24 11 2.2 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the transient scenarios I

I_

I and further evaluation is not required.

Scenario EE-CHG-125 1B in Fire Zone 8G falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-B 8G EE-CHG-125 1B 5.167 6.167 0.8 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 5.17 feet and the vertical distance measuring 6.17 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

Scenario EE-CHG-250 1B in Fire Zone 8G falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, CB-B 8G EE-CHG-250 1B 6.25 6.2 1.0 HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 6.25 feet and the vertical distance measuring 6.2 feet.

Considering the close proximity of the detector to

NLS2013032 Attachment Page 23 of 39 Fire

-.Fire '

I-giionSoUrce Justificai Compartmenit Zone "

H (ft)--

I the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

Scenario EE-SWGR-125 1B in Fire Zone 8G falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-B 8G EE-SWGR-125 1B 1.75 4.2 0.4 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 1.75 feet and the vertical distance measuring 4.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is below the validated range.

Scenario EE-SWGR-250 1 B in Fire Zone 8G falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-B 8G EE-SWGR-250 1B 1.75 4.2 0.4 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 1.75 feet and the vertical distance measuring 4.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is below the validated range.

The ratios calculated for the transient scenarios in Fire Zone 8G are below the validated range.

However, detection activation time is not critical to CB-B 8G Transient 8.75 11 0.8 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the transient scenarios I

I_

I and further evaluation is not required.

Scenario EE-CHG-125 1A in Fire Zone 8H falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-A-1 8H EE-CHG-125 1A 5.17 6.2 0.8 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 5.17 feet and the vertical distance measuring 6.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

NLS2013032 Attachment Page 24 of 39 Fire Fire-,

Igiton

-ust.fication Compartment Zo-.Ineo Sorce.

(fr)

H (f) rH Scenario EE-CHG-250 1A in Fire Zone 8H falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-A-1 8H EE-CHG-250 1A 6.25 6.2 1.0 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 6.25 feet and the vertical distance measuring 6.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

Scenario EE-IVTR-1A in Fire Zone 8H falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-A-1 8H EE-IVTR-IA 4

6.2 0.6 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 4 feet and the vertical distance measuring 6.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the nH value is below the validated range.

Scenario EE-SWGR-125 1A in Fire Zone 8H falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-A-1 8H EE-SWGR-125 1A 1.75 4.2 0.4 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 1.75 feet and the vertical distance measuring 4.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is below the validated range.

Scenario EE-SWGR-250 1A in Fire Zone 8H falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, GB-A-i 8H EE-SWGR-250 1A 1.75 4.2 0.4 HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 1.75 feet and the vertical distance measuring 4.2 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the

NLS2013032 Attachment Page 25 of 39 Fire Fire Ignition Source r (ft)

H (ft) rH "Ustifcation Compartment Zone (ft).

H. (ft ).

configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is below the validated range.

The ratios calculated for the transient scenarios in Fire Zone 8H are below the validated range.

However, detection activation time is not critical to CB-A-1 8H Transient 8.75 11 0.8 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the transient scenarios and further evaluation is not required.

The calculated normalized parameter for this C scenario is within the validated range.

The calculated normalized parameter for this scenario is within the validated range.

Scenario EE-PNL-RPSPP1A in Fire Zone 9A falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-E 9A EE-PNL-RPSPP1A 4

5.83 0.7 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 4 feet and the vertical distance measuring 5.83 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is below the validated range.

The calculated normalized parameter for this scenario is within the validated range.

The ratio calculated for Scenario LRP-PNL-PL1 in Fire Zone 9A is below the validated range.

However, detection activation time is not critical to CB-E 9A LRP-PNL-PL1 4.83 6.67 0.7 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario LRP-PNL-PL2 in Fire Zone 9A is below the validated range.

However, detection activation time is not critical to CB-E 9A LRP-PNL-PL2 0.5 6.67 0.1 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

Scenario PC-CS-H2_021 & 0211 in Fire Zone 9A falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-E 9A PC0CS-H2_021 &

5.92 7.33 0.8 Additionally, this ignition source is located in very 0211 close proximity to the credited device, with the horizontal distance (r) measuring only 5.92 feet and the vertical distance measuring 7.33 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

NLS2013032 Attachment Page 26 of 39 Fire Fire ignition Source r (ft)

H (ft) nH j,

a id:;tion.

Comnpa gitne t

____l___ll______"__l_..._l

__llll

__l ____lllll

____lll

__ll

____l

___st ______t

___n_______l..._l_

CB-E 9A PMIS-MUX-LNK2 12.67 7.83 1.6 The calculated normalized parameter for this scenario is within the validated range.

