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=Text=
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{{#Wiki_filter:SSES-FPRR Text Rev. 17 UNITS 1 AND 2
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==SUMMARY==
TABLE OF CONTENTS FPRR Rev. 22 Page 1 of 2
 
Section Title
 
==1.0 INTRODUCTION==
 
===1.1 Objective===
 
===1.2 Background===
 
===1.3 Philosophy===
 
1.4 Fire Protection Program
 
===1.5 Content===
and Format
 
===2.0 DEFINITIONS===
 
3.0 SAFE SHUTDOWN ANALYSIS
 
===3.1 Introduction===
 
===3.2 Criteria===
 
===3.3 Methodology===
 
===3.4 Appendix===
R Compliance
 
4.0 FIRE PROTECTION SYSTEM DESCRIPTION
 
4.1 Fire Protection Water Supply System
 
===4.2 Automatic===
Wet Pipe Sprinkler Systems 4.3 Dry Pipe Sprinkler Systems
 
===4.4 Automatic===
Preaction Sprinkler Systems
 
===4.5 Deluge===
Systems 4.6 Wet Standpipes and Hose Stations
 
===4.7 Portable===
Fire Extinguishers
 
===4.8 Carbon===
Dioxide Systems
 
===4.9 Halon===
Extin guishing Systems 4.10 Insulation and Jacketing of Cable 4.11 Raceway Wrapping 4.12 Fire Detection And Alarm System 4.13 Appendix R Voice Powered Communication System
 
===5.0 COMPARISON===
OF SUSQUEHANNA SES DESIGN AND FIRE PROTECTION FEATURES TO REGULATORY REQUIREMENTS 6.0 FIRE HAZARDS ANALYSIS 
 
===6.1 Introduction===
 
6.2 Fire Area Description
 
SSES-FPRR Text Rev. 17 UNITS 1 AND 2
 
==SUMMARY==
TABLE OF CONTENTS FPRR Rev. 22 Page 2 of 2
 
===7.0 DEVIATION===
REQUESTS
 
===7.1 Introduction===
 
===7.2 Deviation===
Request Index
 
===8.0 DRAWINGS===
 
SSES-FPRR Text Rev. 11
 
==1.0 INTRODUCTION==
 
FPRR Rev. 13 1.0-1 1 V:\NFM3\Wori<
Areas\Pegues\FPRR TEXT 1_0.DOC SSES-FPRR Text Rev. 11 1.1 OBJECTIVE This Fire Protection Review Report (FPRR) submitted by PPL Susquehanna, LLC (PPL) describes the fire protection features which ensure the capability to achieve and maintain the cold (safe) shutdown of Susquehanna SES Units 1 and 2 and demonstrates compliance to the requirements of Appendix A to Branch Technical Position Auxiliary Power Conversion Systems Branch 9.5-1 (BTP APCSB 9.5-1 ); 10CFR50 Appendix R Sections IILG, 111.J, BI.Land 111.0; 10CFR50.48; and General Design Criterion 3 of Appendix A to 1 OCFR50. FPRR Rev. 13 1.1-1 V:\NFM3\Wori<
Areas\Pegues\FPRR TEXT 1_ 1.DOC 
) SSES-FPRR
 
==1.2 BACKGROUND==
 
In September of 1976, PPL was informed by the NAC that the guidelines in Appendix A to BTP APCSB 9.5-1 would be used by the NRC to evaluate the fire protection program at Susquehanna SES. Additionally, PPL was requested to provide a fire hazards analysis that divided the plant into distinct fire areas and to show that redundant safety
* systems required to achieve and maintain cold shutdown are adequately protected against fire damage. By earty 1980, most of the aspects of Appendix A had been implemented at Susquehanna.
In November, 1980, the NRC issued Appendix R to 10CFR50. Appendix R was originally intended as a mechanism to close out a limited number of open issues for a limited set of plants. PPL agreed to comply with Sections 111.G, 111.J and 111.0 which was applied to all plants. As a result of our analysis compliance to Section UI.L is also shown. Rev. 10 1 .2-1 G:\Lic Docs\FPRR Approved\Text\Seetion01\fp01_0700_02.doc SSES-FPRR 1 .3 PHILOSOPHY It is PPL 1 s corporate philosophy that fire protection be provided for all company facilities in order to protect its employees and facilities as well as the general public from the effects of a fire. Subsequently, proper fire protection was an original design objective for Susquehanna SES. fn addition to fire protection design features which would insure a safe and reliable facility 1 further design and programmatic requirements were necessary to prevent damage to those systems and components essential to the safe operation and safe shutdown of the station as well as the control of any radiological release f rem the station. ft is PPL 1 s philosophy that in the event of a fire, Susquehanna SES Units 1 and 2 will be operated in accordance with symptom based Emergency Operating Procedures an*d Off Normal Procedures.
This Fire Protection Review Report primarily addresses PPL's compliance to the licensing and regulatory requirements which must be met in order to demonstrate the safe shutdown capability of both reactor units in the event of a design basis fire and to control the release of any radioactive elements from the station. While Appendix A addresses the fire protection program as a whole, Appendix A requirements more specifically address the capability of both reactors to achieve and maintain a safe shutdown condiUon.
Therefore, where the requirements of Appendix A and Appendix R overlapped, the Appendix R requirements govern since they most directly affect safe shutdown.
Rev. 10 1.3-1 G:\l..ic Docs\FPRR Approved\Text\SectionDi\lp01_0100_03_doc SSES-FPRR Text Rev. 13 FPRR Rev. 22 1.4-1 1.4  FIRE PROTECTION PROGRAM
 
====1.4.1 Initial====
Implementation
 
Bechtel Power Corporation was the architect/engineer for Susquehanna SES and provided the fire protection engineers and consultants to develop the design concept, preparation of specifications, and selection of experienced fire protection contractors during plant construction.
Bechtel has designed fire protection systems for several operating nuclear plants and employed a specialized staff that monitored the latest in fire protection methods.
 
As the plant progressed from a construction to an operational mode, PPL took full responsibility of the fire protection program. Responsibility for the fire protection program is vested in PPL managerial personnel in the same manner as other operating and design responsibilities.
 
====1.4.2 Compliance====
 
The fire protection program is implemented through approved specification, drawings, and procedures which are generated and controlled under the PPL Operational Quality Assurance Program.
PPL's long term compliance program for fire protection is an integral part of the design control process and assures that present plant fire protection features and hazard configurations will not be degraded by the implementation of a design change. Plant procedures control the use and storage of combustible materials. Design specifications and plant procedures provide for the periodic surveillance of required fire protection features. The combustible loading analysis is modified through the design control process.
 
Through this controlled, programmatic approach, the fire protection features at Susquehanna SES are assured to maintain their integrity as plant operation continues.
 
1.4.3  Personnel/Training
 
1.4.3.1  Fire Protection Staff
 
PPL employs qualified personnel to ensure an adequate fire protection program is provided and maintained. The Site Fire Protection Engineer shall be a qualified fire protection engineer with suitable background experience to meet the job requirements. This will be supplemented with appropriate training from vendor training schools and state fire fighting schools as necessary to carry out the job responsibilities. Other personnel who are assigned fire protection duties will receive the necessary training to perform their assigned functions. Training for the fire protection staff shall include the following as necessary:
 
a) design and maintenance of fire detection, suppression, and extinguishing systems.
 
b) fire prevention techniques and procedures.
 
SSES-FPRR Text Rev. 13 FPRR Rev. 22 1.4-2 c) training and manual fire fighting techniques and procedures for plant personnel and fire brigade.
1.4.3.2  Other Station Employees
 
Instruction shall be provided for all employees with an unescorted security clearance. The instruction shall include, as appropriate, the fire protection program, recognizing the station emergency alarm sirens, and response to a fire related incident, including reporting a fire and
 
evacuating the area.
Instruction shall be provided for security personnel that addresses entry control procedures for outside fire departments and other emergency response agencies, crowd control for personnel exiting the station, and procedures for reporting potential fire hazards observed when touring
 
the facility.
 
Instruction shall be provided to all non fire brigade shift personnel to familiarize them with fire brigade activities and responsibilities.
 
Instruction shall be provided, as appropriate, to those personnel responsible for performing the inspection and maintenance of fire protection equipment.
Employees (when present at the time of a drill) shall participate in a fire exit drill to familiarize them with the evacuation routes and procedures for the individual office/administrative buildings on site. Fire exit drills should be held annually.
 
1.4.3.3  Fire Brigade
: 1) Instruction
 
a) Instruction in the topics listed in (d) below shall be administered to individuals as required to supplement previous experience and training prior to assignment as a fire brigade member.
b) Refresher instruction shall be provided to all fire brigade members on a regularly scheduled basis of not less than four (4) sessions per calendar year. One (1) quarter of grace shall be allowed for make-up of a missed session. The sessions will be repeated at a frequency of not more than 2 years.
c) The instruction shall be provided by qualified individuals, knowledgeable and experienced in fighting the types of fires that could occur in the plant, and in using the types of equipment provided in the plant. Members of the Fire Protection staff may also conduct this training.
d) The scope of this instruction should include the following items:
i) An identification of the fire hazards and associated types of fires that could occur in the plant, and an identification of the location of the hazards, including areas where breathing apparatus is required, regardless of the size of the fire.
 
SSES-FPRR Text Rev. 13 FPRR Rev. 22 1.4-3 ii) Identification of the location of installed and portable firefighting equipment in each area, and familiarization with layout of the plant including access and egress routes to each area.
iii) The proper use of available fire fighting equipment, and the correct method of fighting each type of fire. The types of fires covered shall include electrical fires, fires in cables and cable trays, hydrogen fires, flammable liquids, waste/debris fires, and record file fires.
iv) Indoctrination in the plant fire fighting plan, with coverage of each individual's responsibilities, including changes thereto.
v) The proper use of breathing equipment, communication, lighting, and portable ventilation equipment.
vi) A detailed review of the fire fighting procedures and procedure changes, with particular emphasis on what equipment must be used in particular
 
areas. vii) A review of latest modifications, additions, or changes to the facility or procedures which affect the fire fighting equipment or the fire fighting plan. viii) The proper method of fighting fires inside building and tunnels.
ix) Special instruction shall be provided for fire brigade leaders in directing and coordinating fire fighting activities.
: 2) Hands-On Training/Practice
 
Hands-on training/practice sessions shall be held for fire brigade members on the proper method of fighting various types of fires. These sessions shall provide brigade members with practice in extinguishing actual fires, except in the case of energized cables.
Practice sessions shall be conducted at facilities remote from the nuclear power plant so as not to endanger safety-related equipment. These practice sessions shall be provided annually.
Practice sessions shall also be conducted that require fire brigade members to don protective equipment, including emergency breathing apparatus. These practice sessions shall not necessarily include fire fighting. These practice sessions shall be
 
provided annually.
: 3) Drills
 
Fire brigade drills shall be performed in the plant so that the fire brigade can practice as a team. Drills shall include the following:
 
SSES-FPRR Text Rev. 13 FPRR Rev. 22 1.4-4 a) The simulated use of equipment for the various situations and types of fires which could reasonably occur in each safety-related area.
b) Conformance, where possible, to the established plant fire fighting plans (pre-fire plans). c) Operating fire fighting equipment where practical. This will include self-contained breathing apparatus, communication equipment and portable and/or installed ventilation equipment.
d) Drills shall be performed quarterly for each Operations shift. The minimum number of Fire Brigade drills conducted within a calendar quarter shall be equal to the number of Operations shifts at the station. At least one drill per calendar year for each Operations shift shall be unannounced. Each individual assigned to the Fire Brigade shall participate in at least 2 drills per calendar year. New Fire Brigade members or members who are reassigned to the Fire Brigade after June 30 of a calendar year shall only be required to participate in one (1) drill in that calendar year.
e) Periodically (at least annually), the off-site fire department personnel shall be requested to participate in these drills. These drills shall conform with the facility plan for coordination with off-site fire departments.
f) The drills shall be preplanned to establish the training objectives of the drills. The drills will be critiqued to determine how well the training objectives have been met. At a minimum, the critique shall assess: i) The effectiveness of the Fire alarms, ii) Time required to notify and assemble the Fire Brigade, iii) Selection, placement and use of equipment, iv) Use of the Pre-Fire Plan, v) Each Fire Brigade member's knowledge of their role and ability to perform their assignments, vi) The Fire Brigade Leader's direction of the firefighting effort.
: 4) Organization The Operations Shift Manager - shall not be a member of the fire brigade.
 
1.4.3.4  Off-Site Fire Departments Off-site fire departments shall be offered training annually to include basic radiation principles and practices, typical radiation hazards that may be encountered when fighting fires, and related procedures. This training should also include site access and egress practices and procedures
 
for emergency responders.
 
I \ , .. _j () 1.5 CONTENT AND FORMAT This FPRR is intended to address those fire protection aspects of the plant which are . required to satisfy the requirements delineated in Section 1.1. This report focuses primarily on the demonstration of the capability to bring and maintain both units at Susquehanna SES in a safe shutdown condition in the event of a design basis fire. Section 2.0 of this report provides a listing of terms and definitions to provide clarity and understanding while reviewing this report. Some of the terms are uniquely applicable to the Susquehanna
*Fire Protection Program while others are defined to provide a uniform base of understanding to the reader. Section 3.0 of this report explains the methodology used to perfolTTl the safe shutdown analysis and to demonstrate that both reactor units can be safely shutdown in the event of a fire. Section 4.0 of this report describes the active and passive fire protection features used at Susquehanna SES.* This includes the fire detection and suppression systems, water supply systems, raceway wrappings, cable insulation, etc. Section 5.0 of this report contains an item-,by-item comparison of Susquehanna SES design with the applicable positions of Appendix A to BTP APSCB 9.5-1 and 10CFR50 Appendix R.
* Section 6.0 of this report discusses the fire hazards and plant shutdown methods on a fire area basis. In this section, each fire area of the plant is addressed designating the method to be utilized for achieving and maintaining safe shutdown in the event of a fire. Section 7.0 of this report contains the Appendix R deviation requests required to support the safe shutdown analysis.
Each deviation request addresses plant conditions where a specific Appendix A requirement is not met. The deviation request serves as a means to justify the acceptability of the non-conforming condition based on engineering and fire hazard analysis.
Section 8.0 of this report contains the upper tier fire protection features drawings necessary to understand the technical content of this report and to demonstrate the fire protection features of the -plant. Rev. *10 1.5-1 . G :\Lie Docs\FPRR Approved\Text\Section01
\fp01 _ 0700_ 05.doc SSES-FPRR Text Rev. 11 2.0 DEFINITIONS The following defr~itions are derived using the general industry recognized definition of the term arou~d the time of inception of Appendix R. The terms defined in this section are used throughout this report or in the*post-fire safe shutdown .analysis.
 
===2.1 ADJACENT===
FIRE ZONE An adjacent fire zone is a fire zone having a physical point of contact with a primary fire zone. 2.2 ASSOCIATED CIRCUITS Those cables (safety related, non-safety related, Class 1 E, and non-Class 1 E) that have a physical separation less than that required by Appendix R Section 111.G.2 and: have one of the following:
Common Power Source A common power source with the shutdown equipment (redundant or alternative) and the power source is not electrically protected from the circuit of concern by coordrnated breakers, fuses, or similar devices! or Spurious Operation A connection to circuits of equipment whose spurious operation wou!d adversely effect the shutdown capability (e.g., RHR/RCS isolation valves, ADS valves, instrumentation, steam bypass, etc.), or Common Enclosure A common enclosure (e.g., raceway, panel, junction, etc.) with the shutdown cables (redundant or alternative) and, are not electrically protected by circuit breakers!
fuses or simHar devices, or will allow the propagation of the fire into the common enclosure.
 
===2.3 BUFFER===
ZONE A buffer zone is a fire zone which acts as a spatial barrier between two adjacent fire areas. Using the fire spread limitation, and by assuring multiple paths within two or more adjacent fire zones (referred to as buffer zones), adequate separation between fire areas with different safe shutdown paths is provided without fire barriers (See . Deviation Request No. 7).
* FPRR Rev. 11 2.0-1 SSES-FPRR Text Rev. 11 2.4 CABLE A conductor with insulation, or a stranded conductor with or without insulation and other coverings (single-conductor cable) or a combination of conductors insulated from one another {muttrple-conductor cable). 2.5 CABLE HIT A safe shutdown cab!e, required to support a safe shutdown component for a particular safe shutdown path, that is located in a fire zone which credits that particular safe shutdown path as the required safe shutdown path in the event of a fire in that fire zone (i.e. potential Appendix R non-compliance).
The cable could also be a cable associated wrth a component whose spurious operation could affect the required safe shutdown path. 2.6 CATEGORY I COMPONENT A safe shutdown component which may be required to perform a safe shutdown function in the event of potential fire damage rn the fire zo,ne where the component is located. 2.7 CIRCUIT A conductor or system of conductors through which an etectric current is intended to flow. 2.8 CIRCUIT FAILURE MODES The following are the circuit failure modes that are postulated in the Post-Fire Safe Shutdown Analysis as a result of a fire: Hot Short A fire induced insulation breakdown between conductors of the same cable, a different cable or from some other external source resulting in a compatible but undesired impressed voltage on a specific conductor.
Open Circuit A fire induced break in a conductor resulting
*in a loss of circuit continuity.
Short-to-Ground A fire induced breakdown of a cable 1 s insulation system resulting in the potential on the conductor being applied to ground potential.
FPRR Rev. 11 2.0-2 SSES-FPRR Text Rev. 11 2.9 COLD SHUTDOWN Cold shutdown occurs when the reactor mode switch is in the shutdown position and the average reactor coolant temperature is less than 212&deg; Fat saturated conditions.
Both the Technical Specification and the FSAR have exercised conservatism by using the value of lass than or equal to 200&deg; F for the Cold Shutdown Condition Definition.
2.10 COLD SHUTDOWN REPAIR Repairs made to fire damaged equipment required to support achieving or maintaining cold shutdown for the required safe shutdown path. 2.11 CONDUCTOR A single 'wire' within a cabfe; conductors could also .be considered a circuit or a cable. 2.12 DESIGN BASIS FIRE A postulated event used in the post-fire safe shutdown analysis.
See Exposure Fire. 2.13 ENCLOSURE An identifiable housing such as a cubicle, compartment, terminal box, panel, or enclosed raceway used for electrical equipment or cables. 2.14 EXPOSURE FIRE An exposure fire is a fire in a given area that involves either in situ or transient combustibles and is external to any structures, systems, or components located in or adjacent to that same area. The effects of such fire (e.g., smoke, heat, or ignitton) can adversely affect those structures; systems, or components important to safety. Thus, a fire involving one train of safe shutdown equipment may constitute an exposure fire for the redundant train located in the same area, and a fire involving combustibles other than either redundant train may constitute an exposure fire to both redundant trains located in the same area. 2.15 FIREAREA The tenn "fire area" as used in Appendix R means an area sufficrentJy bounded to withstand the hazards associated with the fire area and, as necessary, to protect important equipment within the fire area from a fire outside the area. A fire area may consist of one or more fire zones.
* FPRR Rev. 11 . 2.0-3 SSES-FPRR Text Rev. 11 Fire area boundaries need not be completely sealed with floor-to-ceiling and/or to-wall boundaries.
Where such boundaries are not floor-to-ceiling or floor-to-floor boundaries with all penetrations sealed to the fire rattng of the boundary, an evaluation is performed to assess the adequacy of the fire area boundary to withstand the hazard associated with the area and to protect safe shutdown equipment within the area from a frre outside of the area.
* Fire area boundary components have been justified to be acceptable rn devfation requests and/or fire hazard analysis.
The primary containment wall are considered to be acceptable fire area boundaries because of their unique construction and since the primary containment is inerted. 2.16 FIRE BARRIER Those components of construction (walls, floorsr and their supports), including beams, joists, columns, penetration seals or closures, fire doors 1 fire dampers and efectrical raceway fire wrapping that are rated by approving laboratories in hours of resistance to fire and are used to prevent the spread of fire. 2.17 FIRE LOADING The amount of combustible material present in a given room, zone or area, usually expressed in the total heat released {BTU) per square foot of floor area of each fire zone and converted to equivalent minutes of fire duration.
2.18 FIRE PROTECTION PROGRAM The fire protection policy for the protection of structures, systems, and components important to safety at each plant and the procedures, equipment, and personnel required to implement the program at the plant site. The fire protection program shall extend the concept of defense-in-depth to fire protection in fire areas important to safety, with the following objectives:
a) To prevent fires from starting; b) To detect rapidly, control, and extinguish promptly those fires that do occur; c} To provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant. 2.19 FIRE RATING The time in minutes or hours that materials or assemblies have withstood a standard fire exposure as establlshed by testing requirements such as ASTM E-119 (NFPA 251 ). FPRR Rev. 11 2.0-4 SSES-FPAR Text Rev. 11
* 2.20 FIRE SUPPRESSION Refers to the capability to control and extinguish a fire (tire fighting).
Manual fire suppression activities refer to the use of hoses or portable extinguishers.
Fixed suppression refers to permanently installed!
non-portable suppression systems that are aufomatically actuated by fire or smoke sensing devices {e.g., detectors and/or fusible links) or manually actuated by plant personnel.
2.21 FIRE UNIT A plant fire could cause impacts to both of the units at SSES. The unit primarHy affected by the fire. For example, Unit 1 is the "fire unit" for a fire in the Unit 1 Reactor Building.
For common plant areas where either unit could be the "fire un if', the tire safe shutdown analysis has designated which unit rs to be considered to be the fire unit. The unit which is not the "fire unit" is designated as the unon-fire unif'. Refer to the definition of 11 non-tire unit" for additional information.
2.22 FIRE ZONE The subdivision of fire area(s) for analysis purposes that is not necessarily bounded by fire rated barriers.
2.23 FLOW DIVERSION COMPONENT A flow diversion component for Appendix R safe shutdown analysis purposes is a component that can divert fluid flow from any safe shutdown system or the reactor pressure vessel. 2.24 FREE OF FIRE DAMAGE The structure, system or component under consideration is capable of performing its intended function during and after the postulated fire, as needed. It may perform this function automaticalty, by remote control, or by manual operations.
2.25 HlGH IMPEDANCE FAULT An electrical fault below the trip point for a breaker on an individual circuit. See 'Multiple high impedance fault'. 2.26 HIGH/LOW PRESSURE INTERFACE A valve whose spurious opening could result in a loss of Reactor Pressure Vessel inventory and, due to the tower pressure rating on the down stream piping, an interlacing LOCA. FPRR Rev. 11 2.0-5 SSES-FPRR Text Rev. 11 2.27
* HOT SHORT See 'Circuit failure modes'. 2.28 HOT SHUTDOWN Hot shutdown occurs when the reactor mode switch is in the shutdown position and the average reactor coolant temperature is greater than 212&deg; F at saturate~
conditions.
Both the Technical Specification and the FSAR have exercised conservatism by using the value of greater than 200&deg; F for the Hot Shutdown Condition Definition.
2.29 IN-SITU COMBUSTIBLE In-situ combustibles are combustible materials which are permanently installed in the plant during initial construction and through the modification process. 2.30 INTERVENING COMBUSTIBLES An intervening combustible is a material which can propagate fire from one location to another. This does not include cables in conduit, cables in wrapped cable tray or transient combustibles.
2.31 ISOLATION DEVrCE A device in a circuit which prevents maltunctrons in one section of a circuit from causing unacceptable influences in other sections of the circuit or other circuits.
2.32 LOCAL CONTROL Operation of safe shutdown equipment on the required safe shutdown path using remote controls (e.g., controt switches) specifically designed for this purpose from a location other than the main control room. 2.33 MANUAL OPERATION Operation of safe shutdown equipment on the required safe shutdown path by an operator when automatic, local or manual controls are no longer available (e.g. opening of a motor operated valve using the hand wheel). 2.34 MANUAL CONTROL Operation of safe shutdown equipment on the required safe shutdown path using the control room control devices (e.g., switches) in the event that automatic control of the equipment is either inhibited based on plant procedures or unable to function as a result of fire induced damage. FPRR Rev. 11 SSES-FPRR Text Rev. 11 2.35 MECHANICAL COMPONENT A component supporting safe shutdown which does not have an electrical interface (e.g. tank. accumulator, turbine-driven pump, heat exchanger).
2.36 MULTIPLE HIGH rMPEDANCE FAULT($) A condition where multiple circuits fed from a single power distribution source each have a high impedance fault. See 1 High Impedance Fautt'. 2.37* NON-FIRE UNIT The unit not experiencing the fire. Depending on the fire conditions, this unit may atso need to be safely shutdown.
This definition applies to fires outside of the Control Room only. For a fire in the Control Room! both units are considered to be the ''fire unit". 2.38 OPEN CIRCUIT See 'Circuit failure modes*. 2.39 PRIMARY FIRE ZONE The primary fire zone is the fire zone where the fire is assumed to be initiated.
2.40 RACEWAY Any channel that is desfgned and used expressly for supporting wires, cable. or bus bars. Raceways consist primarily of, but are not restricted to, cable trays, wireways, conduits, and interlocked annor enclosing cabte. 2.41 REMOTE CONTROL Plant design features that altow the operation of equipment through a combination of electrically powered control switches and relays. Remote control can typically be performed from the main controf room or from local control stations.
including the remote shutdown panel and other locations with control capability outside of the main control room. 2.42 REMOTE SHUTDOWN LOCATION A plant location outside of the main control room with remote control capability.
FPRR Rev. 11 2.0-7 SSES*FPRR Text Rev. 11 2.43 REMOTE SHUTDOWN PANEL The plant location inctuded within the plant design for the purpose of satisfying the requirements of 10 CFR 50 Appendix A General Design Criteria 19. If electrical isolation and redundant fusing is provided at t~rs location, it may also be suitable for use in achieving and maintaining safe shutdown for an event such as a main control room fire. 2.44 REPAIRS A repair constitutes an action which alters the plant equipment in order to restore the function of equipment that has been damaged by the fire. For Appendix A compliance, such repairs are only permitted to restore the capability to achieve cold shutdown and the repair activity must be controlled by procedures and all material required for the repair activity must be readily available on site. Repairs for lil.G shutdown must be completed within 72 hours after the start of the fire. Repairs for 111.L must be compreted rn a time frame such that cold shutdown can be achieved within 72 hours. 2.45 REQUIRED SAFE SHUTDOWN PATH . The safe shutdown path selected for achieving and maintaining sate shutdown in a particular fire area. This safe shutdown path must be capable of performing all of the required safe shutdown functions.
2.46 REQUIRED SAFE SHUTDOWN SYSTEM A system that performs one of the require~ safe shutdown functions and is, therefore, a part of the required safe shutdown path for a particular fire area. 2.47 REQUIRED SAFE SHUTDOWN EQUIPMENT/COMPONENT Equipment th?t is required to either function or not malfunction in order that the required safe shutdown path will be capable of achieving and maintaining safe shutdown in a particular fire area. 2.48 REQUIRED SAFE SHUTDOWN CABLE/CIRCUIT Cable/circuit required to support the operation or prevent the maloperation of required safe shutdown equipment in a particular fire area. 2.49 SAFE SHUTDOWN For Appendix R Section IU.G, Safe Shutdown is defined as the ability, wrth the plant starting from 100% power operation, to achieve and maintain hot shutdown with those systems required for cotd shutdown able to be repaired within 72 hours. FPRR Rev. 11 2.0-8 SSES-FPRR Text Rev. 11 For Appendix R Section HI.L, Safe Shutdown is defined as the ability, with the plant starting from 100% power operation, to achieve cold shutdown conditions within 72 hours and to maintain cotd shutdown conditions thereafter.
2.50 SAFE SHUTDOWN CAPABILITY Redundant Any combination of equipment and systems with the capability to perform the shutdown functions of reactivity control, inventory control, decay heat removal, process monitoring and associated support functions when used within the capabilities of its design. Alternative Where none of the hot shutdown trains of the redundant safe shutdown capability is 11 free of fire damage 0 and dedicated*equipment is not provided, the shutdown systems used are classified as alternative.
Dedicated A system or set of equipment specifically installed to provide one or more of the post-fire safe shutdown functions of inventory control, reactivity control, decay heat removat process monitoring.
and support as a separate train or path. 2.51 SAFE SHUTDOWN EQUIPMENT/COMPONENT Equipment included in the analysis of post-fire safe shutdown capability to demonstrate compliance with Appendix R. 2.52 SHORT-TO-GROUND See 'Circuit failure modes'. 2.53 SAFE SHUTDOWN PATHS A specific combination of analyzed systems and equipment capable of achieving and maintaining a safe shutdown condition during and followtng an exposure fire. 2.54 SPURIOUS OPERATION The inadvertent operation or repositioning of a piece of equipment.
FPRR Rev. 11 2.0-9 SSES-FPRR Text Rev. 11 2.55 TRANSIENT COMBUSTIBLES Transient combustibles are combustible materials that are not permanently installed in the plant through the plant modification process. Transient combustibles are administratively controlred.
2.56 WRAPAROUND AREA On Elevations 683'-0, 719'-1 and 749'-1 of both reactor buildings, an area 66 feet wide has been designated as the Wraparound Area. The Wraparound Area has no physical boundaries but ts used to provide spatial separation between the north and south sides of the reactor buildrngs, each of which generally contains opposite paths of safe shutdown equipment.
Within the Wraparound Area, both paths of safe shutdown equtpment are protected, unless specifically identified in a deviation request or fire hazards analysis.
The concept of the Wraparound Area is presented in Deviation Request No. 4. FPRR Rev. 11 2.0-10 SSES-FPRR Text Rev. 12 3.0 SAFE SHUTDOWN ANALYSIS FPRR Rev. 13 3.0-1 SSES-FPRR Text Rev. 11
 