Scenario RFC-CC-1A & 1B in Fire Zone 9A falls below the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

CB-E 9A RFC-CC-1A & 1B 4.83 6.08 0.8 Additionally, this ignition source is located in very close proximity to the credited device, with the horizontal distance (r) measuring only 4.83 feet and the vertical distance measuring 6.08 feet.

Considering the close proximity of the detector to the fire and the lack of obstructions in the configuration, the use of the detector correlation in the fire model is appropriate even though the r/H value is slightly below the validated range.

The calculated normalized parameter for this CB-9A SS-AT-PS2 14

.75

1.

scenario is within the validated range.

CB-EThe calculated normalized parameter for this scenario is within the validated range.

The calculated normalized parameter for this scenario is within the validated range.

The ratio calculated for Scenario TB-C324 in Fire Zone 9A is below the validated range. However, detection activation time is not critical to the CB-E 9A TB-C324 9

7.83 1.1 analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

Transient Scenario The transient scenarios in Fire Zone 9B fall below TS#1 the validated range. Visual inspections were Transient Scenario performed during fire modeling walkdowns to GB-F 98 TS#2 5

11 0.5 ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

Additionally, the transient fires are located in very close proximity to the credited device, with the CB-F 9B Transient Scenario 11 0.5 largest horizontal distance (r) measuring only 5 feet TS#3 and the vertical distance measuring 11 feet.

Considering the close proximity of the detector to the transient fires and the lack of obstructions in the configuration, the use of the detector correlation in the fire models is appropriate even though the r/H values are below the validated range.

CW-P-VPA (Large The CW-P-VPA scenarios in Fire Zone 11B fall Oil) below the validated range. Visual inspections were TB-A 11B CW-P-VPA (Small 2.48 20.5 0.1 performed during fire modeling walkdowns to Oil) ensure that the ceiling jet correlation was only

NLS2013032 Attachment Page 27 of 39 Fire Source r

rft)

H (ft) st.

i.

Compartment Zone Ignition Source.

r H-. (f applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

Additionally, CW-P-VPA is located in very close proximity to the credited device, with a horizontal TB-A 11B CW-P-VPA 2.48 16 0.2 distance (r) measuring only 2.48 feet and the (Electrical) largest vertical distance measuring 20.5 feet.

Considering the close proximity of the detector to CW-P-VPA and the lack of obstructions in the configuration, the use of the detector correlation in the fire models is appropriate even though the r/H values are below the validated range.

CW-P-VPB (Large 20.5 0.3 The CW-P-VPB scenarios in Fire Zone 11B fall Oil) below the validated range. Visual inspections were CW-P-VPB (Small performed during fire modeling walkdowns to Oil) ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

Additionally, CW-P-VPB is located in very close proximity to the credited device, with a horizontal TB-A 11B CW-P-VPB 6.58 16 0.4 distance (r) measuring only 6.58 feet and the (Electrical) largest vertical distance measuring 20.5 feet.

Considering the close proximity of the detector to CW-P-VPB and the lack of obstructions in the configuration, the use of the detector correlation in the fire models is appropriate even though the r/H values are below the validated range.

EE-SWGR-4160A The ratios calculated for the scenarios in Fire Zone (1N 5a) 13B are outside the validated range. However, EE-SWGIR-4160A detection activation time is not critical to the (1N 5b) HEAF analyses. Automatic detection timing was EE-SWGR-4160B calculated, however, it is not credited to prevent (1N 5a) damage to any targets in these scenarios and EE-SWGR-4160B further evaluation is not required.

NCS 138B 1b)HA 1.93 8

0.2 (15b) HEAF EE-SWGR-4160C The calculated normalized parameter for this (11 5a) scenario is within the validated range.

EE-SWGR-4160C The calculated normalized parameter for this (15b) HEAF scenario is within the validated range.

EE-SWGR-4160D The ratios calculated for the scenarios in Fire Zone (1i5a) 13B are outside the validated range. However, EE-SWGR-4160D detection activation time is not critical to the (15b) HEAF analyses. Automatic detection timing was EE-SWGR-4160E calculated, however, it is not credited to prevent (I5a) damage to any targets in these scenarios and EE-SWGR-4160E further evaluation is not required.

NCS 138B 1b)HA 19.25 8

2.4 (115b) HEAF NCS 13B EE-SWGR-480A 3.85 8.5 0.5 (15a)

NCS 13B EE-SWGR-480A 3.85 8.5 0.5 (15b) HEAF NCS 13B EE-SWGR-480B 7.7 8.5 0.9 (15a)

NCS 13B EE-SWGR-480B 7.7 8.5 0.9 (15b) HEAF NCS 13B EE-XFMR-480A 3.85 8.5 0.5 NCS 13B EE-XMFR-480B 7.7 8.5 0.9 NCS 13B BAT CHRG-RECT 38.5 12 3.2

NLS2013032 Attachment Page 28 of 39 Fire Fire Co artment Ze Ignition Source t (ft)

H (ft) f/H Justification Compartment Zone NCS 13B Transient 43 14 3.1 The calculated normalized parameter for this scenario is within the validated range.

The detection system is credited to prevent whole room damage only for the DG-D-1 (diesel/oil) scenarios. Therefore, the ceiling jet activation correlation was not used to calculate the detection activation time. The developing HGL would activate the detection system before it reached temperatures capable of causing whole room DG-A 14A DG-D-1 1

14 0.1 damage.

The ratio calculated for Scenario DG-D-1 (Electrical) in Fire Zone 14A is below the validated range. However, detection activation time is not critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario DG-PNL-DG1 ECP in Fire Zone 14A is below the validated range.

However, detection activation time is not critical to DG-A 14A DG-PNL-DG1 ECP 3.5 5.83 0.6 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further I

I I evaluation is not required.

The ratio calculated for Scenario DG-REL-DG1 in Fire Zone 14A is below the validated range.

However, detection activation time is not critical to DG-A 14A DG-REL-DG1 3.5 5.67 0.6 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario DG-VRG-DG1 (15a) in Fire Zone 14A is below the validated range. However, detection activation time is not DG-A 14A DG-VRG-DG1 (15a) 6 5.58 1.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and I_

I I further evaluation is not required.

The ratio calculated for Scenario DG-VRG-DG1 (15b) HEAF in Fire Zone 14A is below the validated AA G-VRG-DG1 (15b) range. However, detection activation time is not DG-A 14A HEAF 6

5.58 1.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and I

further evaluation is not required.

The ratio calculated for Scenario EE-SWGR-4160DG1 (15a) in Fire Zone 14A is below the EE-SWGR-validated range. However, detection activation time DG-A 14A 4160DG1 (15a) 5 5.58 0.9 is not critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario EE-SWGR-4160DG1 (15b) HEAF in Fire Zone 14A is below EE-SWGR-the validated range. However, detection activation DG-A 14A 4160DG1 (15b) 6 8

0.8 time is not critical to the analysis. Automatic HEAF detection timing was calculated, however, it is not credited to prevent damage to any targets in the I_

I I_

I I

Iscenario and further evaluation is not required.

NLS2013032 Attachment Page 29 of 39 Fire Fire Ignition Source r (ft)

H (ft) nH Compartment Zone igiinyc f) 11'(t rH-oJustification The ratio calculated for Scenario LRP-RACK-LIR-HV-DG-A in Fire Zone 14A is below the validated LRP-RACK-LIR-HV-range. However, detection activation time is not DG-A 14A DG-A 1

8 0.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario LRP-RACK-LIR-HV-DG-C in Fire Zone 14A is below the validated LRP-RACK-LIR-HV-range. However, detection activation time is not DG-A 14A DG-C 1

8 0.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The detection system is credited to prevent whole room damage only for the DG-D-2 (diesel/oil) scenarios. Therefore, the ceiling jet activation correlation was not used to calculate the detection activation time. The developing HGL would activate the detection system before it reached temperatures capable of causing whole room DG-B 14B DG-D-2 1

14 0.1 damage.

The ratio calculated for Scenario DG-D-2 (Electrical) in Fire Zone 14B is below the validated range. However, detection activation time is not critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario DG-PNL-DG2 ECP in Fire Zone 14B is below the validated range.

However, detection activation time is not critical to DG-B 14B DG-PNL-DG2 ECP 3.5 5.83 0.6 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further I

I_

I evaluation is not required.

The ratio calculated for Scenario DG-REL-DG2 in Fire Zone 14B is below the validated range.

However, detection activation time is not critical to DG-B 14B DG-REL-DG2 3.5 5.67 0.6 the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further I

I_

I evaluation is not required.

The ratio calculated for Scenario DG-VRG-DG2 (15a) in Fire Zone 14B is below the validated range. However, detection activation time is not DG-B 14B DG-VRG-DG2 (15a) 6 5.58 1.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and I_

I_

Ifurther evaluation is not required.

The ratio calculated for Scenario DG-VRG-DG2 (15b) HEAF in Fire Zone 14B is below the validated range. However, detection activation time is not DG-B 14B DGVRGDG2 (15b) 6 5.58 1.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and I_

I further evaluation is not required.