==3.1 INTRODUCTION==
 
The purpose of this section is to identify the methodology used by PPL Susquehanna, LLC {PPL) to demonstrate that both units at the Susquehanna Steam Electric Station {$SES) can be brought to and maintained in a safe shutdown condition assuming a single fire in any fire area. PPL has committed to perform the post-fire safe shutdown analysis in accordance wtth 10CFR50 Appendix R Sections 111.G, IU.J, lft.L (as required by 111.G.3) and 111.0. The post-fire safe shutdown analysis for SSES is a systems based approach.
Specific safe shutdown paths are developed and the availability of one of these paths is assured in each fire area. Credit is not assumed for any system that has not been rigorously determined to be free of fire damage in a particular fire area. Equipment with the potential to spuriously operate and to affect the ability of the required safe shutdown path to achieve and maintain safe shutdown is identified.
Equipment with this spurious operation potential is included on any safe shutdown path that it could affect. Fire induced impacts to this equipment is addressed in the same manner as fire induced impacts to equipment on the required safe shutdown path for a particular fire area. Depending on the fire conditions.
a singre fire in one unit could require that both units be brought to the safe shutdown condition.
As such, the methodology covered in this report addresses safely shutting down both units from the 100% power operating condition to the cold shutdown c.ondition.
For each plant area, a "fire unW and a "non-fire unit" shutdown path are designated.
The "fire unit'1 is the unit that is primarily affected by the fire. For example, for a fire in the Unit 1 Reactor Building, Unit 1 would be designated as the "fire unir. The "non-fire unit" is the unit not designated as the ''fire unit". In the previous example. Unit 2 would be the "non-fire unit". For post-fire safe shutdown meeting the requirements of Appendix R Sections 111.G.1 and 2, offsite power may be used to achieve and maintain safe shutdown provided it has been demonstrated that the fire will not cause a loss of offsite power. Offsite power has been demonstrated to be unaffected by the fire in certain fire areas. In most fire areas, however, the onsite power provided by the Emergency Diesel Generators is used to achieve and maintain post-fire safe shutdown.
For alternative post-fire safe shutdown meeting the requirements of Appendix R Sections 111.G.3 and 111.L, the abilfty to achieve and maintain safe shutdown must be demonstrated for the conditions of offsite power available and offsite power not available.
This requirement is satisfied for SSES by assuming that offsite power is lost for the alternative shutdown path. The Control Room Fire Area is the only fire area where alternative shutdown is used at SSES. Table 3.1-1 is a flow chart that provides an overview of the method used to bring SSES into compliance with Appendix R Sections 111.G and 111.L. FPRR Rev. 13 V:\NFM3\Work Areas\Pegues\FPRR TEXT 3_1.00C Table Rev. 11 I CABLE HITS FPRR Rev. 11 SSES-FPRR TABLE 3.1-1 APPENDIX R COMPLIANCE FLOW CHART APPENDIX R SECTION 111.G AND 111.L SAFE SHUTDOWN CRITERIA i SAFE SHUTDOWN SYSTEM AND COMPONENT IDENTIFICATION i SAFE SHUTDOWN PATH IDENTIFICATION
! SAFE SHUTDOWN CABLE, RACEWAY AND ELECTRICAL COMPONENT I DENTIFICATION DEVELOPMENT OF FIRE AREAS ! EVALUATION OF POTENTIAL CABLE I AND COMPONENT NON-COMPLIANCES l COMPONENT HITS I DEVELOP AND IMPLEMENT STRATEGIES TO MITIGATE I THE FIRE EFFECTS OF EACH CABLE/COMPONENT HIT I I ON SAFE SHUTDOWN CAPABILITY IN EACH FIRE AREA Strategies for Mitigation
: 1. Reroute Cable of Concern 2. Protect Cable of Concl!rn 3. Perform Manual Action : 4 , Perform Repair for Cold Shutdown only 5. Develop Deviat i on 6. Develop Generic Letter 86-1 O Evaluation
: 7. Identify other equiipment to perform same function Items 3 & 4 involve addressing requirements for timing. emergency lighting. manpower communications and dedicated repair equipment.
Page 1 of 1 SSES-FPRR Text Rev. 11 3.2 CRITERfA 3.2.1 1 OCFR50 Appendix R Section 111.G.1 and 2 The criteria used to demonstrate safe shutdown capability in accordance with Appendix R Sections 111.G.1 and 2 is depicted in Table 3.2-1 and described as follows~ Fire protection features shall be provided for structures, systems and components important to safe shutdown.
These features shall be capable of limiting fire damage so that:: a. One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or the emergency control station(s) are free of fire damage; and b. Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be repaired within 72 hours. Free of fire damage is achieved when the structure, system or component under consideration is capable of performing its intended function during and after the postutated fire, as needed. It may perform this function automatically, by remote control or by manual operations.
During the post.fire shutdown, the reactor cootant system process variables shall be maintained within those predicted for a* loss of normal a.c. power, and the fission product boundary integrity shall not be affected; Le. there shall be no fuel clad damage, rupture of any primary cootant boundary, or rupture of the containment boundary.
Deviation Request No. 33 describes that the process variables when using ADS and Core Spray as a redundant post-fire safe shutdown path may be worse than predicted for a loss of normal a.c., but that there will be no affect on the integrity of fission product boundary.
When using ADS and Core Spray as a redundant post-fire safe shutdown path there will be no fuel clad damage, no rupture of the primary coolant boundary and no rupture of the primary containment.
Additionally, Deviation Request No. 33 concludes that the reactor coorant makeup function can maintain the reactor coolant lever above the top of active fuel when using this redundant post*fire safe shutdown path. Shutdown systems installed to ensure post-fire safe shutdown capability need not be designed to meet seismic Category r crrteria, single failure criteria, or other design basis accident criteria, except where required for other reasons, e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage. No design basis event or non-fire damage induced equipment failure is considered in conjunction with a fire for this section. FPRR Rev. 11 3.2*1 SSES-FPRR Text Rev. 11 The safe shutdown equipment and systems for each fire area shall be known to be isolated from associated non-safety circuits fn the fire area so that hot shorts, open circuits or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment.
Except as provided for in Sectron 3.2.2 1 where cables or equipment, including assocjated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:
: a. Separatron of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such Hre barriers shall be protected to provide fire resistance equivalent to that required of the barrier; b. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and automatic fire suppression system shall be installed in the fire area; or c. Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area. Each of these separation approaches may be supplemented with or replaced by deviatron requests or fire hazards analysis that demonstrate an equivalent level of protection to that required above. Deviation requests are used when it is intended that the alternative compliance approach is to be submitted to the NRC for their concurrence.
Fke hazards analysis are an equivalent alternative to deviation requests and are to be prepared using the guidance in NRC Generic Letter 86-1 o. There is, however, no regulatory requirement to submit either deviation requests or fire hazards analysis to the N RC for acceptance.
Maintaining these on file and available for NRC review is an acceptable approach.
For those fire areas where the separation requirements described above cannot be met, the requirements of Appendix A Section 111.G.3 apply. FPRR Rev. 11 3.2 .. 2 SSES-FPRR Text Rev. 11 3.2.2 1 OCFR50 Appendix A Section 111.L (As Required by Section 111.G.3) Appendix A Section Ill. L criteria has been used to demonstrate alternative or dedicated shutdown capability.
Compliance with Appendix R Section UI.L follows directly from Section lll.G.3 for areas where the separation features of Section IH.G.2 cannot be met. In accordance Wfth Appendix R Section 111.G.3, the following requirements apply to the Alternative Shutdown Capability.
Alternative shutdown capability and its associate*d circuits independent of cables, systems or components in the areas, room or zone under consrderation, shall be provided:
: a. Where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section; or b. Where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppress;on systems. rn addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration.
Frre Area CS-9, Control Room, is the only fire area where alternative shutdown is provided.
Fire Area CS-9 does not have a fixed suppression system throughout the tire area. Deviation Request No. 23 describes the fire protection features in Fire Area CS-9, Control Room Fire Area. This deviation request justifies the lack of a fixed suppression system for Fire Area CS-9. The systems and equipment needed for alternative post-fire safe shutdown are those systems necessary to perform the following shutdown functions:
reactivtty control, reactor coolant makeup, reactor depressurization and heat removal, process monitoring and associated support functions.
The criteria as stated in Appendix R Section 111.L for systems perfonning these shutdown functions are as follows: 1. Alternative or dedicated shutdown capability provided for a specific fire area shall be able to (a) achieve and maintain sub-critical reactivity conditions in the reactor; (b) maintain reactor coolant inventory; (c) achieve and maintain hot shutdown; (d) achieve cold shutdown conditions within 72 hours; and {e) maintain cold shutdown condibons thereafter.
During the post-tire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal a.c. power! and the fission product boundary integrity shaU not be affected; i.e. there shall be no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary.
FPRR Rev. 11 SSES-FPRR Te>Ct Rev. 11 2. The performance goals for the shutdown functions shall be: a. The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.
: b. The reactor coolant makeup function shall be capable of maintaining the reactor coolant level above the top of the core for BWRs. c. The reactor heat removal function shall be capable of achieving and maintaining decay heat removal. d. The process monitoring function shafl be capable of providing direct readings of the process variables necessary to perform and control the above functions.
: e. The supporting functions shall be capable of providing the process cooling, lubrication, etc., necessary to permit the operation of the equipment used for safe shutdown functions.
: 3. The shutdown capability for specific fire areas may be unique for each such area, or it may be one unique combination of systems for all such areas. In either case, the alternative shutdown capabiHty shall be independent of the specific fire area{s) and shall accommodate post-fire conditions where off-site power ts available and where off-srte power is not available for 72 hours. Procedures shall be in effect to implement this capability.
: 4. If the capability to achieve and maintain cotd shutdown will not be available because of fire damage, the equipment and systems comprising the means to achieve and maintain the hot shutdown condition shall be capable of maintaining such conditions until cold shutdown can be achieved.
If such equipment and systems will not be capable of being powered by both onsite and off-site electric power systems because of fire damage, an independent onsite power system shan be provided.
The number of operating shift personnel, exclusive of fire brigade members, required to operate such equipment and systems shall be on site at all times. 5. Equipment and systems comprising the means to achieve and maintain cold shutdown conditions shall not be damaged by fire; or the fire damage to such equipment and systems shall be limited so that the systems can be made operabte and cold shutdown can be achieved within 72 hours. Materials for such repairs shalt be readily available on site and procedures FPRR Rev. 11 3.2-4 Text Rev. 11 SSES-FPRR shall be in effect to implement such repairs. It such equipment and systems used prior to 72 hours after the fire will not be capable of being powered by both onsite and off-site electric power systems because of fire damage, an independent onsite power system shall be provided.
Equipment and systems used after 72 hours may be powered by off-site power only. 6. Shutdown systems installed to ensure post-fire shutdown capability need not be designed to meet seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons, e.g., because of interface with or impact on existing safety systems. or because of adverse valve actions due to fire damage. 7. The safe shutdown equipment and systems for e.ach fire area shall be known to be isolated from associated non-safety circuits in the fire area so that hot shorts, open circuits or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment.
The separation and barriers between trays and conduits containing associated circuits of one safe shutdown division and trays and conduits containing circuits or safe shutdown cables from the redundant division, or the isolation of these associated circuits from the safe shutdown equipment, shall be such that a postulated fire involving associated circuits will not prevent safe shutdown.
 
====3.2.3 10CFR50====
Appendix A Section tll.J Appendix R Section 111.J requires that emergency lighting with at least an 8 hour battery power supply be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto. Emergency lighting as outlined in thfs section is not required for operation of safe shutdown equipment when the operation of such equrpment is not required within the first 8 hours of the fire event. 3.2.4 1 OCFRSO Appendrx A Section m.o Appendix R Section 111.0 requires that the reactor coolant pump be equipped with an oil collection system it the containment is not inerted during normal operation.
The containment for Susquehanna Steam E!ectric Station Units 1 and 2 ls inerted and, therefore, Appendix R Section 111.0 does not apply. FPRR Rev. 11 3.2-5 Table Rev. O 111.G.1 Fire protection 1 features shall be provided for*structures, systems. ---...-and components important to safe shutdown 111.G.2 Ensure that one of the redundant trains is free of fire damage(*)
by one of the followin : eparation of cables and equipmen and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no ntervening combustible or fire hazards ( .. ) SSES-FPRR Table 3.2-1 One train of systems necessary to acflieve and maintain hor shutdown is fire damager) Systems necessary to acflieve and maintain cold shutdown can be repaired within 72 hours. Identify an*d locate the cables and equipment.
including associated non* safety circuits that could prevent operation or cause matoperation due t 2"1----1 hot shorts, open circuits, or shorts to nclosure of cable and equipmen and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating ( .. } '-=----1------
ground, of redundant trains of systems necessary to achieve and maintain hot shutdown.
Separation of cables and equipment and associated safety circuits of redundant trains by a fire barrier having a 3-hour rating ( .. ) Ensure that fire detectors and l an automatic fire suppression
~-------+<
system is installed in the area. 111.G.3 Alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the areas, room or zone under cons;deration.
shall be provided.
r*J Free of fire damage Is achieved when the structure, system or component under consideration Is capable of performing Its intended function during and after the postulated fire, as needed. It may perform this function automat/cally, by remote control, or by manual operations.
(**) Deviations or GL 86-10 Evaluations with 10CFR50.59 Safety Determinations may be developed as necessary.
(0*) For simplicity, the mitigation options for Inside non-lnerted containments have been omitted from this diagram. FPRR Rev. 11 Done ....,.__ __ 1) '----------..-/
Page 1 of 1 SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-1
 
===3.3 METHODOLOGY===
PPL's post-fire safe shutdown analysis for the Susquehanna Steam Electric Station Units 1 and 2 is performed in accordance with the requirements and guidance of Appendix R Section III.G.1, III.G.2 and III.G.3 (which invokes III.L) as outlined in the methodology described below. This post-fire safe shutdown analysis demonstrates and assures the availability to achieve and maintain safe shutdown for the condition of a single fire in any plant fire area. It accomplishes this by assuring that systems, components, and raceway for one safe shutdown path for each fire area  (a) capable of performing all of the required hot shutdown functions is free of fire damage, and,(b) if required to achieve and maintain cold shutdown, is capable of being repaired within the required time period.  [Note: For Section III.G.1 and 2, the required time period is 72 hours. For Section III.G.3 (III.L), repairs must be completed and cold shutdown achieved within 72 hours.] 3.3.1 Appendix R Sections III.G and III.L Three (3) basic safe shutdown paths are used at the Susquehanna Steam Electric Station to demonstrate the ability to achieve and maintain post-fire safe shutdown in accordance with the requirements of Appendix R Sections III. G.1, III.G.2 and III.G.3 (which invokes III.L). Safe Shutdown Paths 1 and 3 are used for achieving and maintaining post-fire safe shutdown in the event of a single fire in any fire areas outside of the Control Room Fire Area, CS-9. These safe shutdown paths are classified as redundant safe shutdown paths and the methodology applied to these safe shutdown paths is governed by the requirements of Appendix R
 
Section III.G.1 and III.G.2. Safe Shutdown Path 2 is used for achieving and maintaining post-fire safe shutdown in the event of a fire in the Control Room Fire Area, CS-9. This safe shutdown path is classified as an Alternative Safe Shutdown Path and the methodology applied to this safe shutdown path is governed by the requirements of Appendix R Section III.G.3 (which invokes III.L). There are many similarities between the requirements for Redundant post-fire safe shutdown contained in Appendix R Sections III.G.1 and III.G.2 and for Alternative post-fire safe shutdown contained in Appendix R Section III.G.3 (which invokes III.L). The goal of post-fire safe shutdown is to assure that a single fire in any single plant fire area will not result in any fuel cladding damage, rupture of the primary coolant boundary or rupture of the primary containment. This goal is accomplished by determining those functions important to safely shutting down the reactor and assuring that systems with the capability to perform these functions are not adversely impacted by a single fire in any plant fire area. The required safe shutdown functions are: (1) Reactivity Control; (2) Pressure Control; (3) Inventory Control; and (4) Decay Heat Removal. To accomplish the required safe shutdown functions, certain support system functions (e.g. power, ventilation) and process monitoring capability (e.g. reactor level and pressure indication) are also required.
SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-2 In addition, it must be assured that fire induced spurious operations do not occur that can prevent equipment in the required safe shutdown path from performing its intended safe shutdown function. The spurious operations that present a potential concern for the safe shutdown functions described above are: (1) those that can cause a loss of inventory in excess of make up capability from the reactor; (2) those that can cause a flow diversion or a flow blockage in the safe shutdown systems being used to accomplish the inventory control function; (3) those that can cause a flow diversion or a flow blockage in the safe shutdown systems being used to accomplish the decay heat removal function; and (4) those that can cause an inadvertent overfill of the reactor. The acceptability of the current design features of the BWR to mitigate the effects of an inadvertent reactor vessel overfill condition as a result of either a fire or equipment failure has been addressed by the BWROG in GE Report No. EDE 07-0390 DRF# A00-03773 dated March 30, 1990 in response to NRC Generic Letter 89-19. The NRC subsequently accepted the BWROG Position in a Safety Evaluation dated June 9, 1994. Based on commitments made to the NRC in PLA-4505 dated December 6, 1996, however, preventing an inadvertent overfill of the reactor vessel has been included as a consideration in the SSES post-fire safe shutdown analysis. In the sections that follow, any specific differences between the governing requirements for these safe shutdown paths are highlighted where necessary. 3.3.1.1  Safe Shutdown System and Component Identification As discussed above, the following safe shutdown functions were considered in choosing the systems and components required for safe shutdown:  reactivity control, reactor coolant makeup, reactor depressurization and heat removal, process monitoring, and associated support functions. The first step in performing the safe shutdown analysis was to identify the systems that could be used to perform the safe shutdown functions. Various safe shutdown paths were originally evaluated to shutdown the dual unit plant for the conditions described above. Two primary redundant safe shutdown paths were selected. These paths are the Division I and Division II trains of ADS/Core Spray, Alternate Shutdown Cooling using the Core Spray system and Suppression Pool Cooling. These paths have been identified as Paths 1 and 3, respectively. In certain fire areas, as discussed in Section 6.2 of this document, offsite power sources are credited for Safe Shutdown Path 3 because it has been demonstrated that the fire cannot cause a loss of offsite power and, as such, offsite power will be available for fires in these fire areas. In addition, HPCI would also be available to provide a source of high pressure make up to the reactor in the event of a fire in this fire area. This additional source of high pressure make up is in addition to the low pressure make up capability provided by core spray on Path 3. These paths are incorporated into our symptom based emergency operating procedures and off normal procedures and are discussed in FSAR Subsections 15.2.9, 15.6.4.2.1.1 and 15A.6.5.3. These two paths offer good electrical separation between the different divisions comprising the paths so as to limit the number of potential non-compliant cables and to reduce the number of associated circuit concerns.
SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-3 The capability to simultaneously achieve safe shutdown of both units has been assured by protecting safe shutdown Path 1 and/or 3 for both units in each fire area. In addition, HPCI and its required associated support systems and/or RCIC and its required associated support systems are protected for the unit not experiencing the fire. To assure the availability of an adequate steam supply for operating either HPCI or RCIC, the fire induced spurious operation of the SRVs is prevented on the non-fire unit. SRV depressurization capability is also provided for the unit not experiencing the fire. On Path 1, SRV depressurization capability is available from the Control Room. On Path 3, which uses primarily Division II equipment, SRV depressurization capability is provided from the Lower Relay Room by use of the keylock switches. This operator action is required on Path 3 because all 16 SRVs are powered from Division I power. Additionally, breakers for the Feedwater Stop Valves, HV-B21-1/2F011A/B are opened as a part of the plant start up procedure to assure that a fire induced spurious closure of these valves in the HPCI/RCIC flow path inside of primary containment cannot cause a flow blockage for these systems. In the event of a fire that results in the need to safely shutdown both units, this allows the non-fire unit to be maintained in a stable hot shutdown condition while the fire unit is safely shutdown. Subsequent to safely shutting down the fire unit, the non-fire unit is brought to a safe shutdown condition. With the exceptions and clarifications described below, one of these primary redundant safe shutdown paths is credited for achieving and maintaining post-fire safe for all fire areas outside of the Control Room. (1) Fire Areas R-1D, Unit 1 Valve Access Area, and R-2D, Unit 2 Valve Access Area contain both divisions of the Core Spray injection valves for their respective unit, HV E21 1/2F004A/B and HV E21 1/2F005A/B. Because of this plant design feature, a different safe shutdown path is used to assure the ability to achieve and maintain safe shutdown in these two fire areas. In these fire areas, RCIC, Division I RHR Suppression Pool Cooling and Division I RHR Shutdown Cooling are assured to be available for safely shutting down the fire unit. For the non-fire unit, Path 3 is assured to be available. (2) Onsite power provided by the emergency diesel generators is used for achieving post-fire safe shutdown in all fire areas, except Fire Area D-1, Diesel Generator A, and D-3, Diesel Generator C. In these fire areas, offsite power is used to support post-fire safe shutdown.(3) In Fire Area D-5, Diesel Generator E, the protected safe shutdown path is the same as the protected safe shutdown path for the diesel generator for which Diesel Generator E is substituted. When Diesel Generator E is not substituted for one of the four (4) diesel generators, it has been evaluated to have no impact on the ability to achieve and maintain post-fire safe shutdown should a fire occur in Diesel Generator E. (4) Fire Area R-1C, Unit 1 Primary Containment, and R-2C, Unit 2 Primary Containment, are inerted with nitrogen during normal plant operation. As such, the environment will not sustain a fire and no safe shutdown path is analyzed for these fire areas.
Path 2, or the Alternative Shutdown Path, is based on evacuation from the Main Control Room, and shutting down the plant from each unit's respective Remote Shutdown Panel (RSP). In the event that an MOV required for operation at the RSP is damaged by a hot short from a Control Room fire that bypasses the protective devices, i.e. torque and limit switches, on the valve, safe shutdown is achieved from the RSP by depressurizing the reactor to below the shut-off head for SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-4 the RHR System and entering RHR in the alternate shutdown cooling mode of operation. In this mode of operation, the reactor vessel inventory make-up and the decay heat removal safe shutdown functions are accomplished using the same equipment in the RHR System. The use of this shutdown methodology has been accepted by the NRC in a Safety Evaluation Report dated October 21, 1997. All of the safe shutdown systems discussed below are manually operated. No automatic functions are protected from the effects of fires. Spurious system operation as a result of fire induced failures which affect the automatic initiation logic have been evaluated to assure that these will not have an adverse impact on the ability to achieve and maintain safe shutdown. Reactivity control on all paths is performed by portions of the Reactor Protection System and the Control Rod Drive System (SCRAM function). The Appendix R Safe Shutdown Analysis assures either a manual scram from the Control Room or, where necessary, a scram by venting the instrument air header locally. The Alternative Shutdown Path utilizes a manual SCRAM from the Main Control Room prior to evacuation of the Control Room. Reactor coolant makeup is provided by different divisions of the Core Spray System for Paths 1 and 3 and by RCIC and RHR injection on the Alternative Shutdown Path (Path 2). In certain fire areas, as discussed in Section 6.2 of this document, HPCI would also be available to provide a source of high pressure make up to the reactor in the event of a fire in this fire area. This additional source of high pressure make up is in addition to the low pressure make up capability provided by core spray on path 3. MSIV closure is relied upon for all shutdown paths. This simplifies the analysis by making shutdown paths the same whether or not off-site power is available. If the MSIV's do not isolate automatically, they are isolated manually. For the Alternative Shutdown Path, Path 2, credit is taken for manually closing the MSIV's prior to evacuating the Control Room. The use of this additional operator action prior to Control Room evacuation has been accepted by the NRC in a
 
Safety Evaluation Report dated October 21, 1997. Reactor depressurization is provided by ADS SRVs on Paths 1 and 3, as described in Deviation Request No. 33. On Path 2, reactor depressurization can be performed by opening one of three specific SRVs from the remote shutdown panel or up to six (6) ADS SRVs locally in the Upper Relay Room. For Paths 1 and 3, the reactor heat removal process utilizes alternate shutdown cooling with suppression pool cooling, except for Fire Areas R-1D and R-2D as described above. Normal shutdown cooling and suppression pool cooling is used on the Alternative Shutdown Path, except in the event of fire induced MOV damage as described above. It should be recognized that one loop of Suppression Pool Cooling is required for all paths. Alternate shutdown cooling utilizes the Core Spray System and ADS SRVs. It is used if reactor pressure vessel (RPV) cooldown is required but cannot be accomplished using normal shutdown cooling. To enter alternate shutdown cooling, the reactor head vents, the MSIVs and the main steam line drain lines must all be closed. Then, the SRVs are opened and one core spray pump taking suction from the suppression pool slowly increases reactor water level. The suppression pool cooling mode of RHR is initiated. Reactor water level is slowly raised to flood the main steam lines and establish a flow path through the open SRVs and back to the SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-5 suppression pool. In Fire Areas R-1D and R-2D, the capability to use RHR in the alternate shutdown cooling mode also exists. Process monitoring is provided for all paths. The selection of instrumentation to monitor process variables is based on NRC Information Notice 84-09 dated March 7, 1984, Attachment 1, Section IX and addresses the following considerations:  1) The operators must be able to monitor RPV level and pressure because these are the two parameters that alert the operators to manually SCRAM the reactor and/or actuate a safe shutdown system, 2) Flow rate indication is required for makeup systems and 3) Flow indication for systems with throttleable flow and temperature indication are required for heat transfer systems. In this analysis, since the suppression pool rather than the condenser is being used as the heat sink, both suppression pool temperature and level are monitored. In the event of a fire in the vicinity of Instrument Racks 1C004 and 1C005 on Elevation 749'-1 in Unit 1 and 2C004 and 2C005 on Elevation 749'-1 on Unit 2, Deviation Request No. 27 and 28, respectively, have justified the ability to achieve and maintain safe shutdown in the event of a loss of RPV level and pressure indication. The support functions either remove heat or supply power to the process system functions of reactivity control, reactor coolant makeup, reactor depressurization, and heat removal. Another support function provides a passive, backup source of keepfill water to the ECCS and RCIC pump discharge lines. A tank with at least 2000 gallons of water is the source of water to the pump discharge lines. This tank is part of a backup system and it is not dynamically qualified. This tank gravity feeds water to these discharge lines through the keepfill piping. This source of water is isolated from all other loads by a check valve so that the full capacity of this tank is available for the ECCS & RCIC pump discharge lines. This tank is designed to assure that there is an adequate supply of water to keep the ECCS & RCIC pump discharge lines full of water for greater than eight (8) hours after the loss of condensate transfer, the normal source of ECCS & RCIC Keepfill. This passive backup system is provided because condensate transfer may not be available in the event of an Appendix R fire. By keeping the ECCS & RCIC pump discharge lines full of water, these systems are protected from the damaging effects of waterhammers throughout the period of time when these systems perform their functions in support of post-fire safe shutdown. The support system for reactor heat removal is RHR Service Water which removes heat from the suppression pool in the suppression pool cooling mode and from the reactor loop through the heat exchanger in shutdown cooling. Cooling for equipment is provided by the emergency service water system through the RHR room coolers and HPCI and RCIC room coolers for the non-fire unit. No other RB HVAC components are necessary to achieve safe shutdown. Control Structure HVAC is not necessary to achieve and maintain cold shutdown if the following Operator actions are taken: - Selected electrical heat loads located in the Control Structure must be de-energized within 24 hours following a complete loss of Control Structure HVAC.
- Selected electrical cabinet doors located in the Control Structure must be opened to reduce the internal cabinet temperature within 24 hours following a complete loss of Control Structure HVAC.
SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3 The 125 and 250 VDC Battery Chargers must be verified to be in float mode and the doors to the 250 VDC Battery Rooms must be opened within 6 hours following a loss Battery Room Ventilation System. Power is supplied by the diesel generators, except for Fire Areas D-1 and D-3 as described above, and the batteries to the various components with the AC and DC distribution system modifying voltages as appropriate and distributing the power. The Nuclear Boiler Instrumentation has been evaluated to assure that a spurious actuation of a safety system will not adversely affect the ability to achieve and maintain safe shutdown. Automatic initiation of safety systems is not credited in the Appendix R Safe Shutdown Analysis. Although automatic safety system actuations may occur, the Appendix R Safe Shutdown Analysis assures the availability of manual system initiation only. For the Core Spray System a low pressure permissive bypass switch, HS-1/25249A/B has been installed into the control circuitry for the inboard Core Spray injection valves on each unit, HV E21 1/2F005A/B. This bypass switch allows operation of the Core Spray System in the event that fire induced damage to the Core Spray automatic initiation logic prevents this low pressure permissive signal from closing the contact in the control circuitry. Additionally, in the event that fire damage to the ADS automatic initiation logic prevents manual ADS from the Control Room, operator actions to depressurize the reactor using the keylock switches in the Upper or Lower Relay Rooms are included in the procedures. The effects of fire induced spurious signals were reviewed to assure that these will not result in an overfilling or an inventory loss from the reactor pressure vessel or a flow diversion or flow blockage in the safe shutdown systems being used for inventory make up or decay heat removal. It was determined that there were no adverse effects introduced by this scenario and that safe shutdown can be achieved using protected safe shutdown components. Flow diversion has the potential to prevent safe shutdown by diverting flow from a safe shutdown system or causing a loss of coolant from the RPV. The RPV and all safe shutdown systems were reviewed for potential flow diversion paths. High/Low pressure interfaces were analyzed and spurious openings of the SRVs were considered. Flow diversion paths were determined by reviewing all penetrations of the reactor pressure vessel and all safe shutdown system flow paths and identifying all lines too small to allow a significant flow diversion. All lines that would permit a significant flow diversion were then traced to a point where a determination of flow diversion could be made. This point was always a check valve, a normally closed manual valve, or an actuated valve. It was assumed that check valves function properly and prevent flow diversion and that normally closed manual valves would be in the correct position to prevent flow diversion. Actuated valves were evaluated and dispositioned by one of the methods discussed in Subsections 3.3.1.3 and
 
3.3.1.5.For use of each unit's remote shutdown panel (Alternative Shutdown Path) the following assumptions were made: 1. The reactor is scrammed, the MSIVs are closed, the Reactor Feed Pump Turbines are tripped and the Reactor Feed Pump Discharge Valves are closed in the control room prior to control room evacuation. The first action is consistent with the guidance in NRC Generic Letter 86-10 paragraph 3.8.4. Acceptance of the use of the latter three (3)
SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-7 actions was requested in PLA-4505 dated December 6, 1996 and accepted by the NRC in an SER dated October 21, 1997. Subsequent spurious opening of the Reactor Feed Pump Discharge Valves has been evaluated and determined to have no impact on post-fire safe shutdown. With the Reactor Feed Pump Turbine tripped, reactor vessel injection through the Reactor Feed Pump Discharge Valves would not occur until reactor pressure was reduced to below the shutoff head for the Condensate System. Inadvertent and uncontrolled injection by the Condensate System has been evaluated to be bounded by the design basis loads on the SRV Discharge Piping. 2. Offsite power is lost as well as automatic starting of the onsite diesel generators and the automatic function of valves and pumps whose control circuits could be affected by a control room fire. The analysis demonstrates that capability exists to manually achieve safe shutdown conditions from outside the control room by restoring a.c. power to designated pumps, assuring that valve lineups are correct, and assuring that any spurious valve operations which could permit the loss of reactor coolant can be corrected before unrestorable conditions occur. A communication system has been provided where necessary to facilitate these manual actions. This communication system is described in Section 4.13. Spurious signals/operations, as required by NRC Generic Letter 86-10, must be addressed. The focus of the evaluation is to be on identifying and mitigating the effects of each individual potential spurious operation. Spurious signals/operations are evaluated as follows: 1. Each spurious signal/operation is evaluated on a one-at-a-time basis. By addressing spurious operations on a one-at-a-time basis, the need to consider the aggregate effects of the potential spurious operations and the need to include time domain analysis, such as transient analysis is eliminated. In addition, consideration of combinations of sequentially selected circuit failures is not required. 2. If more than one hot short on the electrical circuitry for a component is required to cause a spurious operation, then the spurious operation is not considered to be credible. In addition, for Hi/Lo Pressure interface valves, 3-phase hot shorts on AC circuits and two hot shorts of the proper polarity without grounding on ungrounded DC circuits are considered to be credible. 3. The effects of each potential spurious operation is mitigated on a one-at-a-time basis using by one of the following: a. Providing a fire barrier or fire wrap.
: b. Routing the circuit of concern in a dedicated raceway that does not contain any other normally energized circuits that could cause a hot short. c. Rerouting or relocating the circuit/component. d. Providing a procedural action. For a Control Room fire actuation of an isolation transfer switch is considered to be an acceptable action to mitigate the effects of any spurious operation on the population of equipment that can be isolated from the effects of a Control Room fire.
SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-8 e. Identifying other equipment that can prevent the spuriously operated equipment from affecting safe shutdown. When using this last option, the alternate equipment selected cannot itself have the potential to spuriously operate during the same fire. The spurious operation criteria described above was submitted to the NRC in PLA-4505 dated December 6, 1996 and accepted by the NRC in an SER dated October 21, 1997. 3.3.1.2  Safe Shutdown Path Identification After identifying the systems required to support the safe shutdown function, the systems were grouped into various shutdown paths. Three safe shutdown paths were developed. They are as follows: Path 1 - The safe shutdown path comprised primarily of Division 1 equipment and cables. This path is used to achieve and maintain safe shutdown in those fire areas where the majority of the installed equipment and cables are Division II. This path is classified
 
as a Redundant Safe Shutdown Path. Path 2 - The alternative shutdown path or remote shutdown panel is used for achieving and maintaining safe shutdown in Fire Area CS-9, Main Control Room Fire Area. Path 3 - The safe shutdown path composed primarily of Division II equipment and cables. This path is used to achieve and maintain safe shutdown in those fire areas where the majority of the installed equipment and cables are Division I. This path is classified as a Redundant Safe Shutdown Path. See Table 3.3-1 for a listing of the safe shutdown systems in each safe shutdown path.
3.3.1.3    Safe Shutdown Cable, Raceway and Electrical Components Identification The previous step identified all the systems and process components required to achieve safe shutdown, as well as, any components that could potentially impact the ability to safely shutdown the reactor through spurious operations. To determine the cables required to operate the safe shutdown components or that could cause the maloperation of the potential spurious operation components, the schematics or elementary wiring diagram for each component was reviewed. For each component, all circuit cables that ensure operability of the component were initially identified as required for safe shutdown. The circuits identified included those for power, control and instrumentation. Additionally, all interlocks in the safe shutdown components circuit were traced back to the initiating devices and all corresponding cables were identified as potentially impacting the safe shutdown component of concern. In this way, all system interactions were identified. The safe shutdown component and cable information was entered into a computer database that contained cable/raceway by plant location. In order to identify preferred safe shutdown paths by plant location, the plant was divided into fire areas.
SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-9 3.3.1.4  Development of Fire Areas Our safe shutdown analysis is based on a fire area concept. Each fire area at the plant uses a minimum of one of the three safe shutdown paths described in Subsection 3.3.1.2 to achieve and maintain safe shutdown. The safe shutdown path used for each fire area is presented in Table 6.1-1. To perform the safe shutdown analysis, the plant was initially analyzed on a fire zone basis. A fire zone is a room or compartment usually separated from adjacent fire zones by a physical barrier. These barriers typically consist of reinforced concrete walls, ceilings and floors or gypsum board walls. These barriers may or may not be fire rated. Penetrations and openings in these non-rated barriers are usually treated in a similar manner as those for fire rated barriers. Therefore, fire zone boundaries should generally resist the spread of fire by a radiant heat transfer mechanism. Deviation Request No. 7 further outlines the fire spread limitation criteria. Each fire zone utilizes one of the three safe shutdown paths identified in Section 3.3.2 for achieving and maintaining safe shutdown. For Appendix R compliance, it was necessary to group these fire zones into fire areas. A fire area is comprised of one or more fire zones and is bounded on all sides by fire rated construction or spatial separation. The fire rated boundaries of these fire areas are designed to ensure that a fire initiated anywhere within the fire area does not propagate into or adversely impact any other fire area in the plant. Since the wraparound fire zones and the buffer fire zones would eventually comply with the requirements of both adjoining fire areas, they were considered to be in both fire areas. The wraparound and buffer fire zones and a few additional fire zones where protection of both safe shutdown paths 1 and 3 is required have been analyzed as a part of a pseudo-fire area in the safe shutdown analysis. The specific fire zones analyzed in this manner are identified in section 6.2. The plant specific fire hazards analysis in Section 6.0 discusses fire area separation in
 
more detail. The physical boundaries of all the fire areas were evaluated and upgraded as necessary to ensure that they are fire rated barriers. All penetrations and openings in these barriers are equipped with fire rated assemblies or are justified by deviation requests. The integrity of the fire barriers are assured by ongoing plant surveillance activities. The plant specific fire hazards analysis in Section 6.0 is presented on a fire area basis, however, within the discussion of each fire area, safe shutdown components are described on a fire zone basis to more specifically identify the location for this equipment. 3.3.1.5  Evaluation of Potential Cable and Component Noncompliances The Appendix R data was sorted by fire zone to develop a list of all potential Appendix R noncompliances which were termed cable hits. Each cable hit was evaluated either individually or on a generic basis, to determine the impact of fire induced faults on all affected components.
The term "cable hit" is used to describe 1. an individual cable that is either required for the proper functioning of a component that is part of the required safe shutdown path for the fire area where the cable is located, SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-10 2. or an individual cable that could potentially result in a spurious operation that could impact the required safe shutdown path in a particular fire area. For example, if a fire zone contains predominantly Division I (Path 1) components, Division II (Path 3) components would be used to achieve safe shutdown in the event of a fire in that fire zone. The reason for this is that the Division I components located in the zone of fire origin would be assumed to be damaged by the fire.The Division II components would be located in a different fire area, and would consequently remain free of fire damage. Therefore, Division II (Path 3) would be used to achieve safe shutdown. However, if a cable to one of the Division II safe shutdown components was routed through the Division I zone, that cable could potentially be destroyed by the fire in that zone. This cable would be called a "cable hit". It should be noted that not all cable hits are noncompliances as discussed in Section 3.3.1.6. The evaluation process consisted of examining each fire zone to determine the number of cable hits generated by first assuming that Division I (Path 1) was required for safe shutdown in that fire zone and then assuming that Division II (Path 3) was required for safe shutdown in that fire zone. The path with the least number of cable hits was then designated as the required safe shutdown path for that fire zone. Safe shutdown components were evaluated in a similar manner as cable hits. Components in noncompliance with Appendix R (i.e., component hits) were called Category I Components. The evaluation process also considered a number of electrical components. Each component was evaluated to determine its affect on safe shutdown. The types of components evaluated and a brief description of their analysis follows:
Pseudo-ComponentsThe concept of pseudo-components was developed to account for certain safe shutdown cables which constitute a control circuit scheme common to various components within a system. A psuedo-component is merely a designation given to a group of cables/devices whose sole purpose is to actuate various safe shutdown components based on certain plant parameters. The purpose for the pseudo-components is to distinguish the cabling and other electrical components for the common circuit scheme from the primary control circuit of each component.
In addition, by associating the cables of a common scheme with a pseudo-component, it avoids the duplication of the common scheme cables and components under each of the affected safe
 
shutdown components.
InterlocksIn order to assure that all system interactions were accounted for, the control circuits for each safe shutdown component were reviewed to identify all interlocks whose failure could adversely affect the required component function. Each interlock component and its respective cables were then evaluated to assess the effect of fire induced failures on the Safe Shutdown component. Interlocks and their connected cables which could adversely affect Safe Shutdown components were identified as being required for safe shutdown. Therefore, interlock components were analyzed in the same manner as Safe Shutdown components.
SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-11 Electrical Distribution Components These are power supplies or other electrical equipment that supports components required for safe shutdown. The required safe shutdown paths for these components was assigned based on the required paths for each safe shutdown load fed by a particular power supply. Included on this list are switchgear, load centers, motor control centers, load center transformers, distribution panels, DC control centers, DC battery chargers, DC batteries, fuse boxes, and
 
battery banks. Postulated Cable Faults Each cable hit was subjected to an evaluation which postulated a hot short, short-to-ground or an open circuit on the cable. Within the context of this report the following definitions are utilized to describe cable faults. - Hot Short - A fire induced insulation breakdown between conductors of the same cable, a different cable or from some other external source resulting in a compatible but undesired impressed voltage on a specific conductor. - Open Circuit - A fire induced break in a conductor resulting in a loss of circuit continuity. - Short to Ground - A fire induced breakdown of a cable's insulation system resulting in the potential on the conductor being applied to ground potential. The methodology used to postulate cable faults and their duration was based on the guidance provided in NRC Generic Letter 86-10 Section 5.3. High/Low Pressure Interfaces For the purposes of postulating credible fire-induced cable faults for high/low pressure interfaces, the criteria outlined in Section 5.3.1 of NRC Generic Letter 86-10 was used Spurious actuation of the safety relief valves was investigated. Based on the definition for a Hi/Lo Pressure Interface presented to the NRC in PLA-4505 dated December 6, 1996 and accepted by the NRC in an SER dated October 21, 1997, the SRVs are not considered to be Hi/Lo Pressure Interfaces. As such, it was determined that postulation of spurious operation of multiple SRV's was not required. The mitigating strategy for any spurious SRV operation is to further depressurize the reactor, as required, using the available SRVs and to inject with the available inventory make-up system, typically Core Spray.
Associated Circuits Several studies were completed to identify and demonstrate compliance with NRC Generic Letter 81-12 which provides a definition of associated circuits for Appendix R consideration and provides guidelines for protecting the safe shutdown capability from the fire-induced failures of associated circuits. The electrical buses required for safe shutdown were identified and all circuits from those buses were analyzed for their safe shutdown function. All of the associated circuits were identified and potential associated circuits of concern were identified by comparison of the bus safe shutdown SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-12 paths with the fire zone safe shutdown paths for those areas through which associated circuit cables were routed. An associated circuit became an associated circuit of concern when the associated circuit cable entered a fire zone where the required safe shutdown path was the same as the safe shutdown path assigned to the bus. It was verified by calculation or analysis that the potential associated circuit of concern would not impair the safe shutdown function of any other circuit powered from the same bus. Some cables which were connected to safe shutdown components were analyzed and were classified as safe shutdown circuits even though they were not required to be functional but their loss could result in the misoperation of the identified safe shutdown component.
Multiple High Impedance Faults (MHIF) The possibility of multiple faults exist when circuits on the same bus are routed in the same raceway. The nature of multiple high impedance faults is that the fault current of the individual branch circuits could be below the trip setting of the branch breakers. If enough branch circuits on the same bus failed in this manner, the additive currents could trip the upstream main breaker for the bus. This could then disable safe shutdown circuits on this bus. MHIFs were addressed by analyzing all of the safe shutdown power buses at the following voltages:  4160, 480, 120 AC and 250, 125 DC. All associated circuits of concern on a common bus were identified within a common "hit" fire zone. Unprotected safe shutdown circuits of the common bus in the hit fire zone were also identified and the fault currents were added to the associated circuit fault current. The total MHIF current was calculated using Generic Letter 86-10 criteria and was added to the total running current of the bus. For all safe shutdown buses, if this current exceeded the long time trip setting of the bus main breaker then either a procedural action to strip and reload the bus was established or the circuit of concern was wrapped in a protective fire barrier. Spurious Actuation The guidance provided in NRC Generic Letter 86-10 was supplemented with the information contained in PLA-4505 dated December 6, 1996 and this criteria was used in the evaluation of each cable hit which could cause spurious actuation of a component. For those spurious actuations which were the result of a hot short, no limitation was placed on the hot short duration. The hot short condition was postulated to exist until action was taken to isolate the fault and negate the spurious operation. In addition to these electrical components, other equipment which could affect the safe shutdown analysis was also evaluated. This equipment included:
Instrument Tubing The evaluation on instrument tubing was performed in a manner similar to that used to determine and evaluate Category I cables. Each instrument on the required component list was reviewed to determine those with associated tubing. The process tap, tubing, and instrument location (fire zones) were identified for each instrument with tubing. The tubing was identified as Category I if any of the tubing was routed through a fire zone on the same shutdown path as SSES-FPRRText Rev. 13 FPRR Rev. 21 3.3-13 the instrument under evaluation. Each Category I hit was evaluated to assess the potential impact on instrument operation and subsequent system/component function. 3.3.1.6  Resolution of Cable and Component Non-compliances All non-compliant cables and components were reviewed to determine their proper disposition. Many of the cable hits were grouped by unique function and addressed under specific analyses.
Individual raceways with numerous cable hits were identified for fire protective wrapping to preclude a specific analysis for each cable hit contained within the raceway. Some cable hits were located in raceway which was already wrapped or planned to be wrapped for other cable hit dispositions. All remaining cable hits were grouped by system and component and an evaluation was performed to determine the impact of a fire-induced cable failure on the component and on the safe shutdown analysis. Based on the above evaluations, each cable hit was ultimately resolved by performing a plant modification (i.e., fire wrapping, circuit modification, cable relocation), a procedural/manual action, further analysis which verified that fire-induced faults would not adversely impact safe shutdown or by a deviation request. Category I components were grouped by function and evaluated in a specific analysis. These analyses took into consideration component location within the fire zone, combustible loading, arrangement and location of fire detection and suppression within the zone. Also considered was separation between components of the redundant shutdown division. Category I components were resolved by a plant modification, a procedural action, a deviation request or an analysis which verified that fire damage to the component would not adversely affect safe
 
shutdown.3.3.2 Appendix R Section III.J Emergency lighting with an 8 hour battery power supply is provided in the main control room and along the access and egress routes from the main control room to each unit's respective remote shutdown panel, to local areas required for operation required for manual control of safe shutdown equipment. For the operator manual action to close the MSIVs on Unit 1 or 2 using the MSIV keylock switches in the Upper and Lower Relay Rooms, the use of Emergency Diesel Generator backed Essential Lighting is credited. This action is only performed in response to a Control Room Evacuation and is only required to be performed if a loss of offsite power does not occur. If a loss of offsite power does occur, the desired MSIV isolation will occur automatically and is assured without performing the action to actuate the MSIV keylock switches in the Upper and Lower Relay Rooms. If a loss of offsite power does not occur, then either Normal or Essential Lighting will be available. If Normal Lighting circuits are damaged by the effects of the Control Room fire, Essential Lighting will be available. Essential lighting circuits for the Lighting in the Upper or Lower Relay Rooms do not run through the Control Room Fire Area, CS-9. 3.3.3 Appendix R Section III.O Susquehanna SES Unit 1 and Unit 2 primary containments are inerted during normal operations; compliance with Section III.0 is achieved.
SSES-FPRR Table Rev. 14 FPRR Rev. 18  Page 1 of 2 TABLE 3.3-1 SAFE SHUTDOWN PATHS PATH 1 1 DIVISION I PATH 2 REMOTE SHUTDOWN PANEL PATH 3 1 DIVISION II Reactivity Control 2  CRD (Scram Function) Manual Scram from the Control Room or by venting the instrument air header locally on elevation 719 of the Reactor Building  Reactivity Control CRD (Scram Function)
Manual Scram Reactivity Control 2  CRD (Scram Function)
Manual Scram from the Control Room or by venting the instrument air header locally on elevation 719 of the Reactor Building Reactor Pressure Control Manual ADS from the Control Room or the Upper Relay Room Manual SRVs from Control Room (Non-Fire Unit)
Inboard MSIVs Reactor Pressure Control A, B, C, SRVs Manual ADS/SRVs from the Upper Relay Room Inboard MSIVs Reactor Pressure Control Manual ADS from the Control Room or the Upper Relay Room Manual SRVs from LRR (Non-Fire Unit) Outboard MSIVs Reactor Coolant Makeup Core Spray RCIC (Non-Fire Unit)
Reactor Coolant Makeup RCIC RHR LPCI  Reactor Coolant Makeup Core Spray HPCI (Non-Fire Unit)
Reactor Heat Removal Process RHR Suppression Pool Cooling Mode RHRSW  Reactor Heat Removal Process RHR Suppression Pool Cooling and Shutdown Cooling Mode RHRSW  Reactor Heat Removal Process RHR Suppression Pool Cooling Mode  RHRSW  Monitoring Suppression Pool Monitoring Nuclear Boiler Instrumentation Control Room Indication Monitoring Suppression Pool Monitoring Nuclear Boiler Instrumentation Remote Shutdown Panel Indication Monitoring Suppression Pool Monitoring Nuclear Boiler Instrumentation Control Room Indication
 
SSES-FPRR Table Rev. 14 FPRR Rev. 18  Page 2 of 2 TABLE 3.3-1 SAFE SHUTDOWN PATHS PATH 1 1 DIVISION I PATH 2 REMOTE SHUTDOWN PANEL PATH 3 1 DIVISION II    Associated Support Functions RHR Room Coolers RCIC Room Coolers (Non-Fire Unit)
Passive Keepfill System
* Tank 1T274 For Unit 1
* Tank 2T274 For Unit 2 Associated Support Functions RHR Room Coolers RCIC Room Coolers Passive Keepfill System
* Tank 1T274 For Unit 1
* Tank 2T274 For Unit 2 Associated Support Functions RHR Room Coolers HPCI Room Coolers (Non-Fire Unit)
Passive Keepfill System
* Tank 1T274 For Unit 1
* Tank 2T274 For Unit 2
* Common Required Components ESW ESSW Pumphouse HVAC
 
D.G. HVAC & Aux. Systems
 
Common Required Components ESW ESSW Pumphouse HVAC
 
D.G. HVAC & Aux. Systems Common Required Components ESW ESSW Pumphouse HVAC
 
D.G. HVAC & Aux. Systems Electrical 3  EDGs A&C or Offsite Power (T-10) Respective Distribution Equipment
 
Electrical 3
EDGs A, B, C, & D Respective Distribution Equipment Electrical 3
EDGs B&D or Offsite Power (T-20)
Respective Distribution Equipment App. R Comm. System (Unit 1)
Communication Loop No. 1
 
Communication Loop No. 5
 
Communication Loop No. 6
 
App. R Comm. System (Unit 1)
Communication Loop No. 2
 
App. R Comm. System (Unit 1)
Communication Loop No. 3
 
Communication Loop No. 4
 
Communication Loop No. 5 Communication Loop No. 7 App. R Comm. System (Unit 2)
Communication Loop No. 1 Communication Loop No. 4 Communication Loop No. 5 Communication Loop No. 6 App. R Comm. System (Unit 2)
 
Communication Loop No. 2 App. R Comm. System (Unit 2)
 
Communication Loop No. 3 Communication Loop No. 5 Communication Loop No. 7 Notes:  1. These Paths are not completely divisionalized.
: 2. For those plant areas where the scram is accomplished by manually venting the air header in the Reactor Building, it must be assured that the ability to trip the Reactor Recirculation Pumps from the Control Room is available. The tripping of the Reactor Recirculation Pumps from the Control Room can occur either automatically or by the Operator performing the action manually using the Control Room trip switch.
: 3. Diesel Generator "E" may be substituted for Diesel A, B, C or D.
SSES-FPRR Table Rev. 2 FPRR Rev. 18 Page 1 of 1 TABLE 3.3-2 SHUTDOWN PATHS AND METHODOLOGY BY FIRE LOCATION FIRE OUTSIDE CONTROL ROOM (EXCEPT FIRE ZONES 1-5B AND 2-5B)
 
Unit 1 (Fire Unit)
Unit 2 (Non-Fire Unit)
 
Path 1  RCIC & Manual SRVs (Note 2)
 
No Spurious SRV or ADS Path 1 Path 3 HPCI & Manual SRVs (Note 2)
No Spurious SRV or ADS
 
Path 3 Unit 1 (Non-Fire Unit)
Unit 2 (Fire Unit)
 
RCIC & Manual SRVs (Note 2)
No Spurious SRV or ADS Path 1  Path 1  HPCI & Manual SRVs (Note 2)
 