The ratio calculated for Scenario EE-SWGR-4160DG2 (15a) in Fire Zone 14B is below the EE-SWGR-validated range. However, detection activation time DG-B 14B 4168DG2 (15a) 5 5.58 0.9 is not critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and I_

I_

I_

II I

Ifurther evaluation is not required.

NLS2013032 Attachment Page 30 of 39 Fire Fire (f

utfctb Compartment Zone Ignition Source r (ft)

H

)

HJustifici The ratio calculated for Scenario EE-SWGR-4160DG2 (15b) HEAF in Fire Zone 14B is below EE-SWGR-the validated range. However, detection activation DG-B 14B 4160DG2 (15b) 5 5.08 1.0 time is not critical to the analysis. Automatic HEAF detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario LRP-RACK-LIR-HV-DG-B in Fire Zone 14B is below the validated LRP-RACK-LIR-HV-range. However, detection activation time is not DG-B 14B DG-B 1

8 0.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and further evaluation is not required.

The ratio calculated for Scenario LRP-RACK-LIR-HV-DG-D in Fire Zone 14B is below the validated LRP-RACK-LIR-HV-range. However, detection activation time is not DG-B 14B DG-D 1

8 0.1 critical to the analysis. Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets in the scenario and I_

I further evaluation is not required.

The calculated normalized parameter for this IS-A 20A FP-P-C (Large Oil) 20 14.8 1.4scnroiwthnhevldedag.

Iscenario is within the validated range.

The calculated normalized parameter for this IS-A 20A FP-P-C (Small Oil) 20 14.8 1.4scnroiwthnhevldedag.

scenario is within the validated rangle.

The ratio calculated for Scenario FP-P-C (Electrical) in Fire Zone 20A exceeds the validated range. However, detection activation time is not IS-A 20A FP-P-C (Electrical) 20 8.4 2.4 critical to the analysis for the electrical fire.

Automatic detection timing was calculated, however, it is not credited to prevent damage to any targets for the electrical fire and further evaluation is not required.

IS-A 20A HV-FCU-HV-lS-1A 10 7

1.4 The calculated normalized parameter for this scenario is within the validated range.

The calculated normalized parameter for this scenario is within the validated range.

IS-A 20A LRP-PNL-S191 25 9.05 2.8 The ratios calculated for Scenarios LRP-PNL-S191 and LRP-PNL-S192 in Fire Zone 20A exceed the validated range. However, detection activation time is not critical to the analyses. Automatic detection IS-A 20A LRP-PNL-S192 20 9.05 2.2 timing was calculated, however, it is not credited to prevent damage to any targets in the scenarios and I further evaluation is not required.

The calculated normalized parameter for this IS-A 20A SW-P-A (Large Oil) 20 14.8 1.4 scenario is within the validated range.

The calculated normalized parameter for this IS-A 20A SW-P-A (Small Oil) 20 14.8 1.4scnroiwthnhevldedag.

scenario is within the validated range.

Scenario SW-P-A (Electrical) in Fire Zone 20A exceeds the validated range. The detection system is credited to actuate the Halon system. Fire PRA target failures beyond the ignition source occur at 9.8 minutes for the electrical fire.

In order for the normalized parameter to fall within the validated range, the height of the ceiling above the ignition source must be conservatively increased to 11.7 (rH=1.7). Utilizing the revised ceiling height and FDT 10, a 105kW fire is required for smoke detection activation. The fire reaches 105kW at 8.5 minutes; therefore, time to automatic suppression is conservatively rounded up to 9.5 minutes. The Halon suppression system actuates prior to the target damage time of 9.8 minutes using

NLS2013032 Attachment Page 31 of 39

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the revised ceiling height and the scenario target failures and frequencies remain unchanged and valid.

The detection system is credited to prevent whole IS-A 20A SW-P-B (Large Oil) 12 14.8 0.8 room damage only for the SW-P-B (oil) scenarios.

Therefore, the developing HGL would activate the detection system before it reached temperatures IS-A 20A SW-P-B (Small Oil) 12 14.8 0.8 capable of causing whole room damage and further evaluation is not required.

Scenario SW-P-B (Electrical) in Fire Zone 20A exceeds the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

IS-A 20A SW-P-B (Electrical) 12 6.3 1.9 Additionally, SW-P-B is located in very close proximity to the credited device, with a horizontal distance (r) measuring 12 feet and the vertical distance measuring only 6.3 feet. Considering the close proximity of the detector to SW-P-B and the lack of obstructions in the configuration, the use of the detector correlation in the fire models is appropriate even though the r/H value exceeds the validated range.

The detection system is credited to prevent whole IS-A 20A SW-P-C (Large Oil) 12 14.8 0.8 room damage only for the SW-P-C (oil) scenarios.