No Spurious SRV or ADS
 
Path 3  Path 3 NOTES:  1. Table 6.1-1 lists the required safe shutdown path (Path 1 or 3) and which unit is the fire unit for all fire areas.
: 2. HPCI or RCIC has been protected for the non-fire unit. With the changes made to add additional RHR pumping capability as a part of the Extended Power Uprate Project, the availability of HPCI or RCIC for the non-fire unit is no longer required. Since these systems, however, have already been protected, the decision was made to maintain their availability to add a measure of conservatism to the post-fire safe shutdown analysis. Additionally, on the non-fire unit, the availability to operate the SRVs is preserved so that reactor pressure can be gradually reduced to allow injection with the low pressure core spray system.
SSES-FPRR Table Rev. 1 TABLE 3.3-3 SHUTDOWN PATHS AND METHODOLOGY BY FIRE LOCATION FIRE ZONES 1-5B AND 2-5B A. B. C. FIRE ZONE 1-5B UNIT 1 Path 1 With Following Changes: CS Not Available For Vessel Makeup Spurious SRV or ADS Must Be Prevented RCIC And Division I or II RHR SPC Used Until Division I or II RHR SDC Can Be Entered (Reactor Pressure <98 Psig) To Achieve Cold Shutdown (Notes 1 and 2) UNIT2 Path 3 (Note 3) NOTES: FIRE ZONE 2-58 UNIT2 Path 1 With Following Changes; A. CS Not Available For Vessel Makeup B. Spurious SRV or ADS Must Be Prevented C. RCIC And Division I or If AHR SPC Used Until Division I or II AHR SOC Can Be Entered (Reactor Pressure <98 Psig) To Achieve Cold Shutdown (Notes 1, 2 and 4) UNIT 1 Path 3 and Division 1 RHR (Notes 3 and 4} 1. As an alternative to the use of RCIC, AHR (LPCI) may be used in the alternative shutdown cooling mode. ADS/SRV's must be available for depressurrzation and vessel flow to the suppression pool. The main steam tine drain valves must be capable of being closed. 2.
* For LPCI and SOC, the F015A valve needs to be opened. Core Spray automatic initiation logic and AHR automatic initiation logic provide the permissive for this valve to open automatically or manually from the Control Room. Manual override from the Control Room exists 1or valves required for SPC that may have closed due to AHR automatic initiation logic. 3. The use of Path 3 is required to allow simultaneous operation of the Unit 1 and 2 RHR pumps to prevent interruption of core cooling when AHR SDC is used to achieve cold shutdown.
: 4. Due to postulated cable faults ;n the Unit 2 RHR automatic initiation logic that coufd resuft in the inability to open the 2F015A valve or spuriously trip RHR pump 1 P202B, Unit 2 Division 11 AHR and Unit 1 Division I RHR are also protected in Fire Zone 2-58. This allows for the operation of Unit 2 Division fl LPC! or SDC while allowing for simultaneous operation of Unit 1 Division I suppression pool cooling. FPRR Rev. 13 Page 1 of 1 Table Rev. 0 UNIT 1 PATH2 SSES-FPRR TABLE 3.3-4 SHUTDOWN PATHS AND METHODOLOGY BY FIRE LOCATION CONTROL ROOM FIRE UNIT2 PATH2 RCIC and SRV's A,B & C with Division !I RHR SPC/SDC , RHRSW, and ESW RCIC and SRV's A,B & C with Division I RHR SPC/SDC, RHRSW, and ESW NOTES: 1. Potential spurious SRV or ADS actuations resulting from a Control Room fire could deplete the steam supply required for operation
'of RCIC from the Remote Shutdown Panel. In the event that this were to occur, safe shutdown would be achieved through the operation of alternate shutdown coc:,ling using LPCI from the Remote Shutdown Panel. 2. Similarly, valve damage due to MOV "Hot Shorts",-as described in NRC IN 92-18, could require the use of alternate SDC using LPCI. FPRR Rev. 11 Page 1 of 1 SSES-FPRR. Text Rev. 11 3.4 APPENDIX A-COMPLIANCE PPL has committed to perform the post-fire safe shutdown analysis in accordance with 1 OCFR50 Appendix A Sections 111.G, 111.J, 111.L (as required by 111.G.3) and 111.0. Compliance with Appendix R is essential to the safe operation of Susquehanna SES. Our Appendix A compliance program is implemented through a series of design standards, specifications:
drawing~ and admini~trative procedures.
Plant modifications are reviewed in the design process for their impact on the safe shutdown analysis, deviation requests, combustible loading analysis and other fire hazard configurations. Existing fire protection features are inspected through ongoing surveillances required by the Technical Requirements Manual. The Susquehanna SES Unit 1 and 2 Operating License Condition NPF-14, Paragraph 2.C.(6) and NPF-22, Paragraph 2.C.{3) indicate that changes may be made to the approved fire protection program without prior NRG approval only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. NRG Generic Letter 86-1 O provides guidance on mak i ng changes to the approved fire protection program. FPRR Rev. 11 3.4-1 SSES-FPRR Text Rev. 11 4.0 FIRE PROTECTION SYSTEM DESCRIPTION This section provides an integrated description of the fire suppression and detection systems which can be used in conjunction with specific discussions in Section 6.0. Components for the fire suppression and detection systems contained within safety related areas, which would cause damage to the safety related equipment should they fail, are supported so that structural integrity will be maintained through a safe shutdown earthquake.
National Fire Protection Association (NFPA) codes and standards were used as guidance for the Susquehanna Fire Protection Program. It is not PPL's nor NFPA's intent that code changes be retroactively applied to existing conditions. The NFPA code or standard used for design documents and procedures was the current NFPA code or standard active on the date when the original design document or procedure was approved (unless otherwise noted). The codes and standards considered and used for the original design of the fire protection system were: a) Basic Fire Protection for Nuclear Power Plants, ANI/MAERP b) Property Loss Prevention Standards for Nuclear Generating Stations , NML c) National Fire Protection Association Standards and Recommended Practices (See Table 4.0-1 for the code of record at the original design , unless otherwise noted.) d) Building Regulations for Protection from Fire and Panic , Commonwealth of Pennsylvania , Department of Labor and Industry e) OSHA Fire Protection Regulations, Vol. 2, 3, 4 and 5 FPRR Rev. 14 4.0-1 Table Rev. O 10-1974 10A-1973 12-1973 12A-1973 13-1974 13A-1971 13E-1973 14-1974 15-1973 20-1974 24-1973 27-1967 30-1973 37-1970 50A-1973 72A-1974 720-1974 72E-1974 75-1972 78-1968 80-1974 90A-1977 91-1973 92M-1972 101-1973 204-1968 241-1973 321-1973 FPRR Rev. 14 SSES-FPRR Table 4.0-1 National Fire Protection Association Standards and Recommended Practices (Code of Record at Original Design) Installation of Portable Fire Extinguishers Maintenance and Use of Portable Fire Extinguishers Carbon Dioxide Extinguishing Systems HALON 1301 Fire Extinguishing Systems Installation of Sprinkler System Maintenance of Sprinkler Systems Fire Department Operations in Properties Protected by Sprinkler and Standpipe Systems Standpipe and Hose Systems Water Spray Fixed Systems Centrifugal Fire Pumps Outside Protection Private Fire Brigades Flammable and Combustible Liquids Code Combustion Engines and Gas Turbines Gaseous Hydrogen Systems Local Protective Signaling Systems Proprietary Signaling Systems Automatic Fire Detectors Electronic Computer Data Processing Equipment Lightning Protection Code Fire Doors and Windows Air Conditioning and Ventilation System Blower and Exhaust Systems Waterproofing and Draining Floors Life Safety Code Smoke and Heat Venting Guide Building Construction and Demolition Operation Classification of Flammable Liquids Page 1 of 1 Text Rev. 11 SSES-FPRR FPRR Rev. 22 4.1-1 4.1  FIRE PROTECTION WATER SUPPLY SYSTEMS The fire protection water supply systems are shown schematically on Drawing E-106227. The plant's two automatic fire pumps have three suction sources: 
 
the two cooling tower basins each containing six million gallons of water and the 500,000 gallon clarified water storage tank from which a minimum of 300,000 gallons of water are available. The clarified water storage tank is provided with an internal standpipe that terminates at the 300,000 gallon level thereby limiting use of the tank's contents for other than fire protection purposes to 200,000 gallons.
 
The 300,000 gallons of water in the clarified water storage tank and the contents of one of the cooling tower basins are available for fire protection use. The other cooling tower basin is provided with a normally closed valve on the fire pump suction supply.
 
The fire protection water supply system has two horizontal centrifugal type fire pumps, each rated for 2500 gpm at 140 psig (net head). Both pumps are located in the circulating water pump house. One pump is motor driven and one is diesel engine driven with a day tank containing enough diesel fuel oil for 8 hours of operation in accordance with NFPA 20. There is also one backup diesel engine driven fire pump
 
rated at 2500 gpm at 155 psig (net head) located at the Well Water Pumphouse with a day tank containing enough diesel fuel oil for 8 hours of operation per NFPA 20.
 
A jockey pump maintains a system pressure of 105 to 125 psig to prevent frequent operation of the main fire pumps. Should the fire main pressure fall the motor driven pump and diesel driven pump start sequentially to maintain system pressure at greater than or equal to 85 psig. Both pumps continue running until shut off manually.
The largest single demand can be satisfied by one fire pump. With a loss of both offsite
 
power supplies, the electric fire pump cannot operate. The diesel fire pump can be
 
started either from the diesel pump controller or in the control room using the diesel fire pump batteries as a power source; no a.c. power is required for the diesel pump
 
starting.
 
The sectional and control valves of both fire pumps and the manual valve in the fuel
 
supply line for the diesel fire pump are locked open and administratively controlled.
 
Either one or both pumps can be started manually from the fire protection control panel
 
in the main control room or locally at the circulating water pump house, in which both
 
pumps are located.
 
The electric power for the electric motor driven fire pump is taken from a load center
 
that is supplied by two power sources.
 
If the primary power source fails, the power will automatically be transferred to the
 
secondary power source.
 
Text Rev. 11 SSES-FPRR FPRR Rev. 22 4.1-2 Alarms including "pump running," "power failure," and "failure to start" are provided and arranged to annunciate in the control room and at the local fire pump panels for
 
monitoring the pumps. For test purposes, a flowmeter has been installed on a test manifold in the pump discharge piping, which indicates flow locally.
 
A 12-in. diameter cement-lined, ductile-iron yard loop encircling the plant is buried in the ground below the frost level, and is made of piping which conforms to the requirements of NFPA 24. A secondary loop surrounds the site support buildings. For the yard main arrangement refer to Drawing E-105176. Post indicator valves have been provided for sectional control. Fire fighting equipment is provided for fire hydrants using the
 
guidelines of NFPA 24.
 
The diesel driven fire pump is enclosed within a 3 hour fire rated enclosure which
 
prevents both fire pumps from being damaged by a single fire.
 
In addition to the above, the Susquehanna SES site has a backup fire protection system which consists of a 2500 gpm diesel driven fire pump a jockey pump and a dedicated water supply. The 2500 gpm pump is not part of the Technical Specification requirements and is isolated from the main yard loop. The backup fire protection system and the main plant fire protection system can be cross-tied. Separation by distance ensures a fire in the circulating water pump house will not damage this pump.
 
SSES-FPAR
 
===4.2 AUTOMATIC===
 
WET PIPE SPRINKLER SYSTEMS Wet pipe sprinkler systems are selected to provide primary suppression capability for various areas. Wet pipe sprinkler systems are designed in accordance with NFPA 13. Each sprinkler system in the area of safety related equipment consists of an alarm valve assembly, an alarm device, piping, and fusible element sprinkler heads. Wet pipe sprinkler systems operate when ambient temperature rises to the melting point of fusible links on sealed sprinkler heads, thus permitting the heads to open. Flow of water through alarm check valves actuates a pressure switch and registers an alarm condition on an audible-visual annunciator on the fire protection control panel in the control room. Once initiated, wet pipe sprinkler operation is terminated manually by shutting the outside screw and yoke (OS& Y) gate valves. The systems are restored to a nready" condition by replacing the sprinkler heads that operated and reopening the OS& Y valves. Rev. 10 4.2-1 G:\l..lc Oocs\FPRR Approved\l eltt\Section04\fp04_
0700_ 02.aoc --
.. * ) ;' ) . __ ,,,. SSES-FPRR 4.3 DRY PIPE SPRINKLER SYSTEMS Dry pipe sprinkler systems are selected to provide primary suppression capability for various areas. Ory pipe sprinkler systems are designed in accordance with NFPA , 3. The dry pipe sprinkler systems are selected for areas where low temperatures may occur, thus avoiding freezing of sprinkler piping. Dry pipe sprinkler systems use automatic sprinkler heads attached to a piping system . that contains air under pressure.
The system operation is initiated by the melting of fusible links, which allows a sprinkler head to open and release the air. Loss of air pressure permits the water pressure to open the dry pipe valve. Activation of the system operates a pressure switch and registers an alarm condition on an audible-visual annunciator on the fire protection control panel in the control room. After operation, the dry pipe sprinkler system is rese_t by manually closing the OS& Y gate valve, draining the system, replacing all sprinkler heads that operated, resetting dry pipe valve, and
* repressurizing the pipe with air, before reopening the OS& Y valve. Rev. 10 4.3*1 G:\Lic Oocs\F PAR Approved\T ext\Section04\fp04_
0700_ 03.dOC SSES-FPRR
 
===4.4 AUTOMATIC===
 
PREACTION SPRINKLER SYSTEMS Automatic preaction sprinkler systems are selected to provide primary fire suppression capability for various plant areas.
* When automatic sprinkler protection is provided in areas containing safety-related equipment, preaction sprinkler systems are provfded to reduce the risk of possibly . flooding the area in the event of a pipe failure. Preaction sprinkler system operation is initiated by sensors which detect a rapid temperature rise, a fixed high temperature, and/or presence of products of combustion (Ionization or Pho~oelectric detectors).
The initiation sensors and local circuits may be shared with the fire detection system described in Section 4.12. The sensor releases a tripping device to open the deluge valve, permitting water to flow into the sprinkler piping system. When the fusibfe links holding the sprinkler heads closed melts, water will discharge from the sprinkler head. A pressure switch will sense water flow and register an alarm condition on an audible-visual annunciator on the fire protection control panel in the control room. After operation, the preaction sprinkler system is reset by closing the OS& Y gate valve, draining the system, repladng all sprinkler heads that operated, resetting the preaction valve, and repressurizing the pipe with air. before reopening the OS&Y valve. Rev. 10 4.4-1
* G:\Lic Docs\FPAR Apprcved\Text\Section04\1p04_0700_04.doc SSES-FPRRText Rev. 11 FPRR Rev. 16 4.5-1
 
===4.5 DELUGE===
SYSTEMSDeluge systems provide fire suppression capability for various areas. Automatic Deluge systems are open-head water spray systems activated by heat detectors which provide a signal to open the deluge valve. The individual systems may be manually activated from a local pushbutton switch or a manual control station. Some of the deluge systems can also be manually activated from the Control Room. The heat detectors, which activate the deluge valves, will operate when temperatures in the protected area rise at an abnormally high rate or reach a fixed temperature. Heat detector actuation is indicated on a local panel and annunciated on the Control Room panel. Deluge systems are reset by closing the outside screw and yoke (OS&Y) gate valve, draining the system, resetting the deluge valve and reopening the OS&Y valve. Manual deluge systems are open-head water spray systems that will discharge upon opening of the manual control valve(s) for the system. These systems are reset by closing the manual control valve(s) and draining the system. Manual deluge systems provide no alarm annunciation. For manual systems, heat detector activation will provide an annunciated high-high temperature "FIRE" alarm on Control Room panels and/or a high temperature "TROUBLE" alarm indication on local and Control Room panels. On receipt of an alarm, an operator will be dispatched to the affected area and manually open the control valves if a fire condition is confirmed.
SSES-FPRR Table Rev. 11 FPRR Rev. 18 4.6-1 4.6  WET STANDPIPES AND HOSE STATIONS
 
Wet standpipes for safety-related buildings were designed and installed for Class II service. Wet standpipes for non-safety related buildings were designed and installed using either Class I, II, or III service. All wet standpipes designed used the guidance of NFPA 14.
Hose stations are strategically located throughout the plant using the guidance of NFPA 14. The minimum residual pressure at the highest hose station in the plant is at least 65 psig with 100 gpm flowing. Each hose station in the power block contains 100 ft. of 1-1/2 inch fire hose with an appropriate nozzle. Hose stations located in areas of the plant where there is electrical equipment are provided with electrically safe fog
 
nozzles, with the exception of the fire hose nozzles in the Fire Zone 0-8A, where
 
straight stream nozzles are provided.
 
The site Fire Brigade is trained in fighting fires using hose stations and actions to be taken should additional fire hose be required. Areas exist in the plant where the
 
installed 100' fire hose at the hose station may not be sufficient to fully reach all extents of the area. For those areas, high rise fire hose packs are available for Fire Brigade
 
use.
SSES-FPRR
 
===4.7 PORTABLE===
FIRE EXTiNGUISHERS Portable fire extinguishers are selected to provide either primary or backup fire suppression capability depending on the particular area. They are located throughout the plant. The exact number, type, and location of each extinguisher has been determined using the guidelines of NFPA 10. Portable fire extinguishers are provided at the containment during refueling and major maintenance operations.
Rev. 10 4.7-1 G:\lic Oocs\FPRR Approved\Text\Sec1ion04\fp04_0700_07.doc Text Rev. 12 SSES-FPRR FPRR Rev. 20 4.8-1
 
===4.8 CARBON===
DIOXIDE SYSTEMS Low pressure carbon dioxide (CO
: 2) systems provide primary fire suppression capability in the electrical equipment rooms as shown on the drawings in Section 8.0. The low pressure carbon dioxide systems are designed using the guidelines of NFPA 12, "Carbon Dioxide Extinguishing Systems". The design quantity of the agent is
 
based on 50 percent concentration in the hazard area. At its minimum allowed level, the carbon dioxide storage tank holds sufficient carbon dioxide to supply a single discharge of carbon dioxide to the largest hazard. When the CO 2 storage tank is used to supply carbon dioxide for generator purging, administrative controls are used to assure that the minimum allowed level is maintained.
The two types of CO 2 systems in use are automatic total flooding and manual spurt. The automatic total flooding system is actuated by heat detectors. A predischarge alarm sounds locally in normally occupied areas and in the control room. HVAC system
 
penetrations into the area are sealed off by CO 2 operated fire dampers. Spearmint odorizer cartridges are provided in all automatic flooding and manual spurt systems for indicating the discharge or presence of CO 2.Manual spurt systems are provided to protect cables in concealed spaces on the control room level. Ionization detectors in the hazard areas actuate the audible and visual alarm on the main fire protection control panel.
Since it is desirable for the operators to remain in the control room, the manual spurt system allows the operators to control the release of CO 2 in the vicinity of the control room. Once the operator activates the manual spurt system, a discharge alarm is sounded in the control room. In addition to the audible alarm, odorizer cartridges
 
provide indication of actuation (CO 2 Flow). 
\ _} ) ... -* / . **-***--*--*------------------
SSES-FPRR
 
===4.9 HALON===
EXTINGUISHING SYSTEMS Power Generation Control Complex (PGCC) modules are provided with self-contained Halon 1301 fire extinguishing systems. Each system includes pressurized cylinders containing liquefied Halon 1301 at ambient temperature, product-of-combustion detectors (ionization), thermal detectors, spray nozzles, control panel, battery backup, and manual pull station. Each PGCC module cable way is sealed at polnt of connection.
Thermal detectors activate automatic discharge of Halon to the panel and floor sections.
The PGCC floor sections are provided with a 20% concentration by volume for a 20 minute duration.
Each system alarms locally and in the control room upon activation.
The Halon 1301 system is design_ed using the guidelines of NFPA 12A.
 
==Reference:==
 
NED0-10466, G. C. Minor, H. R. Clay, aPower Generation Control Rev. 10 Complex Design Criteria and Safety Evaluation," Licensing Topical Report, Class 1, Revision 2, March, 1978. 4.9-1 G:\Lic Docs\FPRR Approved\Tellt\Section04\lp04_0700.09.doc SSES-FPRR Text Rev. 11 4.10 INSULATION AND JACKETING OF CABLE Scheduled Class 1 E cables at Susquehanna SES as a minimum meet the flame propagation requirements of IEEE-383.
see Table 5.0-1, Section 0.3{f). Type tests for each type of scheduled Class 1 E cable used at Susquehanna SES were performed to the requirements of JEEE-383.
Each cable type passed the IEEE-383 vertical flame test. This test used a gas burner flame at 70,000 Btu/hr. These cables self-extinguished or burnt out when the flame source was removed which is the IEEE-383 acceptance criteria for the flame test. Also in accordance with I EEE-383, individually insulated or insulated and jacketed conductors removed from each muJticonductor c~bre. which was type tested, passed a flame resistance test specified in IPCEA S-19-81 Section 6.19.6. Scheduled Non Class 1 E cables used at Susquehanna SES as a minimum meet the flame propagation requirements of IEEE-383 with the possible exception of cables containing PVC. Scheduled Non Class 1 E cables may not have been tested to the procedures outlined in IEEE-383, however these cables meet the IEEE-383 acceptance criteria for the flame test. The cables containing PVC, listed in Table 5.0-1, may not have been qualified to the flame propagation requirements of IEEE-383.
In accordance with the criteria outlined in Table 5.0-1, Section D.2(c), cable insutation and jacketing is evaluated to as~ure the use of plastic, elastomeric, combustible material is minimized.
Any exemptions to this criteria are included in Table 5.0-1, Section D.2{c). FPRR Rev. 13 4.10-1 SSES-FPRR Text Rev. 11 4.11 RACEWAY WRAPPING The wrapping material used at Susquehanna SES to protect cable trays or-conduits meets the requirement of 1 OCFRSO, Appendix R, Sectlon UI.G.2 which requires that the wrapping material used as a fire ba_rrier be either 1 hour or_3 hour rated. Raceway fire barriers are qualified on the basis of a combination of fire testing and engineering evaluations.
Deviations from tested configurations are evaluated to assure that they provide a level of protection in excess of the specific fire hazard in the vicinity of the deviation.
Raceway required to be wrapped in support of the post-fire safe shutdown analysts are shown along with their diagrammatic routing on the Fire Protection Features Drawings.
On these drawings, each raceway is referenced to an isometric drawing that depicts the detailed physical routing of the raceway. On the isometric drawings, the raceway is divided into node points. Each node point is identified with a reference to a typical detail drawing that represents the quaHfied configuration that applies to that portion of the wrapped raceway. Each typical detail drawing provides a reference to the calculations providing the qualification basis for the typical detail. The qualification calculation provides a reference to any testing that supports the qualification of the typical detail. These calculations also contain engineering evaluations justifying deviations to the qualified configurations.
The fire barrier ampacny derating factors used when evaluating power cables in raceway wrapped with Them,o-Lag are indicated in Tabte 4.11-1. The ampacity derating factors in Table 4.11-1 are based on the following:
Conduit. Pull Boxes, Junction Boxes, Air Drops 1 Hour Installations (Upgraded with Thermo-Lag 330-1) The ampacity derating values for 1 Hour rated conduits, pult boxes, junction boxes and air drop enclosures are based on the ampacity derating tests performed by Florida Power Corporation under Project No. 95NK1730 report letter dated May 7, 1996. The ampacity derating values in Table 4.11
* 1 bound the vafues determined in the testing and the values accepted by the NRC (L. Raghavan, Project Manager, Project Directorate lr-3, NAG to Roy. Anderson 1 Senior Vice President Nuclear Operations, Florida Power Corporation, November 14, 1997). Walkdowns and destructive examinations verified that the instalted fire barrier configurations at Susquehanna SES bound those fire barrier configurations in the Florida Power Corporation test. FPRR Rev. 11 4.11-1 SSES-FPRA Text Rev. 11 3 Hour Installations (Upgraded with Thermo-Lag 770-1) The ampacity derating values for 3 Hour rated conduits, pull boxes, junction boxes and air drop enclosures are based on the ampac,ty derating tests performed by Tennessee Valley Authority under Project Nos. 11960797337 and 11960~97338 dated August 21, 1995. The
* ampacity derating values in Table 4.11-1 bound the values determined in the testing and the values accepted by the NRG (NUREG-0847.
Supplement No. 18, October, 1995). Test configurations consisted of a baseline 3 Hour installation
{1-1/8 11 +/- 1/8" with post-buttered joints) of Thermo-Lag 330-1 upgraded with two layers of Thermo-Lag 770-1 material.
The tested configurations are consistent with the construction of the baseline and upgrade configurations installed at Susquehanna SES. Walkdowns and destructive examinations verified that the baseline configurations at Susquehanna SES are bounded by the configurations in the Tennessee Valley Authority test. 3 Hour Installations (Abandoned-in*place; No upgrade material)
The ampacity derating values for 3 Hour rated conduits, pull boxes, junction boxes and air drop enclosures are based on the ampaclty derating tests performed by Florida Power Corporation under Project No. 95NK17030 report letter dated May 7, 1996. The ampacity derating values in Table 4.11-1 bound the values determined in the testing and the values accepted by the NRC (L. Raghavan, Project Manager, Project Directorate 11-3, NRG to Roy Anderson, Senior Vice President Nuclear Operations, Florida Power Corporation, November 14, 1997). Walkdowns and destructive examinations verified that the baseline configurattons at Susquehanna SES are bounded by the configurations in the Ftorida Power Corporation test. Non-Standard Conduit 1 Hour tnstallations The ampacity derating values for 1 Hour rated non-standard conduit enclosures are based on the ampacity derating tests performed by Tennessee Valley Authority under Project No. 11960-97335.
The ampacity derating values in Table 4.11-1 bound the values determined
;n the testing and the values accepted by the NRG (NUREG*0847, Supplement No. 18, October, 1995). Walkdowns examinations verified that the non-standard configurations at Susquehanna SES are bounded by the configurations in the Tennessee Valley Authority test. FPRR Rev. 11 4.11-2 
\ SSES-FPRR Text Rev , 11 3 Hour Installations Walkdowns and destructive examinations verified that.there are no standard 3-Hour installations at Susquehanna SES. Cable Tray and Wireway The ampacity derating values for cable tray without covers is based on the ampacity derating tests performed by Texas Utilities Electric Company under Ampacity Derating Test Report No. TUE 12340-95169.
The ampacity derating values for cable tray with covers and wireway is based on the ampacity derating tests performed by Florida Power Corporation under Project No. 95NK17030 report dated May 8, 1996. The ampacity derating values in Table 4.11-1 bound the values determined in the testing and the vatues accepted by the NRC (TUE 12340-95169
-Timothy J. Policht Project Manager, Project Directorate IV-1, NRG to C. Lance Terry, Group Vice President, Nuclear, TU Electric, June i4, i995 and NUREG-0847, Supplement No. 18, October, 1995) (FPC Project No. 95NK17030
-L. Raghavan, Project Manager, Project Directorate 11-3, NRG to Roy Anderson, Senior Vice President Nuclear Operations, Florida Power Corporation, November 14, 1997). Wireways are considered to be similar to cable tray with covers. Walkdowns and destructive examinations verified that there are no non-standard cable tray or wireway configura1ions at Susquehanna SES. The ampacity derating values in Table 4.11-1 are applicable to 1 Hour and 3 Hour installations based on the Florida Power Corporation test where the same derating values were derived for both 1 Hour and 3 Hour installations.
Walkdowns and destructive examinations verified that the installed fire barrier configurations at Susquehanna SES bound those fire barrier configurations in the Florida Power Corporation and Texas Utilities Electric Company reports. FPRR Rev. 11 4.11-3 SSES-FPAR* Table Rev. O TABLE 4.11-1 AMPACITV DERATING VALUES FOR: RACEWAYS PROTECTED WITH THERMO-LAG Raceway Type Fire Barri~r Derating Factor I Conduit, Air Drop -1 Hour 10.7% I Conduit (non standard) -1 Hour -15.7% I Conduit, Air Drop -3 Hour '13.0% I Pull Boxes, Junction Boxes -1 Hour 10.7% I Pull Boxes, Junction Boxes-3 Hour 13.0% I Cable Tray (without tray covers) 31.5% I Cable Tray (with tray covers) .41.0% I Wireway 41.0% I FPRR Rev. 11 Page 1 of 1 SSES-FPRRText Rev. 12 FPRR Rev. 22 4.12-1 4.12 FIRE DETECTION AND ALARM SYSTEM The fire and smoke detection system is in compliance with NFPA 72E. An uninterruptable power supply has been provided for the fire and smoke detection
 
system.The system complies with the requirements of NFPA 72D. The system is located on the fire protection control panels in the control room. The system records the date and time of a fire alarm. The recording identifies the general location of the alarm by unit (Unit 1, Unit 2 or common).
Fire and smoke monitoring, detection, and alarm are accomplished by installed ionization, photoelectric, flame, or thermal detectors. In certain areas of the plant, heat detectors activate fire suppression systems and fire and smoke detection systems provide early warning alarm function only. In other areas of the plant, the fire and
 
smoke detection system provides early warning alarm and activates the preaction
 
system valve.
The fire and smoke detection system is electrically supervised to detect circuit breaks, ground faults, and power failure. All fire or trouble alarms register on the audible-visual annunciator on the fire protection control panel in the control room. The Fire and Smoke detection system and hardware installed in panels 1C650 and 2C650 meet NFPA 72 2004. Local Fire and Smoke detection panels report to control room panels 1C650 and 2C650. The individual local panels for CO 2 , Sprinkler, Deluge, Pre-action and Halon systems also report to 1C650 or 2C650. Panels 1C650 and 2C650 each have an Operator interface on the front of each panel for all the fire and smoke detection systems. A TruSite Workstation (TSW) located in the Technical Support Center (TSC) serves as a backup to the Control Room. The local fire and smoke detection panels, the TSW, and panels 1C650 and 2C650 are all connected in a style 7 loop. Power to panels 1C650 and 2C650 is provided from a Vital AC source, which is an uninterruptable power supply, with battery backup. The fire and smoke detection system is electronically supervised to detect circuit breaks, ground faults and power failure.The control room 1C650 and 2C650 panel provides fire and trouble indication for the CO 2, smoke detection, sprinkler, deluge, preaction and Halon systems. Individual local panels are provided for each of these systems. In addition to displaying fire and trouble alarms, the local panels provide supervision of detector and release mechanism wiring, and where applicable, provide system activation. Power to panels, except the Halon panels, is provided by separate connections to the uninterruptable power supply, which is described in Subsection 8.3.1.8 of the FSAR. The Halon panels in the power generation control complex are powered by normal a.c. power and are provided with
 
battery packs for backup power.
SSES-FPRRText Rev. 12 FPRR Rev. 22 4.12-2 The control room 0C650 panel contains fire pump start switches and annunciators to alarm fire pumps operating, AC Power Failure, Motor Overcurrent, Engine Running, Control Switch Not in Auto Position and "trouble" alarms. The control structure smoke removal system graphic display is located on panel 0C650 and contains controls for the
 
fans and dampers of this system. 
( ) . -*-"' (_) SSES-FPRR 4.13 APPENDIX A VOICE POWERED COMMUNICATION SYSTEM The Appendix R Voice Powered Communication System provides un-jnterruptable communication from the Control Room and-Remote Shutdown Panel (ASP) to numerous locations throughout the plant where manual actions may be required in the event of postulated fires in various fire zones. This voice powered communication system consists of headsets with acoustic boom and/or noise-shielded microphone that plug into jack plates. The jackplates are located as shown on Table 4.13-1. The system provides communication for use during Appendix A fire scenarios.
No* power is required to operate the syst~m. Rev. 10 4.13-1 G:\Lic Docs\FPRR Worklng\Text\Sectk>n04\fp04_0700_
13.doc SSES-FPRR TABLE 4.13*1 JACKPLATE LOCATIONS UNIT AREA FIRE ZONE(S) 1 Control Room 0-26H 1 Turbine Building 13.8K Switchgear 0-TB 1 Reactor Building . 4.16KV Emerg Switchgear Rooms 1-4C, 1-40, 1-SF, 1-SG -Remote Shutdown Panel 1-20 -Reactor Protection System Dist. Panel 1-SA-S -120V AC Distribution Panels 1-4A-N, 1-4A-W 1 Lower Relay Room 0-240 1 Upper Relay Room 0-27E 2 Control Room 0-26H 2 Turbine Building 13.BKV Switchgear 0-TB 2 Reactor Building -4.16KV Emerg Switchgear Rooms 2-4C, 2-4D, 2-SF, 2-SG -Remote Shutdown Panel 2-2A .. \ I . Reactor Protection System Dist. Panel 2*5A-N 2 Lower Relay Room 0-24G *. " ...... 2 Uooer Relay Room 0-27A Common Diesel Generator Bays A, B, C, D, E 0*41A, 0-418, 0*41C, 0-41 D, 0-41 E Common Control Structure H& V Equipment Room 0-298 0 Rev. 10 Page 1 of 1 G:\Llc Docs\FPRR Approved\Tables\Oevtables'Sectlon04Vpt4_0700_
13_ 1.doe SSES-FPRR Text Rev 11 FPRR Rev. 19 5.0-1
 
===5.0 COMPARISON===
OF SUSQUEHANNA SES DESIGN AND FIRE PROTECTION FEATURES TO REGULATORY REQUIREMENTS The purpose of this section is to compare the fire protection provisions of Susquehanna Steam Electric Station (SSES) Units 1 and 2 with the guidelines in Appendix A of Branch Technical Position APCSB 9.5-1 Rev. 0 and Appendix R to 10CFR50.
 
To identify areas of impact and to facilitate comparison, matrices for items in Appendix A and Appendix R were developed. Table 5.0-1 contains the matrix which compares Susquehanna SES with Appendix A. Table 5.0-2 contains the matrix which compares Susquehanna SES with Appendix R.
 
General Design Criteria 3, Fire Protection, of Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants, requires that structures, systems and components important to safety shall be designed and located to minimize, consistent with safety requirements, the probability and effects of fires and explosions. Noncombustible and heat resistant materials should be used wherever practical throughout the unit, particularly in locations such as Containment and Control Room. Fire detection and fire fighting systems of appropriate capacity and capability shall be provided and designed to minimize the effects of fires on structures, systems and components important to safety. Fire fighting systems shall be designed to assure that their failure, rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems and components.
The purpose of Appendix A of Branch Technical Position APCSB 9.5-1 Rev. 0 is to describe guidelines acceptable for implementing this criterion for Nuclear Power Plants outlined in General Design Criteria 3. The purpose of the Fire Protection Program for Nuclear Power Plants is to maintain the ability to perform and maintain safe reactor plant shutdown functions and to minimize radioactive releases to the environment in the event of a fire.
Appendix A of Branch Technical Position APCSB 9.5-1 Rev. 0 addresses only fire protection for safety related systems and equipment in nuclear power plants, including equipment with the potential to result in radioactive releases to the environment. As such, the requirements in Table 5.0-1 apply only to systems and components in the following structures, and to the fire protection features, e.g. water supply systems, suppression systems, detection systems and fire barriers, for the following structures:
* Reactor Building Unit 1 and 2
* Control Structure 
* 'A' through 'E' Diesel Generator Buildings
* Engineered Safeguards Service Water Pumphouse
* Turbine Building Unit 1 and 2
* Radwaste Building
* Circulating Water Pumphouse
* Low Level Radwaste Storage Facility The plant areas where the requirements of 10CFR50 Appendix R Sections III.G, III.J, III.L and III.O, as outlined in Table 5.0-2, apply are described in the balance of the Fire Protection Review Report.
SSES-FPRR Table Rev. 25 TABLE 5.0-1 SUSQUEHANNA SES AS COMPARED WITH BRANCH TECHNICAL POSITION 9.5-1, APPENDIX A, REV. 0 BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 1 of 49 A. Overall Requirements of Nuclear Plant Fire Protection Program 1. Personnel Responsibility for the overall Fire Protection Program should be assigned to a designated person in the upper level of management. This person should retain ultimate responsibility even though formulation and assurance of program implementation is delegated. Such delegation of authority should be to staff personnel prepared by training and experience in fire protection and nuclear plant safety to provide a balanced approach in directing the Fire Protection Programs for nuclear power plants. The qualification requirements for the fire protection engineer or consultant who will assist in the design and selection of equipment, inspect and test the completed physical aspects of the system, develop the Fire Protection Program, and assist in the fire-fighting training for the operating plant should be stated. Subsequently, the FSAR should discuss the training and the updating provisions such as fire drills provided for maintaining the competence of the station fire-fighting and operating crew, including personnel responsible for maintaining and inspec ting the fire protection equipment. The fire protection staff should be responsible for:
(a) Coordination of building layout and systems design with fire area requirements, including consideration of potential hazards associated with postulated design basis fires, (b) Design and maintenance of fire detection, suppression, and extinguishing systems, (c) Fire prevention activities, (d) Training and manual fire-fighting activities of plant personnel and the fire brigade. The Fire Protection Program is the responsibility of the Senior Vice President-Chief Nuclear Officer. Responsibilities for design are delegated to the Vice President-Nuclear Engineering/Support. The responsibilities for the operational phase of the Fire Protection Program are delegated to the Vice President-Nuclear Site Operations. Within the organization, reporting to the Vice President-Nuclear Engineering/Support is a qualified fire protection engineer who is responsible for formulation and evaluation of the Fire Protection Program. The Susquehanna SES procedures describe the qualification requirements, training requirements, and tasks for personnel assigned fire protection responsibilities.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 2 of 49 2. Design Bases The overall Fire Protection Program should be based upon evaluation of potential fire hazards throughout the plant and the effect of postulated design basis fires relative to maintaining ability to perform safety shutdown functions and minimize radioactive releases to the environment. The Susquehanna SES fire hazards analysis provided in Section 6.0 of this report demonstrates that the plant will maintain the ability to perform safe shutdown functions and minimize radioactive releases to the environment in the event of a fire. 3. Backup Total reliance should not be placed on a single automatic fire suppression system. Appropriate backup fire suppression capability should be provided.All fixed fire suppression systems have manual backup systems of either standpipe and hose reels, portable extinguishers, or fire hydrants. 4. Single Failure Criterion A single failure in the fire suppression system should not impair both the primary and backup fire suppression capability. For example, redundant fire water pumps with independent power supplies and controls should be provided. Postulated fires or fire protection system failures need not be considered concurrent with other plant accidents or the most severe natural phenomena. The effects of lightning strikes should be included in the overall plant Fire Protection Program. Neither the failure of a fire pump, its power supply or controls, nor a crack in a moderate-energy line in the fire suppression system will result in loss of function of both sprinkler and hose standpipe systems in an area protected by such primary and backup systems. Two 100% capacity pumps (one electric and one diesel driven) are provided, each capable of supplying the design flow rate at design pressure. By use of sectional control valves and cross-connecting, damaged fire yard mains can be isolated. Separate supplies are provided for sprinkler and standpipe/hose reel stations. Protection from lightning strikes is a part of the Susquehanna SES design. 5. Fire Suppression Systems Failure or inadvertent operation of the fire suppression system should not incapacitate safety-related systems or components. Fire suppression systems that are pressurized during normal plant operation should meet the guidelines specified in APCSB Branch Technical Position 3-1, "Protection Against Postulated Piping Failures in Fluid Systems Outside Containment." This item is addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in Section 6.1 of this report. (See response to Item E.3.a of Section 5.0-1)
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 3 of 49 6. Fuel Storage Areas  The Fire Protection Program (plans, personnel, and equipment) for buildings storing new reactor fuel and for adjacent fire zones which could affect the fuel storage zone should be fully operational before fuel is received at the site. The Fire Protection Program at Susquehanna SES was in operation prior to fuel being received on site. 7. Fuel Loading The Fire Protection Program for an entire reactor unit should be fully operational prior to initial fuel loading in that reactor unit. The Fire Protection Program at Susquehanna SES was in operation prior to fuel loading. 8. Multiple-Reactor Sites On multiple-reactor sites where there are operating reactors and construction of remaining units is being completed, the Fire Protection Program should provide continuing evaluation and include additional fire barriers, fire protection capability, and administrative controls necessary to protect the operating units from construction fire hazards. The superintendent of the operating plant should have the lead responsibility for site fire protection. Prior to operation of both units at Susquehanna SES, the Fire Protection Program under the responsibility of the Superintendent of the Plant was operational and included fire barriers, fire protection capability, and administrative controls to protect the operating unit from construction fire hazards. Both units at Susquehanna SES are currently operating units. 9. Simultaneous Fires Simultaneous fires in more than one reactor need not be postulated, where separation requirements are met. A fire involving more than one reactor unit need not be postulated except for facilities shared between units. This item is addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in Section 3.0 of this report.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 4 of 49 B. Administrative Procedures, Controls, and Fire Brigade 1. Administrative procedures consistent with the need for maintaining the performance of the fire protection system and personnel in nuclear power plants should be provided. Guidance is contained in the following publications: NFPA 4 - Organization for Fire Services NFPA 4A - Organization for Fire Department NFPA 6 - Industrial Fire Loss Prevention NFPA 7 - Management of Fire Emergencies NFPA 8 - Management Responsibility for Effects of Fire on Operations NFPA 27 - Private Fire Brigades The Susquehanna SES Plant Procedures include the necessary administrative and technical procedures required to implement the Fire Protection Program. National Fire Protection Association (NFPA) codes and standards were used as guidance for the Susquehanna Fire Protection Program. The date of the NFPA code or standard used corresponds with the date in effect when the original design document or procedure was approved. It is not PPL's nor NFPA's intent that code changes be retroactively applied to existing conditions. 2. Effective administrative measures should be implemented to prohibit bulk storage of combustible materials inside or adjacent to safety-related buildings or systems during operation or maintenance periods. Regulatory Guide 1.39, "Housekeepin g Requirements for Water-Cooled Nuclear Power Plants," provides guidance on housekeeping, including the disposal of combustible materials. Administrative procedures control the storage of combustible materials including prohibiting bulk storage of combustible materials in areas where they might endanger safety-related equipment.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 5 of 49 3. Normal and abnormal conditions or other anticipated operations such as modifications (e.g., breaking fire stops, impairment of fire detection and suppression systems) and refueling activities should be reviewed by appropriate levels of management and appropriate special actions and procedures such as fire watches or temporary fire barriers implemented to assure adequate fire protection and reactor safety. In particular: (a) Work involving ignition sources such as welding and flame cutting should be done under closely controlled conditions. Procedures governing such work should be reviewed and approved by persons trained and experienced in fire protection. Persons performing and directly assisting in such work should be trained and equipped to prevent and combat fires. If this is not possible, a person qualified in fire protection should directly monitor the work and function as a fire watch. (b) Leak testing, and similar procedures such as air flow determination, should use one of the commercially available aerosol techniques. Open flames or combustion generated smoke should not be permitted. Administrative controls used at Susquehanna SES maintain the performance of the fire protection system and personnel. These controls establish procedures that:a. Prohibit bulk storage of combustible materials inside or adjacent to safety-related buildings or systems during operation or maintenance periods. b. Govern the handling and limitation of the use of ordinary combustible materials, combustible and flammable gases, liquids, or other combustible supplies in safety-related areas. c. Govern the handling of and limit transient fire loads.
: d. Designate the onsite staff member responsible for the in-plant fire protection review of proposed work activities to identify potential transient fire hazards and specify required additional fire protection in the work activity procedure. e. Govern the use of ignition sources by use of a Hot Work permit system to control welding, flame cutting, brazing, or other open flame operations. f. Control the removal of all waste material in a timely manner.
: g. Prohibit the use of open flames or combustion-generated smoke for leak testing. h. Maintain the periodic housekeeping inspections.
: i. Control the use of specific combustibles in safety-related areas.
: j. Disarm fire detection or fire suppression systems.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 6 of 49 (c) Use of combustible material, e.g., HEPA and charcoal filters, dry ion exchange resins or other combustible supplies, in safety-related areas should be controlled. Use of wood inside buildings containing safety-related systems or equipment should be permitted only when suitable non-combustible substitutes are not available. If wood must be used, only fire retardant treated wood (scaffolding, lay down blocks) should be permitted. Such materials should be allowed into safety-related areas only when they are to be used immediately. Their possible and probable use should be considered in the fire hazard analysis to determine the adequacy of the installed fire protection systems. k. Test plant fire protection and detection systems. l. Provide guidance on actions to be taken by an individual discovering a fire.
: m. Provide guidance on actions to be taken by the fire brigade. 4. Nuclear power plants are frequently located in remote areas, at some distance from public fire departments. Also, first response fire departments are often volunteer. Public fire department response should be considered in the overall Fire Protection Program. However, the plant should be designed to be self-sufficient with respect to fire-fighting activities and rely on the public response only for supplemental or backup capability. Susquehanna SES has been designed to be self-sufficient with respect to fire protection and relies on the public fire departments for supplemental and backup capability. 5. The need for good organization, training, and equipping of fire brigades at nuclear power plant sites requires effective measures be implemented to assure proper discharge of these functions. The guidance in Regulatory Guide 1.101, "Emergency Planning for Nuclear Power Plants," should be followed as applicable. (a) Successful fire fighting requires testing and maintenance of the fire  protection equipment, emergency lighting and communication, as well  as practice as brigades for the people who must utilize the  equipment. A test plan that lists the individuals and their  responsibilities in connection with routine tests and inspections of the  fire detection and protection systems should be developed. The test  plan should contain the types, frequency, and detailed procedures for  testing. Procedures should also contain instructions on maintaining  fire protection during those periods when the fire protection system is  impaired or during periods of plant maintenance, e.g., fire watches or  temporary hose connections to water systems. See Item B.3 above.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 7 of 49 (b) Basic training is a necessary element in an effective fire-fighting operation. In order for a fire brigade to operate effectively, it must operate as a team. All members must know what their individual duties are. They must be familiar with the layout of the plant and equipment location and operation in order to permit effective fire-fighting operations during times when a particular area is filled with smoke or is insufficiently lighted. Such training can only be accomplished by conducting drills several times a year (at least quarterly) so that all members of the fire brigade have had the opportunity to train as a team, testing itself in the major areas of the plant. The drills should include the simulated use of equipment in each area and should be preplanned and post-critiqued to establish the training objective of the drills and determine how well these objectives have been met. These drills should periodically (at least annually) include local fire department participation where possible. Such drills also permit supervising personnel to evaluate the effectiveness of communications within the fire brigade and with the on-scene fire team leader, the reactor operator in the control room, and the offsite command post.Plant procedures detail the organization and actions necessary to accomplish the self-sufficient fire-fighting response. The training intervals and persons to be trained are set forth in FPRR Section 1.4. Local fire departments are invited and encouraged to attend training provided by PPL. The fire-fighting program utilizes the appropriate National Fire Protection Association codes and standards as guidance. 6. To have proper coverage during all phases of operation, members of each shift crew should be trained in fire protection. Training of the plant fire brigade should be coordinated with the local fire department so that responsibilities and duties are delineated in advance. This coordination should be part of the training course and implemented into the training of the local fire department staff. Local fire departments should be educated in the operational precautions when fighting fires on nuclear power plant sites. Local fire departments should be made aware of the need for radioactive protection of personnel and the special hazards associated with a nuclear power plant site. See Item B.5. above.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 8 of 49 7. NFPA 27, "Private Fire Brigade" should be followed in organization, training, and fire drills. This standard also is applicable for the inspection and maintenance of fire-fighting equipment. Among the standards referenced in this document, the following should be utilized: NFPA 194 - "Standard for Screw Threads and Gaskets for Fire Hose Couplings," NFPA 196 - "Standard for Fire Hose," NFPA 197 - "Training Standard on Initial Fire Attacks," NFPA 601 - "Recommended Manual of Instructions and Duties for the Plant Watchman on Guard." NFPA booklets and pamphlets listed on page 27-11 of Volume 8, 1971-72 are also applicable for good training references. In addition, courses in fire prevention and fire suppression which are recognized and/or sponsored by the fire protection industry should be utilized. The Fire Protection Program utilizes the appropriate NFPA codes and standards as guidance. C. Quality Assurance Program Quality Assurance (QA) programs of applicants and contractors should be developed and implemented to assure that the requirements for design, procurement, installation, and testing and administrative controls for the Fire Protection Program for safety-related areas as defined in this Branch Position are satisfied. The program should be under the management control of the QA organization. The QA program criteria that apply to the Fire Protection Program should include the following: Construction Phase A program was provided for the design and construction phases of the fire protection installation. The program was not under the control of the QA organization. The following is a description of that program. 1. Design Control and Procurement Document Control Measures should be established to assure that all design-related guidelines of the Branch Technical position are included in design and procurement documents and that deviations therefrom are controlled. Procedures were followed by both PP&L and Bechtel, whereby appropriate existing NRC safety guides and other regulatory documents including new revision were included in design documents in accordance with Bechtel Division Engineering Standards. Plant procurement specifications were reviewed and controlled in accordance with the current procedures, design criteria, regulatory documents, and codes and standards referenced in the specific design criteria.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 9 of 49 2. Instructions, Procedures, and Drawings Inspections, tests, administrative controls, fire drills, and training that govern the Fire Protection Program should be prescribed by documented instructions, procedures, or drawings and should be accomplished in accordance with these documents. Appropriate procurement and drawing procedures existed in Bechtel for the control of inspections, tests, and instructions for the fire protection equipment and systems during the procurement and construction phases. Specific care was taken to formulate adequate tests, equipment procurement, and fire drill procedures to ensure maximum fire protection capability following plant construction.3. Control of Purchased Material, Equipment, and Services Measures should be established to assure that purchased material, equipment, and services conform to the procurement documents. Materials, services, and equipment purchased were supplied and subcontracted by individuals who have demonstrated their ability to the industry to provide quality material, equipment, and services. Bid evaluations were performed in accordance with Bechtel procedures. Surveillance inspections were performed on suppliers work (other than that performed by recognized national laboratories) in accordance with the inspection requirements of the particular equipment or material specification. Receiving inspections were performed in accordance with the Quality Control Instructions and normal warehouse procedures. 4. Inspection A program for independent inspection of activities affecting fire protection should be established and executed by, or for, the organization performing the activity to verify conformance with documented installation drawings and test procedures for accomplishing the activities. Bechtel field personnel witnessed the fire protection installation and verified conformance with design drawings. 5. Test and Test Control A test program should be established and implemented to assure that testing is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. The tests should be performed in accordance with written test procedures; test results should be properly evaluated and acted on. Not applicable to the design and construction phase.
 