Therefore, the developing HGL would activate the detection system before it reached temperatures IS-A 20A SW-P-C (Small Oil) 12 14.8 0.8 capable of causing whole room damage and further evaluation is not required.

Scenario SW-P-C (Electrical) in Fire Zone 20A exceeds the validated range. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for detection timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the detector being credited.

IS-A 20A SW-P-C (Electrical) 12 6.3 1.9 Additionally, SW-P-C is located in very close proximity to the credited device, with a horizontal distance (r) measuring 12 feet and the vertical distance measuring only 6.3 feet. Considering the close proximity of the detector to SW-P-C and the lack of obstructions in the configuration, the use of the detector correlation in the fire models is appropriate even though the r/H value exceeds the validated range.

The calculated normalized parameter for this IS-A 20A SW-P-D (Large Oil) 20 14.8 1.4scnroiwthnhevldedag.

scenario is within the validated range.

The calculated normalized parameter for this IS-A 20A SW-P-D (Small Oil) 20 14.8 1.4scnroiwthnhevldedag.

scenario is within the validated range.

Scenario SW-P-D (Electrical) in Fire Zone 20A exceeds the validated range. The detection system is credited to actuate the Halon system. Fire PRA target failures beyond the ignition source occur at 12 minutes for the electrical fire.

IS-A 20A SW-P-D (Electrical) 20 6.3 3.2 In order for the normalized parameter to fall within the validated range, the height of the ceiling above the ignition source must be conservatively increased to 11.7 (r/H=1.7). Utilizing the revised ceiling height and FDT 10, a 105kW fire is required for smoke detection activation. The fire reaches

NLS2013032 Attachment Page 32 of 39 Fire F

t Source r

i(t) e(ft) rH [ustfidaton Compartment one 105kW at 8.5 minutes; therefore, time to automatic suppression is conservatively rounded up to 9.5 minutes. The Halon suppression system actuates prior to the target damage time of 9.8 minutes using the revised ceiling height and the scenario target failures and frequencies remain unchanged and valid.

The calculated normalized parameter for this A

I T

e 17 1scenario is within the validated range.

The Alpert ceiling jet correlation was also used for modeling sprinkler actuation at CNS, in addition to a correlation that accounts for the time required to heat the thermal link of the sprinkler. Refer to "Sprinkler Activation Correlation" below for detailed discussion on the use of the sprinkler activation correlation.

For other targets located in the ceiling jet, the radiant heat flux ZOI was calculated using the point source model. Using the point source model bounds the use of the ceiling jet correlation:

a. For fire zones at CNS with high ceilings: The radiant heat flux ZOI calculated using the point source model was applied to determine target damage from the floor to the top of the flame. Since the ceiling height is higher than the top of a flame, it is high enough that the ceiling jet ZOI is reduced to the approximate size of the plume radius.

Within the plume radius, the plume temperatures lead to target damage.

b. For fire zones at CNS with low ceilings: The radiant heat flux ZOI calculated using this point source model extends horizontally further than the ceiling jet. This ZOI calculated using the point source model was applied to determine target damage from the floor to the ceiling. Because the horizontal ZOI calculated by the point source model extends further than the ceiling jet, the point source model is bounding.

For the following scenarios, the point source model used to calculate the radiant heat ZOI does not bound the ZOI caused by the ceiling jet. The scenarios are dispositioned as follows:

a. For the large oil fires in Fire Zones 4D, 5B, and 20A, and the large diesel fires in Fire Zones 14A and 14B, the ceiling jet radial distance relative to the ceiling height is not applicable to these fire scenarios because the fire scenarios do not consider failure to targets from the ceiling jet or radiant heat. Rather, all fire scenarios conservatively postulate whole room damage which bounds the ceiling jet and radiant heat ZOL.

Equivalence Ratio This parameter is not applicable to fire modeling using the Detailed Fire Modeling Workbooks. The underlying consideration for this parameter is that conditions in the enclosure are not expected to be worse in a fire where the combustion process is affected

NLS2013032 Attachment Page 33 of 39 by lack of oxygen than they would be under fire conditions where the combustion process is assumed unaffected. This parameter is not applicable to fire modeling calculations using the Detailed Fire Modeling Workbooks (NUREG-1805 FDTs) because oxygen levels are not taken into account with the equations employed by these models.

Therefore, the fire will not be limited by lack of oxygen.

Compartment Aspect Ratio

1) Within the validated range (0.6-5.7):

a. Most room geometries for the fire zones at CNS where detailed fire modeling was performed are within the validated range of NUREG-1824 with respect to Compartment Aspect Ratio. For other rooms, a justification is provided below where the normalized parameter was outside of the validated range.