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 10 of 49 6. Inspection, Test, and Operating Status Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspections. Not applicable to the design and construction phase. 7. Non-Conforming Items Measures should be established to control items that do not conform to specified requirements to prevent inadvertent use of installation. Materials received by either Bechtel personnel or PP&L personnel, which did not comply with the purchase specification and equipment found not operating satisfactorily during testing, were segregated or identified as nonconforming items in accordance with Bechtel Quality Control Instructions, PP&L Warehouse procedures, or PP&L Testing Program Procedures. 8. Corrective Action Measures should be established to assure that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material and non-conformances are promptly identified, reported, and corrected. Conditions or equipment which would be adverse to fire protection were identified and a corrective course of action recommended to PP&L by Bechtel. 9. Records Records should be prepared and maintained to furnish evidence that the criteria enumerated above are being met for activities affecting the Fire Protection Program. Records in the form of design drawings, letters, comment, etc., were prepared and stored to furnish evidence that fire protection criteria have been met. 10. Audits Audits should be conducted and documented to verify compliance with the Fire Protection Program including design and procurement documents, instructions, procedures and drawings, and inspection and test activities.
None. Operational Phase Following the turnover of the fire protection systems to PP&L, the PP&L OQA program took effect. The Operation Quality Assurance Program concerning fire protection is discussed in FSAR Section 17.2.2.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 11 of 49 D. General Guidelines for Plant Protection 1. Building Design (a) Plant layouts should be arranged to: (1) Isolate safety-related systems from unacceptable fire hazards, and (2) Separate redundant safety-related systems from each other so that both are not subject to damage from a single fire hazard. Safe shutdown systems are addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in Section 3.0 and 6.0 of this report. (b) ln order to accomplish 1.(a) above, safety-related systems and fire hazards should be identified throughout the plant. Therefore, a detailed fire hazard analysis should be made. The fire hazards analysis should be reviewed and updated as necessary. Additionally, the fire hazards analysis should be done after any plant modification. A fire hazards analysis has been completed as part of Susquehanna SES compliance with 10CFR50, Appendix R. This fire hazards analysis will be revised after any plant modifications as necessary. (c)  For multiple reactor sites, cable spreading rooms should not be shared between reactors. Each cable spreading room should be separated from other areas of the plant by barriers (walls and floors) having a minimum fire resistance of three hours. Cabling for redundant safety divisions should be separated by walls having three-hour fire barriers. The redundant division Cable Spreading Rooms on each Unit are separated from each other by a 3-hour barrier. Each unit's cable spreading rooms are also separated from the other unit by a 3-hour barrier. Each unit's cable spreading rooms are also separated from their respective unit's Reactor and Turbine Buildings by a 3-hour barrier. Within each unit's Control Structure, the Upper Cable Spreading Rooms in each unit are separated from their respective unit's Upper Relay Rooms by a3-hour barrier. Each cable spreading room in each unit is separated from adjacent duct and cable chases, the elevator and the stairwell by a 2-hour barrier. Beams supporting the upper cable spreading room floor slabs are not fire proofed; however, they are addressed and justified in Deviation Request No. 6. The upper and lower cable spreading rooms primarily contain different divisions of safety-related cable. The separation of redundant safe shutdown cabling complies with the requirements of 10CFR50, Appendix R.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 12 of 49 (d) Interior wall and structural components, thermal insulation materials and radiation shielding materials, and sound-proofing should be non-combustible. Interior finishes should be non-combustible or listed by a nationally recognized testing laboratory, such as Factory Mutual or Underwriters' Laboratory, Inc. for flame spread, smoke and fuel contribution of 25 or less in its use configuration (ASTM E-84 Test, "Surface Burning Characteristics of Building Materials"). The interior walls and structural sound proofing and radiation shielding materials are non-combustible. The interior finishes are either non-combustible or listed by a testing laboratory for flame spread, smoke, and fuel contribution of 25 or less in its use configuration. Interior finishes are considered to be non-combustible if (1) they have a structural base of non-combustible material, (2) they are not over 1/8" thick and (3) they have a flame spread rating of less than 50 when measured in accordance with ASTM E-84, "Surface Burning Characteristics of Building Materials."(e) Metal deck roof construction should be non-combustible (see the building materials directory of the Underwriters' Laboratory, Inc.) or listed as Class I by Factory Mutual System Approval Guide. Non-combustible roof construction is used at Susquehanna SES. (f) Suspended ceilings and their supports should be of non-combustible construction. Concealed spaces should be devoid of combustibles. Adequate fire detection and suppression systems should be provided where full implementation is not practicable. "Suspended ceiling panels are constructed from non-combustible material as evidenced by the panels being UL listed for flame spread, smoke and fuel contribution of 25 or less. Suspended ceiling supports are non-combustible."  Concealed spaces and suspended ceilings are devoid of combustibles with the exception of cables. Where cables are present in these areas, fixed fire suppression and detection are provided. (g) High voltage - High amperage transformers installed inside buildings containing safety-related systems should be of the dry type or insulated and cooled with non-combustible liquid. It is PP&L's practice to install dry type transformers in buildings. All transformers have been taken into account as part of the combustible loading analysis in compliance with Appendix R. Safety-related systems that are exposed to flammable oil filled transformers should be protected from the effects of a fire by: (i) Replacing with dry transformers or transformers that are insulated and cooled with non-combustible liquid; or (ii) Enclosing the transformer with a three-hour fire barrier and installing automatic water spray protection.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 13 of 49 (h) Buildings containing safety-related systems, having openings in exterior walls closer than 50 feet to flammable oil filled transformers should be protected from the effects of a fire by: (i) Closing of the opening to have fire resistance equal to three hours, (ii) Constructing a three-hour fire barrier between the transformers and the wall openings; or Several buildings at t he Susquehanna Steam Electric Station containing safety-related systems have openings in the exterior walls that are located closer than 50 feet to an oil filled transformer. The oil filled transformers are located on grade, which for the reactor building is at Elevation 670'-0" and for the E-Diesel Generator building is at Elevation 675'-0". In each of these cases, the building is a reinforced concrete structure with a wall thickness in excess of that which would be required to achieve a three-hour fire resistance rating. The Reactor Buildings have openings in their exterior walls closer than 50 feet  (iii) Closing the opening and providing the capability to maintain a water curtain in case of a fire. to the four (4) flammable, oil-filled engineered safeguard transformers:  0X-201; 0X-203; 0X-211; and 0X-213. - Blowout panels located below grade in the exterior wall of the Reactor Buildings are protected by steam vents constructed of reinforced concrete which extend approximately 20 feet above grade. The walls of these steam vents are 12" thick which would be equivalent to a fire rating of more than three-hours. Most of the penetrations in these steam vent walls are sealed as three-hour fire rated penetrations. The non-fire rated penetrations are open and provide no fire resistance rating. There are no more than three non-rated penetrations in each steam vent enclosure with the largest sized penetration being 6" in diameter. These penetrations must remain open because they perform a vacuum breaker function in the event of a high-energy steam break inside of the Reactor Building. These open penetrations do not provide a direct pathway between the steam vent enclosure and the reactor building blowout panels. The open penetrations are at Elevation 672'-0" and the top of the reactor building blowout panels are at Elevation 677'-9". The largest size penetration is 6" diameter and there are fewer than 3 open (non-fire rated) penetrations in any one steam vent. The steam vent covers are mild carbon steel plate reinforced with structural steel angles. These covers are approximately 20 feet above grade at Elevation 690'-0". These covers are approximately 20 feet from the oil-filled transformers. The vent covers protect the steam vents from weather and SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 14 of 49 foreign substances and only open in the event of a high energy line break that releases steam through the blowout panels. In the event of a transformer fire, the steam vent covers, although not fire rated, are considered to be adequate to prevent the fire from entering the steam vent area. - The remaining exposed penetrations in the reactor building wall within a 50  foot radius of the oil filled transformers are three-hour fire rated or have been  evaluated by a qualified FPE to provide acceptable fire protection per  GL 86-10. - The door to the Unit 2 Truck Bay Airlock is not an approved three-hour fire barrier. The door is approximately 45 feet from the transformers. The door opens to the Unit 2 Reactor Building Truck Bay which contains some safety-related conduits, but no safety-related equipment. The nearest floor penetration is a floor drain that is over 12' away from the Unit 2 Truck Bay Airlock door. The floor of the Unit 2 Truck Bay is reinforced concrete and it slopes away from the floor hatch. The E Diesel Generator building has openings within 50 feet of test facility oil-filled transformer 0X-207. - Exhaust vent openings above elevation 726'-0" in the south wall are at least 40'-0" from the transformer. The vents open to non-safety related areas of the E-Diesel Generator building. The vents have 3/4" drains, which would divert any liquid (e.g. transformer oil) prior to accumulating. - The portion of the south wall of the E-Diesel Generator building enclosed by the blast door access protection does not require additional fire rating. - The remaining elevation of the south wall and the penetrations, up to elevation 726'-0" have a fire rating sufficient to preclude any impacts to safety related equipment from an oil filled transformer fire.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 15 of 49 (i) Floor drains, sized to remove expected fire-fighting water flow should be provided in those areas where fixed water fire suppression systems are installed. Drains should also be provided in other areas where hand hose lines may be used if such fire-fighting water could cause unacceptable damage to equipment in the area. Equipment should be installed on pedestals, or curbs should be provided as required to contain water and direct it to floor drains.  (See NFPA 92M, "Waterproofing and Draining of Floors.")  Drains in areas containing combustible liquids should have provisions for preventing the spread of the fire throughout the drain system. Water drainage from areas which may contain radioactivity should be sampled and analyzed before discharge to the environment. The floor drains at Susquehanna SES are required and are sized to accommodate the expected fire-fighting water flow from the fixed suppression systems or hose stations. Curbs are used where necessary to divert water to floor drains. Floor drains in potentially radioactive areas are routed to liquid radwaste. The water from these floor drains is monitored prior to release to the environment. (j) Floors, walls, and ceilings enclosing separate fire areas should have minimum fire rating of three hours. Penetrations in these fire barriers, including conduits and piping, should be sealed or closed to provide a fire resistance rating at least equal to that of the fire barrier itself. Door openings should be protected with equivalent rated doors, frames, and hardware that have been tested and approved by a nationally recognized laboratory. Such doors should be normally closed and locked or alarmed with alarm and annunciation in the control room. Penetrations for ventilation system should be protected by a standard "fire door damper" where required. (Refer to NFPA 80, "Fire Doors and Windows.") The fire hazard in each area should be evaluated to determine barrier requirements. If barrier fire resistance cannot be made adequate, fire detection and suppression should be provided, such as: (i) Water curtain in case of fire, (ii)  Flame retardant coatings, (iii) Additional fire barriers. Fire barriers required to separate redundant safe shutdown equipment are addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R, as described in Section 6.0 of this report. Additional fire barriers as required by Appendix A have a rating exceeding the combustible loading in the adjacent areas. Openings in these barriers are protected to ensure the fire rating integrity of the barrier. One of the following measures is employed to ensure that fire doors which separate fire areas protect openings as required in case of fire: 1) Fire doors are kept closed and electrically supervised at a continuously manned location; or 2) Fire doors are locked closed; or
: 3) Fire doors are provided with automatic hold-open and release mechanisms and inspected weekly to verify that doorways are free of obstructions; or 4) Fire doors are kept closed and inspected weekly to verify that they are in the closed position.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 16 of 49 2. Control of Combustibles (a) Safety-related systems should be isolated or separated from combustible materials. When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function. Such protection may involve a combination of automatic fire suppression and construction capable of withstanding and containing a fire that consumes all combustibles present. Examples of such combustible materials that may not be separable from the remainder of its system are: This item is addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in this report. (1) Emergency diesel generator fuel oil day tanks. (2) Turbine-generator oil and hydraulic control fluid systems. (3) Reactor coolant pump lube oil system. (b) Bulk gas storage (either compressed or cryogenic) should not be permitted inside structures housing safety-related equipment. Storage of flammable gas such as hydrogen should be located outdoors or in separate detached buildings so that a fire or explosion will not adversely affect any safety-related systems or equipment. (Refer to NFPA 50A, "Gaseous Hydrogen Systems.") Bulk gas storage at Susquehanna SES is not permitted inside buildings housing safety-related systems. The bulk storage of hydrogen is located outdoors away from any buildings housing safety-related equipment. The orientation of the bulk hydrogen storage containers is with the long axes parallel to the Circulating Water Pumphouse west wall. The bulk storage of nitrogen is located in a vertical tank oriented with its long axis parallel to the north wall of the Radwaste Building. Bulk chlorine is not currently stored at Susquehanna SES. Care should be taken to locate high pressure gas storage containers with the long axis parallel to building walls. This will minimize the possibility of wall penetration in the event of a container failure. Use of compressed gases (especially flammable and fuel gases) inside buildings should be controlled. (Refer to NFPA 6, "Industrial Fire Loss Prevention.") The Hydrogen Water Chemistry System storage facility is located southwest of the South Gatehouse, outside of the plant security Protected Area. This facility consists of cryogenic liquid storage tanks (one each for hydrogen, oxygen and nitrogen), ambient air vaporizers, automatic valves to isolate the tanks, liquid hydrogen pumps, hydrogen gas receivers and excess flow control devices to protect against a large system leak. This facility is designed and installed in accordance with NRC approved report EPRI NP-5283-SR-A, "Guidelines for Permanent BWR Hydrogen Water Chemistry Installation-1987 Revision". The high pressure gas receivers are located so their long axis is not pointed at any safety related buildings. This will minimize the possibility of wall penetration in the event of a container failure that might generate a missile.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 17 of 49 The use of compressed gas inside plant buildings is controlled by administrative procedures.
  (c)  The use of plastic materials should be minimized. In particular,  halogenated plastics such as polyvinyl chloride (PVC) and neoprene  should be used only when substitute non-combustible materials are  not available. All plastic materials, including flame and fire retardant  materials, will burn with an intensity and BTU production in a range  similar to that of ordinary hydrocarbons. When burning, they produce  heavy smoke that obscures visibility and can plug air filters,  especially charcoal and HEPA. The halogenated plastics also  release free chlorine and hydrogen chloride when burning which are  toxic to humans and corrosive to equipment.
The use of plastics, particularly halogenated plastics (PVC neoprene), will be minimized and these types of materials will be used only when non-combustible substitutes are not available in plant areas where the use of plastic materials could impact the ability to achieve or maintain post-fire safe shutdown. The concern with plastics is that they burn like hydrocarbons producing heavy quantities of smoke. Halogenated plastics are emphasized as an additional concern because they also produce toxic gases and corrosive substances when burning.
This requirement is implemented by minimizing the use of plastics in situations where their use could result in large quantities of plastics accumulating in plant areas where, if ignited, they could pose a threat, for the reasons stated above, to the ability to achieve or maintain post-fire safe shutdown. Typical items of concern are bulk cables runs, particularly in open cable trays, where high chlorine content cables could produce large quantities of toxic gases if ignited, or large pieces of equipment where alternative non-combustible materials of construction to plastics are readily available.
Based on this, the use of plastics will be minimized for the following types of equipment in plant areas where their use could impact the ability to achieve or maintain post-fire safe shutdown:
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 18 of 49
: 1. Architectural finishes, coatings, tiles, flooring, paneling etc. 2. Bulk cables, scheduled and unscheduled, permanent and temporary cable 3. Furnishings, chairs, tables, cabinets 4. Tanks, storage containers 5. Equipment such as the refueling bridge Conversely, the use of plastics, as described below, is exempt from this requirement due to the limited amount of material involved and due to the fact that in these cases, alternative non-combustibles substitute materials are not available. Plastics, including PVC, used in wiring supplied on vendor components or sub-components is generically exempt from this criteria. For these types of items, any fire affecting these items would typically be limited to the cabinet or skid on which the component was mounted. Additionally, such a fire would produce limited amounts of smoke and have little affect on personnel or equipment in the surrounding area. In the event of a cabinet fire, extensive cleaning of items such as relay contacts would be required regardless of the presence of these types of materials. Therefore, for the reasons cited above, minimizing the use of plastics, including PVC,does not apply to the following types of equipment:  (a) Component housings for relays and other panel mounted components, computers, telephones, communications and testing equipment.  (b) Wiring used in vendor supplied panels, computers or equipment.
Additional exceptions to this policy on minimizing the use of plastics will be documented and justified in either the FPRR or DBD019. The following are additional exceptions to this criteria:
: 1. Exemptions applicable to the category of architectural finishes, coatings, tiles, flooring, paneling, etc.  - Plastic architectural materials are used only where no suitable substitute material is available, such as:  (a) Plastic laminate flooring on some access floor areas, plastic laminated countertops.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 19 of 49 (b) Vinyl asbestos tile and seamless vinyl flooring, vinyl all base, vinyl edge trim on access floor panels, and vinyl coated acoustic ceiling panels. These vinyl materials are acceptable for use without evidence of test or listing by a nationally recognized laboratory based on the guidance provided in NUREG-0800.    (c) Floor panels installed in the PGCC rooms are used due to their unique magnetic shielding capabilities and strength to weight ratio.
These panels pass the requirements for flame spread per ASTM E84 as documented in FPRR Table 5.0-1, Section D.1.(d).
  (d) Acrylic lenses are used in fluorescent lighting fixtures.    (e) Carpeting installed in areas containing safety-related equipment has been tested for fire safety under both the Pill Test (FF1-70) and Critical Radiant Panel Test (NFPA 253). The results ensure the carpet will not spread flame in the initial growth stage of a fire and the carpet will not contribute to flame spread in the event of a fire due to other combustibles.      (e).1 Pill Test (FF1-70) Results show the carpeting passes federal standards.    (e).2 Critical Radiant Panel Test (NFPA 253-1978) Results show the CRF of the carpeting is acceptable at a value of 0.45 W/cm 2  (or higher).
: 2. Exemptions applicable to the category of bulk cables, scheduled and unscheduled, permanent and temporary cable:  - Cabling as described in Table 5.0-1, Sections D.3(f) and (g).  - PVC insulated wiring  is not in compliance in the following areas:
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 20 of 49  (a) Time Response Testing cables (b) Fiber optic cables designated as Cable Code FB8 and installed prior to Feb. 1998 contain PVC material (those installed after Feb. 1998 should not contain PVC).  - Elevator traveling cables are not in compliance in the following areas: (a) Unit 1 and Unit 2 Reactor Building elevators traveling cables are specially constructed. Non-PVC cables are unavailable to the industry. (b) The Control Structure passenger elevator traveling cable is specially constructed. Non-PVC cables are unavailable to the industry.  - Cables installed in the Turbine Building under DCP 93-3063 and labeled as THHN. (d) Storage of flammable liquids should, as a minimum, comply with the requirements of NFPA 30, "Flammable and Combustible Liquids Code." - PVC Cables installed in the Radwaste Building Elevation 676" for Crane OH301 upgrade under EC 1090866. The storage of flammable liquids at Susquehanna SES uses the guidance within the applicable sections of NFPA 30. 3. Electric Cable Construction, Cable Trays, and Cable Penetrations (a) Only non-combustible materials should be used for cable tray construction.Susquehanna SES cable trays are constructed of non-combustible material. (b) See Section F.3 for fire protection guidelines for cable spreading rooms.See Section F.3. (c) Automatic water sprinkler systems should be provided for cable trays outside the cable spreading room. Cables should be designed to allow wetting down with deluge water without electrical faulting. Manual hose stations and portable hand extinguishers should be provided as backup. Safety-related equipment in the vicinity of such cable trays, that does not itself require water fire protection, but is subject to unacceptable damage from sprinkler water discharge, should be protected from sprinkler system operation of malfunction.Protection of redundant safe shutdown cabling is addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in Section 6.0 of this report. The tray configuration outside the cable spreading rooms complies with the separation criteria of Regulatory Guide 1.75. Manual hose stations and portable hand extinguishers are provided for fire protection.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 21 of 49 When safety-related cables do not satisfy the provisions of Regulatory Guide 1.75, all exposed cables should be covered with an approved fire retardant coating and a fixed automatic water fire suppression system should be provided. Cables procured for use at Susquehanna SES have been designed for installation in a wet or dry location. (d) Cable and cable tray penetration of fire barriers (vertical and horizontal) should be sealed to give protection at least equivalent to that fire barrier. The design of fire barriers for horizontal and vertical cable trays should, as a minimum, meet the requirements of ASTM E-119, "Fire Test of Building Construction and Materials," including the hose stream test. Where installed penetration seals are deficient with respect to fire resistance, these seals may be protected by covering both sides with an approved fire retardant material. The adequacy of using such material should be demonstrated by suitable testing. Vertical and horizontal cable and cable tray penetrations are sealed. The design of penetration seals for horizontal and vertical cable and cable trays have been qualified by standard fire testing methods in accordance with either ASTM E119 "Fire Test of Building Construction and Materials", IEEE 634 "Standard Cable Penetration Fire Stop Qualification Test", or ASTM E814 "Fire Tests of Through-Penetration Fire Stops". All fire testing for these penetration seals considered the exposure fire time-temperature curve as defined in ASTM E119. Thermal responses at representative locations (i.e. sealant surface, through penetrant, or interface of sealant/through penetrant) on the unexposed sides of the tested assemblies were recorded for comparison to the appropriate acceptance criteria identified in the above referenced standard fire tests. Hose stream testing has been performed on all fire-tested configurations. The majority of the hose stream testing meets the ASTM E119 requirements. However, several configurations were qualified by alternative hose stream testing applications deemed acceptable by Generic Letter 86-10 Supplement 1, Information Notice 88-04,  Appendix A, and NUREG-0800, Section 9.5.1. (e) Fire breaks should be provided as deemed necessary by the fire hazards analysis. Flame or flame retardant coatings may be used as a fire break for grouped electrical cables to limit spread of fire in cable ventings. (Possible cable derating owing to use of such coating materials must be considered during design.) Although fire breaks have been installed at Susquehanna SES, they are not deemed necessary as a result of the fire hazards analysis. Therefore, it is not intended that new breaks will be installed nor will existing breaks be maintained unless the fire break is specifically described in Section 6.0, a deviation request, or is part of a fire barrier.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 22 of 49 (f) Electric cable constructions should as a minimum pass the current IEEE No. 383 flame test.  (This does not imply that cables passing this test will not require additional fire protection.) All scheduled cable types used at Susquehanna SES have been qualified in accordance with the Flame Test Requirements of IEEE 383-1974 except for small quantities of PVC insulated and jacketed cables identified in our response to Item D.2.c. above. For cable installation in operating plants and plants under construction that do not meet the IEEE No. 383 flame test requirements, all cables must be covered with an approved flame retardant coating and properly derated. (g) To the extent practical, cable construction that does not give off corrosive gases while burning should be used in new cable installations.Cable types which give off highly corrosive gases while burning such as PVC cabling are not used for new cable installations at Susquehanna SES except for small quantities of PVC insulated and jacketed cables identified in our response to Item D.2.c above. Fiber optic cables designated as Cable Code FB8 and installed prior to Feb. 1998 contain PVC material. Fiber optic cables installed after Feb. 1998 should not contain PVC material. (h) Cable trays, raceways, conduit, trenches, or culverts should be used only for cables. Miscellaneous storage should not be permitted, nor should piping for flammable or combustible liquids or gases be installed in these areas. Previously installed equipment in cable tunnels or culverts need not be removed if they present no hazard to the cable runs as determined by the fire hazards analysis. At Susquehanna SES, the raceways (cable trays and conduits) are used only for cables. Piping for flammable or combustible liquids or gases is not routed near safe shutdown systems. (i) The design of cable tunnels, culverts, and spreading rooms should provide for automatic or manual smoke venting as required to facilitate manual fire-fighting capability. The Control Structure, including the cable spreading rooms, is provided with a manual smoke removal system to facilitate manual fire-fighting capability. (j) Cables in the control room should be kept to the minimum necessary for operation of the control room. All cables entering the control room should terminate there. Cables should not be installed in floor trenches or culverts in the control room. Existing cabling installed in concealed floor and ceiling spaces should be protected with an automatic total flooding halon system.
Cables installed in the control room (Fire Zone 0-26H) have been kept to the minimum necessary for operation of the control room. Design practice is not to route cables into the control room without terminating them there. Cabling installed in concealed floor and ceiling spaces are protected with total flooding CO 2 systems.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 23 of 49 4. Ventilation (a) The products of combustion that need to be a specific fire area should be evaluated to determine how they will be controlled. Smoke and corrosive gases should generally be automatically discharged directly outside to a safe location. Smoke and gases containing radioactive materials should be monitored in the fire area to determine if release to the environment is within the permissible limits of the plant Technical Specifications. The products of combustion which need to be removed from a specific fire area should be evaluated to determine how they will be controlled. The SSES ventilation exhaust system is described below. Not all rooms and areas have fixed exhaust systems to remove combustion products. The rooms and areas that do have exhaust systems capable of removing smoke do not automatically discharge directly outside as specified in the guideline. This specified discharge is contrary to effective fire-fighting guidelines, which refer to automatic room isolation in the event of fire, and guidelines and regulations that govern the release of radioactivity. In all cases the operator will have the option of controlling the various systems manually. The exhaust systems contain fire dampers and doors where penetrations are made in fire-rated walls, floors, or ceilings. Products of combustion emanating from areas that could contain radioactive materials are continuously monitored prior to discharge. These monitors do not monitor a given single-fire area. The following described the method used in controlling smoke from various areas: Control Structure:  In case of fire in any room in the control structure between elevations 698'-0" through 771'-0", the fire dampers of the supply and return air ducts will close automatically and isolate the room. After the fire has been extinguished, the smoke removal fan can be started manually and the required dampers necessary for smoke removal from the affected room will be opened by remote manual operation. The exhausted smoke is monitored for radiation in the exhaust stack.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 24 of 49 Turbine Building:  The turbine lube oil reservoir room, hydraulic control power room, lube oil conditioner room, and upper and lower switchgear rooms in the turbine building are provided with fire dampers in their supply and return air ducts. The above listed rooms will be isolated in case of fire. There is no dedicated smoke removal system in the turbine building. Smoke and heat vents on a ratio of 1 sq. ft. of effective vent area to each 100 sq. ft. of floor area and heat vents are operated either by fusible link or manually. Reactor Building:  The heating and ventilating system of the reactor building is a 100 percent outside air operation. The reactor building has no dedicated smoke removal system. Only the emergency load center and emergency switchgear rooms are provided with fire dampers at the ventilation system penetrations for isolation in case of fire. Portable smoke ejectors are provided if required. Once control of the fire is established, the ventilation system serving the affected area can be activated. Radwaste Building:  The heating and ventilating system of the radwaste building is a 100 percent outside air operation. In case of fire, the supply and exhaust fans can be stopped manually by the operator. Smoke could be removed after a fire by using a portable smoke ejector. There is no dedicated smoke removal system in the radwaste building. Diesel Generator, ESSW Pumphouse, and Circulating Water Pumphouse:  None of these buildings are provided with a dedicated smoke removal system. Upon receiving an alarm in the control room, the operator can remotely stop the ventilation systems in either the diesel generator building or the ESSW pumphouse. The circulating water pumphouse requires local tripping of each fan system in order to isolate the building. All systems for the subject buildings are capable of exhausting and supplying fresh air by manually activating the ventilation systems.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 25 of 49 (b) Any ventilation system designed to exhaust smoke or corrosive gases should be evaluated to ensure that inadvertent operation or single failures will not violate the controlled areas of the plant design. This requirement includes containment functions for protection of the public and maintaining habitability for Operations personnel. Other than the smoke vents in the turbine building roof and the smoke exhaust system for the control structure, there are no portions of the ventilation system specifically dedicated to smoke removal. The basic design of the overall plant ventilation system considers the effects of inadvertent operation and single failure. The effects of inadvertent operation of the control room ventilation system (pressurization) are minimized by administrative controls. The fire dampers provided within the ventilation system affect only those portions isolated by the dampers with no adverse effects on the balance of the systems. (c) The power supply and controls for mechanical ventilation systems should be run outside the fire area served by the system. The controls for all fans are in the same fire area they serve except for hand switches located in the control room. (d) Fire suppression systems should be installed to protect charcoal filters in accordance with Regulatory Guide 1.52, "Design Testing and Maintenance Criteria for Atmospheric Cleanup Air Filtration." The suppression systems for charcoal filters are designed in accordance with the recommendation of Regulatory Guide 1.52. (e) The fresh air supply intakes to areas containing safety-related equipment or systems should be located remote from the exhaust air outlets and smoke vents of other fire areas to minimize the possibility of contaminating the intake air with the products of combustion. No basis for determining the acceptability of intake and exhaust separation is given in the guideline. Because the requirements of the Uniform Building Code and standard practice are met, existing plant design is considered in compliance with the guideline. The minimum distance between an exhaust system and fresh air intake is approximately 90 feet. (f) Stairwells should be designed to minimize smoke infiltration during a fire. Staircases should serve as escape routes and access routes for fire fighting. Fire exit routes should be clearly marked. Stairwells, elevators, and chutes should be enclosed in masonry towers with a minimum fire rating of three hours and automatic fire doors at least equal to the enclosure construction at each opening into the building. Elevators should not be used during fire emergencies. Where stairwells or elevators cannot be enclosed in three-hour fire-rated barrier with equivalent fire doors, escape and access routes should be established by pre-fire plan and practiced in drills by operating and fire brigade personnel. Although the stairwells are not ventilated by the HVAC system, they are provided with fire doors which are normally closed which minimize smoke infiltration. The stairways are clearly marked and are enclosed in two-hour shafts which is the industry standard construction. This provides a three-hour floor-to-floor separation.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 26 of 49 (g) Smoke and heat vents may be useful in specific areas such as cable spreading rooms and diesel fuel oil storage areas and switchgear rooms. When natural-convection ventilation is used, a minimum ratio of I sq. foot of venting area per 200 sq. feet of floor area should be provided. If forced-convection ventilation is used, 300 CFM should be provided for every 200 sq. feet of floor area. See NFPA No. 204 for additional guidance on smoke control. Smoke and heat vents are provided in the turbine building at a ratio of 1 sq. ft. ft venting area to each 100 sq. ft. of floor area. The upper and lower switch gear room fire doors would need to be opened manually and exhausted with a portable smoke ejector. The cable spreading rooms are provided with a separate smoke removal system as described in Item D.4.a. of this table. (h) Self-contained breathing apparatus, using full face positive pressure masks, approved by NIOSH (National Institute for Occupational Safety and Health - approval formerly given by the U.S. Bureau of Mines) should be provided for fire brigade, damage control, and control room personnel. Control room personnel may be furnished breathing air by a manifold system piped from a storage reservoir if practical. Service or operating life should be a minimum of one half except for the self-contained units. The self-contained breathing apparatus available on site are full face positive pressure masks. This apparatus is provided to the fire brigade, damage control, and control room personnel. Each self-contained breathing apparatus has a minimum of one half hour service time. Each has an adequate supply of bottles and an air recharging system is on site which satisfies the six-hour supply of reserve air requirement. At least two extra air bottles should be located onsite for each self-contained breathing unit. In addition, an onsite 6-hour supply of reserve air should be provided and arranged to permit quick and complete replenishment of exhausted supply air bottles as they are returned. If compressors are used as a source of breathing air, only units approved for breathing air should be used. Special care must be taken to locate the compressor in areas free of dust and contaminants. (i) Where total flooding gas extinguishing systems are used, area intake and exhaust ventilation dampers should close upon initiation of gas flow to maintain necessary gas concentration. (See NFPA 12, "Carbon Dioxide Systems," and 12A, "Halon 1301 Systems.") Initiation of a total flooding gas extinguishing system automatically closes the inlet and exhaust dampers in ventilation ducts serving the areas protected by the system. The Halon 1301 systems are totally enclosed within the PGCC units and do not require dampers to isolate.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 27 of 49 5. Lighting and Communication Lighting and two-way voice communication are vital to safe shutdown and emergency response in the event of fire. Suitable fixed and portable emergency lighting and communication devices should be provided to satisfy the following requirements: (a) Fixed emergency lighting should consist of sealed beam units with individual 8-hour minimum battery power supplies. Sealed beam units with individual eight-hour minimum battery power supplies are addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in this report. Additional lighting which meets Pennsylvania State requirements for emergency egress is provided throughout the facility. (b) Suitable sealed beam battery powered portable hand lights should be provided for emergency use. Sealed beam battery-powered portable hand lights are provided for emergency use. (c) Fixed emergency communication should use voice powered head sets at preselected stations. The communication system consists of four separate and independent networks: 1. Radio system - 5 channel UHF Security (1 primary, 1 backup) Operations (1 for Unit 1, 1 for Unit 2) Other Talk Groups (1 Channel) 2. Public address - 6 channels, 1 page and 5 talk 3. Private auto branch exchange telephone system 4. Voice Powered Communication System (d) Fixed repeaters installed to permit use of portable radio communication units should be protected from exposure fire damage. Repeaters for the radio system are not protected since they are located in an area of the turbine building which contains low combustibles and no safety-related equipment.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 28 of 49 E. Fire Detection and Suppression 1. Fire Detection (a) Fire detection systems should as a minimum comply with NFPA 72D, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems." (b) Fire detection system should give audible and visual alarm and annunciation in the control room. Local audible alarms should also sound at the location of the fire. (c) Fire alarms should be distinctive and unique. They should not be capable of being confused with any other plant system alarms. (d) Fire detection and actuation systems should be connected to the plant emergency power supply. The system complies with the requirements of NFPA 72D, Proprietary Protective Signaling Systems, except as follows: - Operation and supervision of the system is not the primary function of the operators. - Only a low-level alarm is provided for the clarified water storage tank to indicate level is at 300,000 gallons. - Water storage containers are not provided with alarm annunciation when water temperature is below 40F. - The Fire Alarm and Supervisory Alarm contacts, by having a normally closed contact or lacking the proper end of line resistor, do not meet the requirements of NFPA 72D, except for those identified below: -  Deluge Sprinkler Systems (E-327, sh 22) -  Halon Systems (E-327, sh 26) -  PI Valves (E-327, sh 29 and 31) -  Wet and Dry Pipe Sprinkler Systems (E-327, sh 29 and 31) - Local alarms are as follows: 1) Deluge and preaction systems - no local audible alarm 2) CO 2 - I common local audible alarm 3) Ionization, combustion, and fire detectors - no local audible alarm The AC power supplied to the fire detection and actuation systems is fed from the vital AC system.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 29 of 49 2. Fire Protection Water Supply Systems (a) An underground yard fire main loop should be installed to furnish anticipated fire water requirements. NFPA 24, "Standard for Outside Protection," gives necessary guidance for such installation. It references other design codes and standards developed by such organizations as the American National Standards Institute (ANSI) and the American Water Works Association (AWWA). Lined steel or cast iron pipe should be used to reduce internal tuberculation. Such tuberculation deposits in an unlined pipe over a period of years can significantly reduce water flow through the combination of increased friction and reduced pipe diameter. Means for treating and flushing the systems should be provided. Approved visually indicating sectional control valves, such as Post Indicator Valves, should be provided to isolate portions of the main for maintenance or repair without shutting off the entire system. The underground yard fire main loop complies with NFPA 24. It is made of mortar-lined ductile iron pipe to reduce tuberculation. Water used for fire service meets requirements of NFPA 22 and does not require treatment. Flushing of the fire main is possible by sectionalized control of the main fire loop. Post indicator valves provide sectionalized control and isolation to portions of the fire main loop. The fire main system piping is separate from the service and domestic water system piping. The fire main system piping should be separate from service or sanitary water system piping. (b) A common yard fire main loop may serve multi-unit nuclear power plant sites if cross-connected between units. Sectional control valves should permit maintaining independence of the individual loop around each unit. For such installations, common water supplies may also be utilized. The water supply should be sized for the largest single expected flow. For multiple reactor sites with widely separated plants (approaching 1 mile or more), separate yard fire main loops should be used. Susquehanna SES is a two-unit plant site. A common underground fire loop serves both units of the plant. Since both units are in a single plant structure, it is not possible to run an individual loop around each unit. The fire main includes post indicator valves for sectionalizing control of the fire protection water distribution system. A common water supply is used and sized for the maximum expected flow of a single plant fire since fires in both units simultaneously are not a design consideration.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 30 of 49 (c) If pumps are required to meet system pressure or flow requirements, a sufficient number of pumps should be provided so that 100% capacity will be available with one pump inactive (e.g., three 50% pumps or two 100% pumps). The connection to the yard fire main loop from each fire pump should be widely separated, preferably located on opposite sides of the plant. Each pump should have its own driver with independent power supplies and control. At least one pump (if not powered from the emergency diesels) should be driven by non-electrical means, preferably diesel engine. Pumps and drivers should be located in rooms separated from the remaining pumps and equipment by a minimum three-hour fire wall. Alarms indicating pump running, driver availability, or failure to start should be provided in the control room. Details of the fire pump installation should as a minimum conform to NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps." Two 100% redundant 2500 gpm, 140 psi fire pumps are provided. One pump is diesel driven and the other pump is electric. One additional 100% backup 2500 gpm, 165 psi diesel driven fire pump is provided. SSES is provided with three separate sources of water to be used for fire protection. The three sources (clarified water storage tank, Unit 1 and Unit 2 cooling tower basis) are interconnected, allowing the pumps to draw water from any or all sources. Individual fire pump connections to the yard fire main loop are separated with sectionalizing valves between connections. The diesel engine driven fire pump is located in a room enclosed by three-hour fire rated walls, doors, and duct penetrations. The motor driven fire pump is located in the main pump room with the service water pumps and circulating water pumps. This area has a low combustible loading and is protected by hose reels and portable fire extinguishers. The diesel engine driven fire pump is protected by a wet pipe sprinkler system. Alarms indicating pump running, driver availability, or failure to start have been provided in the control room. The fire pump installation conforms to NFPA 20 with the exception that the electric fire pump feeder circuit conductors, which are physically routed inside of the turbine building and circulating Water pump house, are not protected with two inches of concrete or a 2 hour fire rated barrier. The two primary fire pumps are installed in the Circulating Water Pump House and are separated by a 3 hour rated fire wall. A single fire is not capable of removing both fire pumps from service due to the fire wall. The fire wall meets the intent of a 2 hour fire rated barrier protecting the feeder circuit conductors for installations with a single primary pump.  (d) Two separate reliable water supplies should be provided. If tanks are used, two 100% (minimum of 300,000 gallons each) system capacity tanks should be installed. They should be so interconnected that pumps can take suction from either or both. However, a leak in one tank or its piping should not cause both tanks to drain. The main plant fire water supply capacity should be capable of refilling either At Susquehanna SES, there are three separate sources of water to be used for fire protection. The three sources for the Motor Driven and Diesel Driven Fire Pumps are available to be interconnected. The Backup Diesel Driven Fire Pump source is not interconnected to the three primary sources.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 31 of 49 tank in a minimum of eight hours. Common tanks are permitted for fire and sanitary or service water storage. When this is done, however, minimum fire water storage requirements should be dedicated by means of a vertical standpipe for other water services. The domestic water tank does not use a vertical standpipe for minimum fire water storage requirements, however, administrative controls are in place to ensure 300,000 gallons of water are dedicated for fire water.  (e) The fire water supply (total capacity and flow rate) should be calculated on the basis of the largest expected flow rate for a period of two hours, but not less than 300,000 gallons. This flow rate should be based (conservatively) on 1,000 gpm for manual hose streams plus the greater of: (1) All sprinkler heads opened and flowing in the large designed fire area, or (2) The largest open head deluge system(s) operating. The capacity of the clarified water storage tank used for fire protection is 300,000 gallons. Each of the cooling tower basins contains approximately 6,000,000 gallons. The fire water supply (total capacity for each source) is calculated based on the largest expected flow rate for a period of two hours, but not less than 300,000 gallons. The largest expected flow rate is based on all Technical Requirements Manual (TRM) systems assuming a 500 gpm manual hose stream allowance plus the greater of:  (1) All sprinkler heads within the system with the largest design area and with the highest design density opened and flowing, or  (2) The largest open head deluge system operating.
The value of 500 gpm is based on the NRC Safety Evaluation Report, NUREG 0776, provided for Susquehanna Units 1 & 2. This value is also consistent with the current requirement for manual hose stream allowance in the NRC Standard Review Plan, NUREG 0800.  (f) Lakes or fresh water ponds of sufficient size may qualify as sole source of water for fire protection but require at least two intakes to the pump supply. When a common water supply is permitted for fire protection and the ultimate heat sink, the following conditions should also be satisfied: (1) The additional fire protection water requirements are designed into the total storage capacity, and (2) Failure of the fire protection system should not degrade the function of the ultimate heat sink.
(3)Not applicable to Susquehanna SES.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 32 of 49 (g) Outside manual hose installation should be sufficient to reach any location with an effective hose stream. To accomplish this, hydrants should be installed approximately every 250 feet on the yard main system. The lateral to each hydrant from the yard main should be controlled by a visually indicating or key-operated (curb) valve. A hose house, equipped with hose and combination nozzle, and other auxiliary equipment recommended in NFPA 24, "Outside Protection," should be provided as needed but at least every 1,000 feet. Outside manual hose installations have been installed to protect safety related and non-safety related buildings. For the yard main loop surrounding the power block (i.e. Turbine, Reactor and Radwaste Buildings), this is accomplished by installing hydrants at intervals of approximately 250 feet on average along the yard loop surrounding the power block. For other safety related buildings, hydrants have been installed within 250 feet of the building. Fire fighting equipment, such as fire hose, nozzles, adaptors, etc., is provided for each hydrant using NFPA 24 as guidance. The yard main laterals to the hydrants are controlled by a post indicator valve.
PP&L has standardized on American National Fire Hose connection screw thread (NST) as set forth in the National Fire Protection Association Standard 1963. Equipment and material is provided to support the plant's need to be self-reliant; adapters from American National Fire Hose connection screw threads (NST) to the thread type of the local fire department are provided for fire department use. Threads compatible with those used by local fire departments should be provided on all hydrants, hose couplings, and standpipe risers. 3. Water Sprinklers and Hose Standpipe Systems (a) Each automatic sprinkler system and manual hose station standpipe should have an independent connection to the plant underground water main. Headers fed from each end are permitted inside buildings to supply multiple sprinkler and standpipe systems. When provided, such headers are considered an extension of the yard main system. The header arrangement should be such that no single failure can impair both the primary and backup fire protection systems. Each sprinkler and standpipe system should be equipped with OS&Y (outside screw and yoke) gate valve, or other approved shut-off valve, and water flow alarm. Safety-related equipment that does not itself require sprinkler water fire protection but is subject to unacceptable damage if wetted by sprinkler water discharge should be protected by water shields or baffles. Sprinkler systems and manual hose station standpipes are connected to the plant underground water main separately so that no single active failure or crack in a moderate-energy line can impair both the primary and backup fire suppression systems. Hose, standpipe, and automatic water suppression systems serving a single fire area have independent connections to the yard main system. Headers fed from each end are not used at Susquehanna SES.
The effect of fire protection on safe shutdown equipment is addressed as part of the Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in this report. All sprinkler systems in safety-related buildings are equipped with an approved shutoff valve and a water flow alarm. All standpipes in safety-related buildings are equipped with approved shutoff valves.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 33 of 49 (b) All valves in the fire water systems should be electrically supervised. The electrical supervision signal should indicate in the control room and other appropriate command locations in the plant. (See NFPA 26, "Supervision of Valves.") All major fire-protection control valves are provided with electrical supervision or locked in the open position with the exception of normally closed valves. When electrical supervision of fire protection valves is not practicable, an adequate management supervision program should be provided. Such a program should include locking valves open with strict key control, tamper proof seals, and periodic, visual check of all valves. (c) Automatic sprinkler systems should as a minimum conform to requirements of appropriate standards such as NFPA 13, "Standard for the Installation of Sprinkler Systems," and NFPA 15, "Standard for Water Spray Fixed Systems." The appropriate requirements of NFPA 13 and NFPA 15 were used as guidance for the design and installation of automatic sprinkler systems. (d) Interior manual hose installation should be able to reach any location with at least one effective hose steam. To accomplish this, standpipes with hose connections equipped with a maximum of 75 feet of 1-1/2 inch woven jacket lined fire hose and suitable nozzles should be provided in all buildings, including containment, on all floors and should be spaced at not more than 100-foot intervals. Individual standpipes should be of at least 4-inch diameter for multiple hose connections and 2-1/2 inch diameter for single hose connections. These systems should follow the requirements of NFPA No. 14 for sizing, spacing, and pipe support requirements. A general system description for standpipes and hose stations at Susquehanna is included in FPRR section 4.6. The standpipes and hose stations were installed prior to the issue date of BTP 9.5-1. There are no standpipes or hose stations inside of primary containment, although a fire hose station is located just outside the Equipment and Personnel Airlock to the containment. Hose stations are strategically located throughout the plant using the guidance of NFPA 14. Each hose station in the power block contains 100 feet of 1-1/2 inch fire hose with an appropriate nozzle. Hose stations were originally designed to assure that each room or plant area would be within the effective range of a 100' fire hose with suitable nozzle. This resulted in most of the hose stations being spaced at greater than 100' intervals. However, areas have been identified in the plant where an effective hose stream from the installed 100' fire hose at the hose station may not be sufficient to fully reach all extents of each area. The site Fire Brigade is trained in fighting fires using hose stations and actions to be taken should additional fire hose be required. For those areas where the installed fire hose is not long enough, high rise fire hose packs are available for Fire Brigade use.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 34 of 49 Hose stations should be located outside entrances to normally unoccupied areas and inside normally occupied areas. Standpipes serving hose stations in areas housing safety-related equipment should have shut off valves and pressure reducing devices (if applicable) outside the area. There are no standpipes or hose stations inside of the ESSW pumphouse or the A, B, C, and D diesel generator buildings. Both the ESSW pumphouse and the diesel generator building are in close proximity to outside yard fire hydrants. These fire hydrants are provided with hose houses which are outfitted with 2-1/2 inch and 1-1/2 inch hoses and nozzles. All normally occupied areas have hose stations provided inside with the exception of the Control Room, where they are located adjacent to the Control Room. Standpipes serving hose stations in areas housing safety-related equipment have post indicator valves located outside the building. (e) The proper type of hose nozzles to be supplied to each area should be based on the fire hazard analysis. The usual combination spray/straight-stream nozzle may cause unacceptable mechanical damage (for example, the delicate electronic equipment in the control room) and be unsuitable. Electrically safe nozzles should be provided at locations where electrical equipment or cabling is located. The hose nozzles are selected based on the fire hazards analysis. Electrically safe nozzles are provided where electrical equipment or cabling is located. (f) Certain fires such as those involving flammable liquids respond well to foam suppression. Consideration should be given to use of any of the available foams for such specialized protection application. These include the more common chemical and mechanical low expansion foams, high expansion foam, and the relatively new aqueous film forming form (AFFF) for the portion of hose standpipe system affected by this functional requirement should at least satisfy ANSI Standard B31.1, "Power Piping." The water supply for this condition may be obtained by manual operator actuation of valve(s) in a connection to the hose standpipe header from a normal Seismic Category I water system such as Essential Service Water System. The cross-connection should be (a) capable of providing flow to at least two hose stations (approximately 75 gpm/hose station), and (b) designed to the same standards as the seismic Category I water system; it should not degrade the performance of the Seismic Category I water system. Automatic foam fire suppression systems are not installed at PPL Susquehanna, LLC. Foam is available .for use at PPL Susquehanna LLC. Administrative controls restrict the use of foam on Elevation 818 and on the Reactor Building roof during those times when new fuel is being stored in the new fuel storage vault.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 35 of 49
: 4. Halon Suppression Systems The use of Halon fire extinguishing agents should as a minimum comply with the requirements of NFPA 12A and 12B, "Halogenated Fire Extinguishing Agent Systems - Halon 1301 and Halon 1211."  Only UL or FM approved agents should be used. The appropriate requirements of NFPA 12A and 12B were used for the design and installation of Halon systems. Preventive maintenance and testing are performed in accordance with the plant technical specifications. In addition to the guidelines of NFPA 12A and 12B, preventive maintenance and testing of the systems, including check weighing of the Halon cylinders should be done at least quarterly. Particular consideration should also be given to: (a) Minimum required Halon concentration and soak time. (b) Toxicity of Halon.
(c) Toxicity and corrosive characteristics of thermal decomposition products of Halon. 5. Carbon Dioxide Suppression Systems The use of carbon dioxide extinguishing systems should as a minimum comply with the requirements of NFPA 12, "Carbon Dioxide Extinguishing Systems." The appropriate requirements of NFPA 12 were used for the design and installation of the CO 2 systems. Particular consideration should also be given to: (a)  Minimum required CO 2 concentration and soak time. (b) Toxicity of CO 2.(c) Possibility of secondary thermal shock (cooling) damage.
(d) Offsetting requirements for venting during CO 2 injection to prevent overpressurization versus sealing to prevent loss of agent.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 36 of 49 6. Portable Extinguishers Fire extinguishers should be provided in accordance with guidelines of NFPA 10 and 10A, "Portable Fire Extinguishers, Maintenance and Use." Dry chemical extinguishers should be installed with due consideration given to cleanup problems after use and possible adverse effects on equipment installed in the area. The appropriate requirements of NFPA 10 were used for the selection and location of plant portable fire extinguishers. The effectiveness, nature, and clean-up associated with each fire extinguishing agent is considered in placement of fire extinguishers. F. Guidelines for Specific Plant Areas 1. Primary and Secondary Containment (a) Normal Operation Fire protection requirements for the primary and secondary containment areas should be provided on the basis of specific identified hazards. For example: This item is addressed as part of the Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in Section 6.0 of this report. Safety related HVAC charcoal filters for SGTS and CREOAS are protected with manually operated deluge systems. Lubricating oil or hydraulic fluid system for the primary coolant pumps. Cable tray arrangements and cable penetrations. Charcoal filters. Because of the general inaccessibility of these areas during normal plant operations, protection should be provided by automatic fixed systems. Automatic sprinklers should be installed for those hazards identified as requiring fixed suppression. Fire suppression systems should be provided based on the fire hazards analysis. Fixed fire suppression capability should be provided for hazards that could jeopardize safe plant shutdown. Automatic sprinklers are preferred. An acceptable alternate is automatic gas (Halon or CO 2)for hazards identified as requiring fixed suppression protection.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 37 of 49 Operation of the fire protection systems should not compromise integrity of the containment or the other safety-related systems. Fire protection activities in the containment areas should function in conjunction with total containment requirements such as control of contaminated liquid and gaseous release and ventilation. See the response to Item E.3.a of Table 5.0-1. An enclosure may be required to confine the agent if a gas system is used. Such enclosures should not adversely affect safe shutdown or other operating equipment in containment. Fire detection systems should alarm and annunciate in the control room. The type of detection used and the location of the detectors should be most suitable to the particular type of fire that could be expected from the identified hazard. A primary containment general area fire detection capability should be provided as backup for the above described hazard detection. To accomplish this, suitable smoke detection (e.g., visual obscuration, light scattering and particle counting) should be installed in the air recirculation system ahead of any filters. Automatic fire suppression capability need not be provided in the primary containment atmospheres that are inerted during normal operation. However, special fire protection requirements during refueling and maintenance operations should be satisfied as provided below. (b) Refueling and Maintenance Refueling and maintenance operations in containment may introduce additional hazards such as contamination control materials, decontamination supplies, wood planking, temporary wiring, welding, and flame cutting (with portable compressed fuel gas supply). Possible fires would not necessarily be in the vicinity of fixed detection and suppression systems. Management procedures and controls necessary to assure adequate fire protection are discussed in Section 3a. In addition, manual fire-fighting capability should be permanently installed in containment. Standpipes with hose stations and portable fire extinguishers should be installed at strategic locations throughout The Susquehanna SES plant procedures govern transient combustibles and ignition sources in the primary and secondary containments. The atmosphere inside the primary containment area is inerted with nitrogen during operation. There are no standpipes with hose stations installed within the primary containment. During maintenance and refueling, a hose from the standpipe/hose reel located inside the shielding wall of the equipment and personnel access door can be brought into the containment. Portable fire extinguishers are also provided at the containment during refueling and major maintenance outages.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 38 of 49 containment for any required manual fire-fighting operations. Adequate self-contained breathing apparatus are provided at several locations within the plant in designated fire brigade sheds. Equivalent protection from portable systems should be provided if it is impractical to install standpipes with hose stations. Adequate self-contained breathing apparatus should be provided near the containment entrances for fire fighting and damage control personnel. These units should be independent of any breathing apparatus or air supply systems provided for general plant activities. 2. Control Room The control room is essential to safe reactor operation. It must be protected against disabling fire damage and should be separated from other areas of the plant by floors, walls, and roofs having minimum fire resistance ratings of three hours. The control room fire area is bounded on all sides by three-hour fire-rated barriers except for the structural steel beams supporting the floor slab over the control room which are not fire proofed and the fire barriers that interfere with the stairwells, the elevators, the duct chases and the cable chases which are 2-hour rated  The structural steel supporting the floor slab over the control room is addressed and justified in Deviation Request No. 6. The interfacing fire barriers with the stairwells, the elevators and the duct chases have a rating sufficient to withstand the level of combustibles in each area. The cable chases are addressed and justified in Deviation Request No. 37. Control room cabinets and consoles are subject to damage from two distinct fire hazards: (a) Fire originating within a cabinet or console; and (b) Exposure fire involving combustibles in the general room area. A standpipe with a hose reel is located at the control room elevation in each of the two control structure stairwells. Electrically safe nozzles have been provided. Portable fire extinguishers are located both inside and outside adjacent to the control room. Fire detection is provided under the false floor, above the false ceiling, in cable chases, and in the normally occupied areas. Manual fire-fighting capability should be provided for both hazards. Hose stations and portable water and Halon extinguishers should be located in the control room to eliminate the need for operators to leave the control room. An additional hose piping shutoff valve and pressure reducing device should be installed outside the control room. Hose stations adjacent to the control room with portable extinguishers in the control room are acceptable. Breathing apparatus for control room operators is readily available. Cables located in concealed floor and ceiling spaces are provided with fixed automatic total flooding or manual spurt CO 2 protection. A duct ionization smoke detector is installed in the outside air intake plenum, which alarms in the control room if smoke is about to enter the control room. The operator can manually isolate the control room ventilation system.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 39 of 49 Nozzles that are compatible with the hazards and equipment in the control room should be provided for the manual hose station. The nozzles chosen should satisfy actual fire-fighting needs, satisfy electrical safety, and minimize physical damage to electrical equipment from hose stream impingement. Fire detection in the control room cabinets and consoles should be provided by smoke and heat detectors in each fire area. Alarm and annunciation should be provided in the control room. Fire alarms in other parts of the plant should also be alarmed and annunciated in the control room.Automatically isolating the control room ventilation system by the detection system would be degrading to the safety-related ventilation system since the fire detection system is non-safety related. Cables in the PGCC floor sections are protected by an automatic Halon system. See Section D.3.(j) for a discussion of cable terminations. Breathing apparatus for control room operators should be readily available. Control room floors, ceiling, supporting structures, and walls, including penetrations and doors, should be designed to a minimum fire rating of three hours. All penetration seals should be airtight. The control room ventilation intake should be provided with smoke detection capability to automatically alarm locally and isolate the control room ventilation system to protect operators by preventing smoke from entering the control room. Manually operated venting of the control room should be available so that operators have the option of venting for visibility. Manually operated ventilation systems are acceptable. Cables should not be located in concealed floor and ceiling spaces. All cables that enter the control room should terminate in the control room. That is, no cabling should be simply routed through the control room from one area to another. If such concealed spaces are used, however, they should have fixed automatic total flooding halon protection. 3. Cable spreading room (a) The preferred acceptable methods are: (1) Automatic water system such as closed head sprinklers, open head deluge, or open directional spray nozzles. Deluge and open spray systems should have provisions for manual operation at a remote station; however, there should also be provisions to preclude inadvertent operation. Location of sprinkler heads or Automatic pre-action water system using closed head directional spray nozzles is provided to protect the cable spreading rooms.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 40 of 49 spray nozzles should consider cable tray sizing and arrangements to assure adequate water coverage. Cables should be designed to allow wetting down with deluge water without electrical faulting. Open head deluge and open directional spray systems should be zoned so that a single failure will not deprive the entire area of automatic fire suppression capability. The use of foam is acceptable, provided it is of a type capable of being delivered by a sprinkler or deluge system, such
 
as an Aqueous Film Forming Foam (AFFF). (2) Manual hoses and portable extinguishers should be provided as backup. Manual fire hose stations and portable fire extinguishers are provided as backup. (3) Each cable spreading room of each unit should have divisional cable separation and be separated from the other and the rest of the plant by a minimum three-hour rated fire wall.  (Refer to NFPA 251 or ASTM E-119 for fire test resistance rating.) Each unit has two cable spreading rooms which generally contain separate electrical divisions. The redundant division cable spreading rooms on each Unit are separated from each other by a 3-hour barrier. Each unit's cable spreading rooms are also separated from the other unit by a 3-hour barrier. Each unit's cable spreading rooms are also separated from their respective unit's Reactor and Turbine Buildings by a 3-hour barrier. Within each unit's Control Structure, the Upper Cable Spreading Rooms in each unit are separated from their respective unit's Upper Relay Rooms by a 3-hour barrier. Each cable spreading room in each unit is separated from adjacent duct and cable chases, the elevator and the stairwell by a 2-hour barrier. The ability to safely shut down the plant is addressed as part of the Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in this report. (4) At least two remote and separate entrances are provided to the room for access by fire brigade personnel. Two remote and separate entrances are provided to each of the cable spreading rooms.(5) Aisle separation provided between tray stacks should be at least three feet wide and eight feet high. The aisle separation between tray stacks in the upper cable spreading room, for the most part, satisfy with the width and height recommendations of Appendix A. However, due to space limitations in some areas, the aisle height clearance is between 7 feet and 3 feet 6 inches. (b) For cable spreading rooms that do not provide divisional cable separation of a(3), in addition to meeting a(1), (2), (4), and (5) above, the following should also be provided:
N/A SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 41 of 49 (1) Divisional cable separation should meet the guidelines of Regulatory Guide 1.75, "Physical Independence of Electric Systems". (2) All cabling should be covered with a suitable fire retardant coating. (3) As an alternate to a(1) above, automatically initiated gas systems (Halon or CO
: 2) may be used for primary fire suppression, provided a fixed water system is used as a backup. (4) Plants that cannot meet the guidelines of Regulatory Guide 1.75, in addition to meeting a(1), (2), (4), and (5) above, an auxiliary shutdown system with all cabling independent of the cable spreading room should be provided. 4. Plant Computer Room Safety-related computers should be separated from other areas of the plant by barriers having a minimum three-hour fire resistant rating. Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Manual hose stations and portable water and Halon fire extinguishers should be provided. The computers at Susquehanna SES are not safety related, but a three-hour barrier separates the computer room from the relay rooms. The computer room is protected by a CO 2 system. The computer room fire detection system is automatic and is alarmed in the control room. No local annunciation is provided. Portable extinguishers are provided. 5. Switchgear Rooms Switchgear rooms should be separated from the remainder of the plant by minimum three-hour rated fire barriers to the extent practicable. Automatic fire detection should alarm and annunciate in the control room and alarm locally. Fire hose stations and portable extinguishers should be readily available. Acceptable protection for cables that pass through the switchgear room is automatic water or gas agent suppression. Such automatic suppression must consider preventing unacceptable damage to electrical equipment and possible necessary containment of agent, following discharge. Switchgear rooms are enclosed by concrete or concrete block walls of sufficient thickness and density to qualify as three-hour rated barriers. Floor slabs and overhead slabs are of sufficient thickness to qualify as three-hour rated barriers. Exposed floor steel framing is not fireproofed. However, it is justified in Deviation Request No. 6. The fire detection system in the switchgear rooms alarm on the fire protection control panel in the control room. No automatic water or gas agent suppression is provided for cables passing through the switchgear rooms. Fire hose stations and portable extinguishers are readily available.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 42 of 49 6. Remote Safety-Related Panels The general area housing remote safety-related panels should be provided with automatic fire detectors that alarm locally and alarm and annunciate in the control room. Combustible materials should be controlled and limited to those required for operation. Portable extinguishers and manual hose stations should be provided. The fire detection system in the area of remote safety-related panels will alarm on the fire protection control panel in the control room. Fire hose stations and portable extinguishers are provided. Combustible material is controlled through the plant procedures. 7. Station Battery Rooms Battery rooms should be protected against fire explosions. Battery rooms should be separated from each other and other areas of the plant by barriers having a minimum fire rating of three hours inclusive of all penetrations and openings. (See NFPA 69, "Standard on Explosion Prevention Systems.") Ventilation systems in the battery rooms should be capable of maintaining the hydrogen concentration well below 2 volume % hydrogen concentration. Standpipe and hose and portable extinguishers should be provided. The appropriate requirements, including protection against fire and explosions, of NFPA 69 were used as guidance for the design of the battery rooms. Battery rooms containing combustible batteries are separated from each other and other plant areas by three-hour fire-rated barriers. The ventilation system is capable of maintaining the hydrogen concentration below 2% by volume. Portable extinguishers and hose stations are provided. Alternatives:
(a) Provide a total fire-rated barrier enclosure of the battery room complex that exceeds the fire load contained in the room. (b) Reduce the fire load to be within the fire barrier capability of 1-1/2 hours. OR(c) Provide a remote manual actuated sprinkler system in each room and provide the 1-1/2 hour fire barrier separation.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 43 of 49 8. Turbine Lubrication and Control Oil Storage and Use Areas A blank fire wall having a minimum resistance rating of three hours should separate all areas containing safety-related systems and equipment from the turbine oil system. This item is addressed as part of the Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in Section 6.0 of this report. When a blank wall is not present, open head deluge protection should be provided for the turbine oil hazards, and automatic open head water curtain protection should be provided for wall openings. 9. Diesel Generator Areas Diesel generators should be separated from each other and other areas of the plant by fire barriers having a minimum fire resistance rating of three hours. Automatic fire suppression such as AFFF foam or sprinklers should be installed to combat any diesel generator or lubricating oil fires. Automatic fire detection should be provided to alarm and annunciate in the control room and alarm locally. Drainage for fire-fighting water and means for local manual venting of smoke should be provided. The diesel generator buildings A, B, C, and D are separated from each other and other plant areas by minimum three-hour fire barriers. The E Diesel Generator Building is physically detached from all other plant buildings. An automatic pre-action fire suppression system and a fire detection system are provided for each diesel generator building. The systems alarm on the fire protection control panel in the control room. Drainage is provided for fire-fighting water. The ventilation systems for the diesel generator areas are discussed in Item E.4 (a) above. Day tanks with total capacity up to 1100 gallons are permitted in the diesel generator area under the following conditions: A 550-gallon capacity day tank is mounted on the skid of each diesel engine. The whole area is protected by a preaction sprinkler system. This is in accordance with the guidance provided in NFPA 37. (a) The day tank is located in a separate enclosure with a minimum fire resistance rating of three hours, including doors or penetrations. These enclosures should be capable of containing the entire contents of the day tanks. The enclosure should be ventilated to avoid accumulation of oil fumes. (b) The enclosure should be protected by automatic fire suppression systems such as AFFF or sprinklers.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 44 of 49 When day tanks cannot be separated from the diesel-generator, one of the following should be provided for the diesel generator area: (a) Automatic open head deluge or open head spray nozzle systems. (b) Automatic closed head sprinklers. (c) Automatic AFFF that is delivered by a sprinkler deluge or spray system. (d) Automatic gas system (Halon or CO
: 2) may be used in lieu of foam or sprinklers to combat diesel generator and/or lubricating oil fires. 10. Diesel Fuel Oil Storage Areas Diesel fuel oil tanks with a capacity greater than 1100 gallons should not be located inside the buildings containing safety-related equipment. The diesel fuel storage tanks are buried outside and adjacent to the diesel generator buildings. They should be located at least 50 feet from any building containing safety-related equipment, or if located within 50 feet, they should be housed in a separate building with construction having a minimum fire resistance rating of three hours. Buried tanks are considered as meeting the three-hour fire resistance requirements. See NFPA 30, "Flammable and Combustible Liquids Code," for additional guidance. When located in a separate building, the tank should be protected by an automatic fire suppression system such as AFFF or sprinklers. Tanks, unless buried, should not be located directly above or below safety-related systems or equipment regardless of the fire rating of separating floors or ceilings. In operating plants where tanks are located directly above or below the diesel generators and cannot reasonably be moved, separating floors and main structural members should, as a minimum, have fire resistance rating of three hours. Floors should be liquid tight to prevent leaking of possible oil spills from one level to another. Drains should be provided to remove possible oil spills and fire-fighting water to a safe location.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 45 of 49 One of the following acceptable methods of fire protection should also be provided: (a) Automatic open head deluge or open head spray nozzle system(s), (b) Automatic closed head sprinklers, or (c) Automatic AFFF that is delivered by a sprinkler system or spray system. 11. Safety-Related Pumps Pump houses and rooms housing safety-related pumps should be protected by automatic sprinkler protection unless a fire hazards analysis can demonstrate that a fire will not endanger other safety-related equipment required for safe plant shutdown. Early warning fire detection should be installed with alarm and annunciation locally and in the control room. Local hose stations and portable extinguishers should also be provided. The pumps needed to achieve safe shutdown have been addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R. Local hose stations and portable extinguishers are available at these areas. 12. New Fuel Area Hand portable extinguishers should be located within this area. Also, local hose stations should be located outside but within hose reach of this area. Automatic fire detection should alarm and annunciate in the control room and alarm locally. Combustibles should be limited to a minimum in the new fuel area. The storage area should be provided with a drainage system to preclude accumulation of water. The storage configuration of new fuel should always be so maintained as to preclude criticality for any water density that might occur during fire water application. The new fuel area is a vault with top access covered with a watertight cover plate over a removable aluminum grating. Portable fire extinguishers have been provided adjacent to the top access of the new fuel area. The new fuel area is within the range of hose reel 1HR-201 or 2HR-201. There are no automatic fire detectors within the vault, but there are smoke detectors on the ceiling above the vault. The new fuel is stored in a configuration such that criticality is precluded by administrative controls. Straight stream nozzles are provided in the area of the new fuel storage area. The plant procedures provide control of combustible material in the area. The use of fog spray nozzles on Elevation 818 for fire fighting and for the B.5.b Strategies to spray the spent fuel pool and the reactor/containment is addressed in plant procedures. 13. Spent Fuel Pool Area Protection for the spent fuel pool area should be provided by local hose stations and portable extinguishers. Automatic fire detection should be provided to alarm and annunciate in the control room and to alarm locally. Hose stations and portable extinguishers are provided in the area of the spent fuel pool. The automatic fire detection system above the spent fuel pool area alarms on the fire protection control panel in the control room.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 46 of 49 14. Radwaste Building The radwaste building should be separated from other areas of the plant by fire barriers having at least three-hour ratings. Automatic sprinklers should be used in all areas where combustible materials are located. Automatic fire detection should be provided to annunciate and alarm in the control room and alarm locally. During a fire, the ventilation systems in these areas should be capable of being isolated. Water should drain to liquid radwaste building sumps. Acceptable alternative fire protection is automatic fire detection to alarm and annunciate in the control room, in addition to manual hose stations and portable extinguishers consisting of hand-held and large wheeled units. The radwaste building is separated from the other plant areas by a three-hour fire-rated barrier except for the internal conduit seals as described in Deviation Request No. 20. The controlled zone shops and the access control and laundry area are provided with automatic wet pipe sprinklers. The charcoal portion of the tank vent filter unit is provided with a manual deluge system. All areas in the radwaste building are within reach of at least one water stream from a hose reel. The cable trays in the corridors and pipeway are not provided with automatic sprinklers or fire detectors since they are not controlling or supplying power to safety-related equipment, and a fire in the cable trays will not endanger safety-related equipment. Portable fire extinguishers are located in all areas containing combustible materials except for high radiation areas. Smoke detectors are located in the elevator foyers, the radwaste control center, and the electrical equipment room. Fire detection alarms on the fire protection control panel in the control room and not locally. Ventilation for the radwaste building is discussed in Section D4. (a) above.
Floor drains which drain to liquid radwaste sumps are provided. 15. Decontamination Areas The decontamination areas should be protected by automatic sprinklers if flammable liquids are stored. Automatic fire detection should be provided to annunciate and alarm in the control room and alarm locally. The ventilation system should be capable of being isolated. Local hose stations and hand portable extinguishers should be provided as backup to the sprinkler system. Flammable liquids are not stored in decontamination areas. 16. Safety-Related Water Tanks Storage tanks that supply water for safe shutdown should be protected from the effects of fire. Local hose stations and portable extinguishers should be provided. Portable extinguishers should be located in nearby Safety-related water tanks are not used at Susquehanna SES.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 47 of 49 hose houses. Combustible materials should not be stored next to outdoor tanks. A minimum of 50 feet of separation should be provided between outdoor tanks and combustible materials where feasible. 17. Cooling Towers Cooling towers should be of non-combustible construction or so located that a fire will not adversely affect any safety-related systems or equipment. Cooling towers should be of non-combustible construction when the basins are used for the ultimate heat sink or for the fire protection water supply. The cooling towers at Susquehanna SES are used as a source of water for the fire protection system. The Unit 1 cooling tower is constructed of non-combustible structural components. The Unit 1 fill material is non-combustible, cement fiber boards. The Unit 2 cooling tower is constructed of non-combustible structural components. The Unit 2 fill material is primarily non-combustible, cement fiber boards. Approximately 1.5% of the fill has been replaced with PVC film fill material having a flame spread rating of less than or equal to 25. A fire in the cooling towers would not adversely affect any safety-related structures, systems, or components. Therefore, no additional suppression systems or other fire protection features are required. Due to the limited amounts of combustible PVC film fill installed, the low flame spread rating on this material, and the lack of proximity or potential impact to safety-related structures, systems, and components, this change is considered to maintain an equivalency to the requirements of this section. Cooling towers of combustible construction so located that a fire in them could adversely affect safety-related systems or equipment should be protected with an open head deluge system installation with hydrants and hose houses strategically located.
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 48 of 49 18. Miscellaneous Areas Miscellaneous areas such as records storage areas, shops, warehouses, and auxiliary boiler rooms should be so located that a fire or effects of a fire, including smoke, will not adversely affect any safety-related systems or equipment. Fuel oil tanks for auxiliary boilers should be buried or provided with dikes to contain the entire tank contents. The affect of a fire in miscellaneous areas on safe shutdown equipment is addressed as part of Susquehanna SES compliance with 10CFR50, Appendix R, as discussed in Section 6.0 of this report. The auxiliary boilers at Susquehanna SES are electric and, therefore, do not have any fuel oil tanks. G. Special Protection Guidelines 1. Welding and Cutting, Acetylene - Oxygen Fuel Gas Systems This equipment is used in various areas throughout the plant. Storage locations should be chosen to permit fire protection by automatic sprinkler systems. Local hose stations and portable equipment should be provided as backup. The requirements of NFPA 51 and 51B are applicable to these hazards. A permit system should be required to utilize this equipment.  (Also refer to 2f herein.) Use and storage of all compressed gas cylinders, including Acetylene and Oxygen, within the plant are controlled by plant procedures. Bulk storage of compressed gas cylinders is located outside of and remote from safety-related buildings. The applicable requirements of NFPA 51 and 51B were used as guidance in the preparation of plant procedures. 2. Storage Area for Dry Ion Exchange Resins Dry ion exchange resins should not be stored near essential safety-related systems. Dry unused resins should be protected by automatic wet pipe sprinkler installations. Detection by smoke and heat detectors should alarm and annunciate in the control room and alarm locally. Local hose stations and portable extinguishers should provide backup for these areas. Storage areas of dry resin should have curbs and drains. (Refer to NFPA 92M, "Waterproofing and Draining of Floors.") Bulk storage of dry ion exchange resins are not located near essential safety-related systems or safe shutdown systems. Small amounts (less than 40 c.f.) of dry ion exchange resin are stored in safety related buildings in the plant, all of which are not stored near essential safety-related or safe shutdown equipment. Automatic fire suppression, smoke detection, manual hose stations, and fire extinguishers are provided in these areas except as noted below: 1) Units 1 and 2 Reactor Building elev. 779' (no suppression), 2) Units 1 and 2 Turbine Building elev. 699' (no detection or suppression), 3) Radwaste Building elevation 676' (no detection or suppression).
SSES-FPRR Table Rev. 25  TABLE 5.0-1BRANCH TECHNICAL POSITION GUIDELINESUSQUEHANNA SES COMPLIANCEFPRR Rev. 22 Page 49 of 49 3. Hazardous Chemicals Hazardous chemicals should be stored and protected in accordance with the recommendations of NFPA 49, "Hazardous Chemicals Data." Chemicals storage areas should be well ventilated and protected against flooding conditions since some chemicals may react with water to produce ignition. The applicable requirements of NFPA 49 were used as guidance for the storage and protection of hazardous chemicals. Where necessary, chemical storage areas are ventilated and protected against flooding conditions. 4. Materials Containing Radioactivity Materials that collect and contain radioactivity such as spent ion exchange resins, charcoal filters, and HEPA filters should be stored in closed metal tanks or containers that are located in areas free from ignition sources or combustibles. These materials should be protected from exposure to fires in adjacent areas as well. Consideration should be given to requirements for removal of isotopic decay heat from entrained radioactive materials. Closed metal tanks or containers are used to store contaminated materials. Administrative procedures for handling, storage, and protection of radioactive materials are used at Susquehanna SES. The containers for waste, requiring special considerations for removal of isotopic decay heat, are designed for sufficient heat removal, heat generation, and radiation protection.
SSES*FPRR l Table Rov. 11 TABLE 5.0*2 Page 1 of 7 COMPARISON WITH 10 CFR 50 APPENDIX R REQUIREMENTS IILG. Fire Protection of Safety Shutdown Capability
.,,. 1. Fire Protection features shall be provided for structures, systems, and components important to safe shutdown.
These features shall be capable of limiting fire damage so that: a. One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage; and b. Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station(s) can be re_Q_aired within 72 hours. 2. Except as provided for in paragraph G.3 of this section, where cables or equipment, Including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:
FPRR REV. 13 SUSQUEHANNA SES POSITION The design of the fire protection features at Susquehanna SES is such that both units can achieve and maintain a safe shutdown condition assuming a fire anywhere on site by the use of at least one safe shutdown path. The philosophy used to determine the safe shutdown paths is given in Section 3.0 of this report. Cold shutdown systems can be repaired within 72 hours. As discussed in Section 3.0 of this report, the safe shutdown paths system components and cabling including supi,ort systems and associated circuits were identified.
At least one shutdown path is available in each fire area. (See Section 6.0 of this report for a description of each fire area.) Where separation and protection did not meet the requirements of this Section of 10CFR50 Appendix R, either deviations were requested or changes were made using the Fire Protection Program License Condition coupled with a Fire Hazards Analysis and/or a Fire Protection Program screen. These deviation requests are contained in Section 7.0 of this report. Also, the guidance in NRC Generic Letter 86-10. Section 3.1.2 states that rated fire boundaries which have been evaluated and accepted in a published SER, need not be reviewed as part of the reanalysis for compliance wilh Section 111.G of Appendix R A number of fire barriers at Susquehanna SES have been evaluated and accepted in NUREG 0776 and its supplements and are therefore considered fire rated.
I SSES-FPRR II Table Rev. 11 TABLE 5.0-2 COMPARISON WITH 10 CFR 50 APPENDIX R REQUIREMENTS
: a. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a three-hour rating. Structural steel forming a part of or supporting such fire . baniers shall be protected lo provide fire resistance equivalent to that required of the barrier; b. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system shaU be installed in the fire area; or c. Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a one-hour rating. In addition fire detectors and an automatic fire suppression system shall be installed in the fire area. SUSQUEHANNA SESPOSITION Page 2 of 7 Inside noninerted containments one of the.fire protection means specified above or one of the following fire protection means shall be provided:
Since the primary containments at Susquehanna SES are inerted during normal operation.
these .requirements do not apply. d. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards; e. Installation of fire detectors and an automatic fire suppression system in the fire area: or f. Separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield. FPRR REV. 13 II SSES*FPRR II Table Rev. 11 TABLE 5.0a2 Page 3 of 7 COMPARISON WITH 10 CFR 50 APPENDIX R REQUIREMENTS
: 3. Alternative or dedicated shutdown capability and its associated circuits, independent of cables. systems or components in the area, room or zone under consideration, shall be provided:
: a. Whe*re the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G2 of this section; or b. Where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems. ln addition, fire detection and a fixed fire suppression system shall be installed in the area, room or zone under consideration.
111.J Emergency Lighting Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for manual control of safe shutdown equipment and in access and egress roules thereto. FPRR REV. 13 SUSQUEHANNA SES POSITION The design of the alternative shutdown path meets the criteria as set forth in 10CFR50, Appendix R. Section 111.L as required by Generic Letter 86-10. The description of this path is discussed in Section 3.0 of this report. Where separation and protection did not meet the requirements of 10CFR50 Appendix R, deviations were requested.
These deviation requests are contained in Section 7.0 of this report. Eight-hour battery powered emergency lighting is provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto except as noted in the deviation requests.
SSES-FPRR II Table Rev. 11 TABLE 5.0*2 Page 4 of 7 COMPARISON WITH 10 CFR 50 APPENDIX R REQUIREMENTS 111.L Alternative and Dedicated Shutdown Capability
: 1. Alternative or dedicated shutdown capability provided for a specific fire area shall be able to (a} achieve and maintain subcritical reactivity condiUons in the reactor. (b) maintain reactor coolant inventory; (c) achieve and maintain hot standby conditions for a PWR (hot shutdown for a BWR); (d) achieve cold shutdown conditions within 72 hours: and (e} maintain cold shutdown conditions thereafter.
During the postfire shutdown, the reactor coolant system process variables shall be maintained within those predicted for a loss of normal A.C. power, and the fission product boundary integrity shall not be affected; i.e., there shall be no fuel clad damage, rupture of any primary coolant boundary, or rupture of the containment boundary.
: 2. The performance goals for the shutdown functions shall be: a. The reactivity control function shall be capable of achieving and maintaining cold shutdown reactivity conditions.
: b. The reactor coolant makeup funclion shall be capable of maintaining the reactor coolant level above the top of the core for BWRs and be within the level indication in the pressurizer for PW Rs. c. The reactor heat removal function shall be capable of achieving and maintaining decay heat removal. d. The process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control the above functions.
FPRR REV. 13 SUSQUEHANNA SES POSITION The design of the alternative shutdown path meets the criteria as set forth in this section. The description of the alternative shutdown path is discussed in Section 3.0 of this report. 
[I SSES-FPRR II Table Rev. 11 TABLE 5.0ft2 COMPAR\SON WITH 10 CFR 50 APPENDIX R Rf;OUIREMENTS
: e. The supporting functions shall be capable or providing the process cooling, lubrication, etc., necessary to permit the operation of the equipment used for safe shutdown functions.
: 3. The shutdown capability for specific fire areas may be unique for each such area, or it may be one unique combination of systems for all such areas. In either case, the alternative shutdown capability shall be independent of the specific fire area(s) and shall accommodate postfire conditions where off-site power is available and where off-site power is not available for 72 hours. Procedures shall be in effect to Implement this capability.
: 4. If the capability to achieve and maintain cold shutdown will not be a\/ailable because of fire damage, the equipment and systems comprising the means to achieve and maintain the hot standby or hot shutdown condition shall be capable of maintaining such conditions until cold shutdown can be achieved.
If such eQuiprnent and systems will not be capable of being powered by both on-site and off-site electric power syslems because of fire damage. an independent on-site power system shall be provided.
The number of operating shift personnel exclusive of fire brigade members, required to operate such equipment and systems shall be on site at all times. FPRR REV. 13 SUSQUEHANNA SES POSITION Page 5of 7 II SSES-FPRR II Table Rev. 11 TABLE 5.0-2 COMPARISON WITH 10 CFR 50 APPENDIX R REQUIREMENTS
: 5. Equipment and systems comprising the means to achieve and maintain cold shutdown conditions shall not be damaged by fire; or the fire damage to such equipment and systems shall be limited so that the systems can be made operable and cold shutdown can be achieved within 72 hours. Materials for such repairs shall be readily available on site and procedures shall be in effect to implement such repairs. If such equipment used prior to 72 hours after the fire will not be capable of being powered by both on-site and off-site electric power systems because of fire damage. an independent on-site power system shall be provided.
Equipment and systems used after 72 hours may be powered bv off.site power only. 6. Shutdown systems installed to ensure postfire shutdown capability need not be designed to meet seismic Category I criteria, single failure criteria, or other design basis accident criteria, except where required for other reasons, e.g., because of interface with or impact on existing safety systems, or because of adverse valve actions due to fire damage. 7. The safe shutdown equipment and systems for each fire area shall be known to be isolated from associated non.safety circuits in the fire area so that hot shorts, open circuits or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment.
The separation and barriers between trays and conduits of one safe shutdown division and trays and conduits containing associated circuits or safe shutdown cables from the redundant division, or the isolation of these associated circuits from the safe shutdown equipment, shall be such that a postulated fire involving associated circuits will not prevent safe shutdown.
FPRR REV. 13 SUSQUEHANNA SES POSITION Page 6 of 7 I SSES-FPRR I Table Rev. 11 TABLE 5.0-2 Page 7 of 7 COMPARISON WITH 10 CFR 50 APPENDIX R REQUIREMENTS SUSQUEHANNA SES POSITION ~111.0 Oil Collection System for Reactor Coolant Pump The reactor coolant pump shall be equipped with an oil collection system If I Since Susque~anna SE~ Unit 1 _and 2 P,rima!Y C!=)ntain,ments are inerted during the containment is not inerted during normal operation.
The oil collection normal operation.
compliance with Section 111.0 1s achieved.
system shall be so designed, engineered, and installed that failure will not lead to fire during normal or design basis accident conditions and that there is reasonable assurance that the systems will withstand the Safe Shutdown Earthquake.
Such collection systems shall be capable of collecting lube oil from all potential pressurzied and unpressurized leakage sites in the reactor coolant pump lube oil systems. Leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory.
A flame arrester is required in the vent and the flash poinl characteristics oj the oii present the hazard oj fire flashback.
Leakage points to be protected shall include lift pump and piping, overflow lines, lube oil cooler. oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reseivoirs where such features exist on the reactor coolant pumps. The drain line shall be large enough to accommodate the largest potential oil leak. FPRR REV. 13 SSES-FPRR Text Rev. 12 6.0 FIRE HAZARDS ANALYSIS FPRR Rev. 13 6.0-1 SSES-FPRRText Rev. 12 FPRR Rev. 17 6.1-1
 