2) Below the validated range (<0.6):

a. Sensitivity study: For fire zones having an aspect ratio below the validated range where detailed fire modeling was performed and whole room damage was not postulated, a sensitivity study was performed to determine the potential for HGL development with a compartment aspect ratio within the validated range. This approach is recommended by NUREG-1934. This study considered the impact of decreasing the height of the fire zones resulting in values that fall within the validation range. Reducing the height of the fire zones decreased the volume of the compartment and created more severe conditions than the actual fire zone configurations at CNS.

b. All cables within the fire zones are of thermoset material; therefore, the target damage temperature is 330'C. The fire sizes presented in the table below were selected as the largest fire in the fire zone which did not create a HGL of 330'C in the current analysis (fires which create a HGL of 330'C in the current analysis already postulate whole room damage and bound any use of the HGL calculation tool outside of the validated range). The following fire scenarios were analyzed with aspect ratios within the validated range.

wB:

wp Mo ! el&-.eJi ý6..J.......

FIre, Zone, Ui~Sze(W X AMPL Te@p10qp tA&0ecf'c Rati6(t 1A 772 182 184 1D 772 182 184 The results of the sensitivity study indicate that altering the fire zone geometries to bring the aspect ratio into the validation range does not cause either fire zone to reach a damaging (i.e., 330'C) HGL.

NLS2013032 Attachment Page 34 of 39

3) Above the validated range (>5.7): NUREG-1934 suggests that a large aspect ratio could lead to a misrepresentation of the HGL by the FDTs. The basis is when considering a very large room with vastly different dimensions, the HGL may not be uniformly distributed across the ceiling. Rather, hot spots can occur close to the fire scenario.

a. Sensitivity study: For fire zones having an aspect ratio above the validated range where detailed fire modeling was performed and whole room damage was not postulated, a sensitivity study was performed to analyze the potential for HGL development in a fire zone with a compliant compartment aspect ratio. This approach is recommended by NUREG-1934. This study was done by decreasing the length or width of the fire zones to values that fall within the validation range.

Reducing the length or width of the fire zones decreased the volume of the compartment and created more severe conditions than the actual fire zone configurations at CNS.

b. All cables within the fire zones are of thermoset material; therefore, the target damage temperature is 330'C. The fire sizes presented in the table below were selected as the largest fire in the fire zone which did not create a HGL of 330'C in the current analysis (fires which create a HGL of 330'C in the current analysis already postulate whole room damage and bound any use of the HGL calculation tool outside of the validated range). The following fire scenarios were analyzed with aspect ratios within the validated range.

JFreZoie

~re Size

-HG'L Teno:mp

. e-l roiIe Firg~ Zon HGL Ten omp iant 9A 1318 192 200 11F 317 97 139 13B 633 119 127 The results of the sensitivity study indicate that altering the fire zone geometries to bring the aspect ratios into the validation range does not cause any fire zone to reach a damaging (i.e., 330'C) HGL.

Radial Distance, r, relative to the Fire Diameter, D Radiative heat flux was calculated using the point source radiation model found in the FDT 05.1 and FIVE fire models. Since the fire diameter is not an input to this correlation (i.e., Fuel Area set to 0 ft2 in FDT 05.1), a sensitivity analysis is not possible and this normalized parameter is not applicable to the heat flux model used for fire modeling at CNS.

NLS2013032 Attachment Page 35 of 39 Sprinkler Activation Correlation Sprinkler activation times were calculated for a number of fire scenarios at CNS using FDT 10 of NUREG-1805. The FDT 10 calculation uses the Alpert ceiling jet correlation in addition to a correlation that accounts for the time required to heat the thermal link of the sprinkler. The ceiling jet velocity is a sub-model in the analysis.

The ceiling jet correlation is valid for an r/H value in the range of 1.2 to 1.7 in NUREG-1824. Consistent with NUREG-1805, the "r" value is the radial distance to the sprinkler, while "H" is the height of the ceiling above the top of the fuel source (i.e., the fire elevation). NUREG-1934 cautions that the ceiling jet application must be carefully evaluated in commercial nuclear power plants for possible obstructions near the ceiling (e.g., cable trays, HVAC ducts, piping, etc.) that may disrupt the ceiling jet and invalidate the model. Otherwise, NUREG-1934 suggests a sensitivity analysis may be performed by moving the fire location to distances that fall within the validated range. However, the guidance in NUREG-1934 acknowledges that this may not be possible in certain fire scenarios involving fixed ignition sources or critical target locations.

The table below identifies each fire zone at CNS that employs the NUREG-1805 FDT 10 sprinkler activation correlation and the calculated r/H ratio for each scenario:

4D RRLO-P-A1,A2,A3,B1,B2,B3 (Large Oil) 0 8.33 0

4D RRLO-P-A1,A2,A3,B1,B2,B3 (Small Oil) 0 8.33 0

4D RRLO-P-A1,A2,A3,B1,B2,B3 (Electrical) 0 5

0 5B LRP-PNL-02-184-A 5

2 2.5 5B LRP-PNL-02-184-B 9.1 2

4.55 5B RRMG-GEN-MGA (Large Oil) 0 16 0

5B RRMG-GEN-MGA (Small Oil) 0 16 0

5B RRMG-GEN-MGA (Electrical) 0 6.2 0

5B RRMG-GEN-MGB (Large Oil) 0 16 0

5B RRMG-GEN-MGB (Small Oil) 0 16 0

5B RRMG-GEN-MGB (Electrical) 0 6.17 0

8D EE-CHG-125 1C 2.6 6.1 0.43 9A EE-PNL-CPP 4

7.33 0.55 9A EE-PNL-NBPP 4

7.33 0.55 9A EE-PNL-RPSPP1A 6

7.33 0.82 9A EE-PNL-RPSPP1B 5

7.33 0.68 9A LRP-PNL-PL1 6.83 5

1.37 9A LRP-PNL-PL2 0.5 5

0.1 9A PC-CS-H2_021 & 0211 5.25 6.83 0.77 9A PMIS-MUX-LNK2 2.75 7

0.39

NLS2013032 Attachment Page 36 of 39 Fire Zone Ignition Source r (ft)

H (ft) riH 9A RFC-CC-1A & 1B 3.33 7.58 0.44 9A SS-BAT-UPS2 5.08 7.92 0.64 9A SS-IVTR-UPS2 4.42 7.92 0.56 9A APARS BD 3.17 6.42 0.49 9A TB-C324 5

7 0.71 11B CW-P-VPA (Large Oil) 7.75 20.5 0.38 11B CW-P-VPB (Large Oil) 2.67 20.5 0.13 With the exception of Fire Scenario LRP-PNL-PLI in Fire Zone 9A, all the configurations implement an r/H value outside of the validated range. The following discussions address each scenario, or set of scenarios, by either performing a sensitivity study or by providing justification for the use of the correlation outside of the validated range.

The ratios calculated for the ignition sources in Fire Zone 4D, Fire Zone 8D, and ignitions sources LRP-PNL-PL2, SS-BAT-UPS2, SS-IVTR-UPS2, and TB-C234 in Fire Zone 9A, are below the validated range. However, suppression activation time is not critical to the analyses. Automatic suppression timing was calculated, however, it is not credited to prevent damage to any targets in these scenarios and further evaluation is not required.

Fire scenarios RRMG-GEN-MGA and RRMG-GEN-MGB in Fire Zone 5B and Fire Scenarios CW-P-VPA and CW-P-VPB in Fire Zone 11 B credit the automatic sprinkler systems to prevent whole room damage only. Therefore in each fire zone, the developing HGL would activate the automatic suppression system before it reached temperatures capable of causing whole room damage (330'C), and further analysis is not required.

Fire scenarios in Fire Zone 9A fall below the validated range. The guidance in NUREG-1934 does not define r/H values below the validated range as non-conservative with respect to suppression. Visual inspections were performed during fire modeling walkdowns to ensure that the ceiling jet correlation was only applied for suppression timing when there were no major obstructions (e.g., beam pockets, cable trays, HVAC ducts, piping, etc.) located in the ceiling jet between the plume and the sprinkler being credited. Additionally, these ignition sources are located in very close proximity to the sprinkler head being credited, with the largest horizontal distance (r) measuring only 6 feet and the greatest vertical distance measuring 7.6 feet. Considering the close proximity of the sprinkler to the fire, the conservatisms in the calculation and the lack of obstructions in the configurations, the use of the sprinkler correlation in these fire models is appropriate even though the r/H values are below the validated range.

Scenario LRP-PNL-02-184-A in Fire Zone 5B is above the recommended range.

However, the calculated time of 2.9 minutes used in the fire model assumed a convective HRR fraction of 0.7. The Alpert Ceiling Jet correlation was verified and validated in

NLS2013032 Attachment Page 37 of 39 NUREG-1824 using the total HRR and not the convective portion. Using the total HRR, the time to suppression for this model would be 2.0 minutes. The margin provided by the additional 55 seconds to the suppression time ensures that the model is conservative.

Additionally, the close proximity of the sprinkler to the fire, the conservatisms in the calculation, and the lack of obstructions in this configuration, the use of the sprinkler correlation in this fire model is appropriate even though the r/H values are not within the validated range.

Scenario LRP-PNL-02-184-B in Fire Zone 5B is above the recommended range.

However, the calculated time of 3.0 minutes used in the fire model assumed a convective HRR fraction of 0.7. The Alpert Ceiling Jet correlation was verified and validated in NUREG-1824 using the total HRR and not the convective portion. Using the total HRR, the time to suppression for this model would be 2.2 minutes. The margin provided by the additional 48 seconds to the suppression time ensures that the model is conservative.

Additionally, the close proximity of the sprinkler to the fire, the conservatisms in the calculation, and the lack of obstructions in this configuration, the use of the sprinkler correlation in this fire model is appropriate even though the r/H values are not within the validated range.

Gas Temperatures The sprinkler activation time correlation used for fire modeling at CNS also includes a calculation for the time required to heat the sensing element of the suppression device from room temperature to operation temperature. Per page 3-141 of the 19 th edition of the NFPA Fire Protection Handbook, it has been found that significant error for heat sensing element correlation can be found when the gas temperature does not substantially exceed the activation temperature of the heating element. In these cases, it is possible for small changes in predicted gas temperatures to result in large changes in predicted operation time. This effect may be important in the case of constant or slowly varying gas temperatures where:

(Tm-Toperation)/(Tm-Tr,) < /

Where:

Tm = Gas temperature surrounding heat activation link Topeaton = Activation temperature of link T. = Ambient temperature Fire Zone Ign Si1'urce d'e' 4D RRLO-P-A1,A2,A3,B1,B2,B3 (Large Oil) 4D RRLO-P-A1,A2,A3,B1,B2,B3 (Small Oil)

NLS2013032 Attachment Page 38 of 39 Fire Zone Ignito,riSource operl! on.'

T..

o T-.)

25 4D RRLO-P-A1,A2,A3,B1,B2,B3 (Electrical) 101.7 74 40 0.45 Yes 5B LRP-PNL-02-184-A 117.5 74 40 0.56 Yes 5B LRP-PNL-02-184-B 123 74 40 0.59 Yes 5B RRMG-GEN-MGA (Large Oil) 15417.08 74 40 1.00 Yes 5B RRMG-GEN-MGA (Small Oil) 141.4 74 40 0.66 Yes 5B RRMG-GEN-MGA (Electrical) 96.5 74 40 0.40 Yes 5B RRMG-GEN-MGB (Large Oil) 15417.08 74 40 1.00 Yes 5B RRMG-GEN-MGB (Small Oil) 141.4 74 40 0.66 Yes 5B RRMG-GEN-MGB (Electrical) 96.95 74 40 0.40 Yes 8D EE-CHG-125 1C 111.65 74 29.4 0.46 Yes 9A EE-PNL-CPP 144.46 74 25 0.59 Yes 9A EE-PNL-NBPP 144.46 74 25 0.59 Yes 9A EE-PNL-RPSPP1A 116.16 74 25 0.46 Yes 9A EE-PNL-RPSPP1B 127.95 74 25 0.52 Yes 9A LRP-PNL-PL1 101.74 74 25 0.36 Yes 9A LRP-PNL-PL2 122.94 74 25 0.50 Yes 9A PC-CS-H2_021 & 0211 121.48 74 25 0.49 Yes 9A PMIS-MUX-LNK2 95.91 74 25 0.31 Yes 9A RFC-CC-IA & 1B 136 74 25 0.56 Yes 9A SS-BAT-UPS2 84.02 74 25 0.17 No 9A SS-IVTR-UPS2 89.75 74 25 0.24 No 9A APARS BD 124.7 74 25 0.51 Yes 9A TB-C324 92.48 74 25 0.27 Yes 11B CW-P-VPA (Large Oil) 226.69 100 40 0.68 Yes 11B CW-P-VPB (Large Oil) 346.62 100 40 0.80 Yes The ratio calculated for all scenarios crediting suppression activation are within the acceptable range, with the exception of scenarios involving SS-BAT-UPS2 and SS-IVTR-UPS2. The ratio calculated for these two scenarios is slightly below the acceptable value of 0.25. Therefore, the effect of small changes in gas temperature in operation time must be considered. In the fire scenarios for SS-BAT-UPS2 and SS-IVTR-UPS2, however, suppression activation time is not critical to the analysis. Automatic suppression timing was calculated. However, it is not credited to prevent damage to any targets in these scenarios and further evaluation is not required. Considering the lack of criticality of the suppression timing and the fact that the calculated ratio is very near 0.25, the model is still considered appropriate.

NLS2013032 Attachment Page 39 of 39 Request: Fire Modeling RAI 02c, d, e, f, 03, 04, and 05 NPPD Response:

These RAIs were addressed in the 60-day and 90-day responses.