==6.1INTRODUCTION==
 
====6.1.1 PurposeThe====
purpose of this section is to demonstrate that a single fire postulated to occur anywhere at the plant will not affect the ability of both units to be brought and to be maintained in cold shutdown condition. Section 6.1 describes the general fire protection features used in the fire hazards analysis of each fire area. This discussion serves as an overview to the detailed fire area analysis in Section 6.2. Section 6.2 describes each fire area within the plant and addresses the capability to safely shutdown based on the fire area configuration, combustible loading, specific fire hazards, safe shutdown equipment in each fire zone within the fire area and the deviation requests which directly impact that fire area. Table 6.1-1 lists each fire area in the plant and provides a description of each area, the required safe shutdown path for each area, the FPRR section where its fire hazards analysis is presented and a list of all the fire zones in each fire area. 6.1.2  Fire Protection FeaturesOur safe shutdown criteria is based on the premise that a fire initiated within any given fire area will be contained within that fire area and not damage safe shutdown equipment in any other fire area. Furthermore, as presented in Deviation Request No. 7, for certain fire zones a fire initiated in that fire zone is postulated to spread to each adjacent fire zone which is not separated from the fire zone of origin by fire rated construction. In this manner, safe shutdown components and cables in unaffected fire areas and fire zones will be used to safely shutdown both reactors. As discussed in Section 3.3.1.4, the plant was divided into specific fire areas with each fire area consisting of one or more fire zones. Fire areas were selected to optimally separate the safe shutdown components and cables in each redundant path. This selection process was used to separate, to the greatest extent possible, those systems and components in each redundant path required for safe shutdown as identified in Table 3.1-1. 6.1.2.1  Establishing Fire Areas BoundariesIn accordance with NRC guidelines, the term "fire area" as used in Appendix R is an area sufficiently bounded to withstand the hazards associated with the area and, as necessary, to protect important equipment within the area from a fire outside the area. At Susquehanna SES, a fire area is separated from all other fire areas in the plant by fire-rated construction or spatial separation. The fire rating of the fire-rated construction is designed to withstand the fire load of the fire area or any specific combustible configuration within the fire area. Where relied upon, spatial separation between two fire areas precludes the propagation of the postulated fire from one fire area to another. In order to determine the adequacy of the fire rating of the fire area boundaries, the physical fire area boundaries (i.e., walls and floors/ceilings) were evaluated. The majority of these barriers consist of 12" minimum thick reinforced concrete. Fire-rated gypsum board has also been used for wall construction in some areas. Structural steel and openings in these barriers have been provided with fire rated components or have been justified by deviation requests. Spatial separation has been used as a fire area boundary where sufficient physical distance, lack of intervening combustibles and/or fire protection features exist to adequately separate the SSES-FPRRText Rev. 12 FPRR Rev. 17 6.1-2 redundant safe shutdown equipment of two different areas. At Susquehanna SES two distinct methods of spatial separation were used; the wraparound zone and the buffer zone. A brief description of both concepts is provided here. The wraparound zone exists at three elevations in each Reactor Building. These are areas of the plant which are corridors that connect Fire Areas R-1A with R-1B (Unit 1) and R-2A with R-2B (Unit 2). The construction of a fire-rated wall is impractical due to the plant configuration in these areas. The wraparound zone was initially a spatial separation of 50 ft. between the two communicating fire areas. Due to field conduit routing tolerances of + 8 ft., the wraparound zone was expanded 8 ft. on each side to account for cabling designed to be in the 50 foot area. Hence, the wraparound zone became a 66 foot wide area. Within the wraparound zone, both redundant divisions of required safe shutdown cables are either protected by fire protective wrapping, by spatial separation of 50 feet (minimum), or justified by a fire hazards analysis.
Safe shutdown components within the wraparound zone have been analyzed and are addressed in deviation requests. The fire hazards and combustible configuration of each wraparound area was examined to determine the acceptability of the zone as a spatial separation barrier. A fire initiated in either of the two fire areas connected by the wraparound zone will not propagate through the wraparound zone and into the adjacent fire-free area.
Additionally, a fire initiated within the wraparound zone will not propagate to both adjacent fire areas. Our Appendix R compliance program prohibits the location of any safe shutdown components within the wraparound zone unless a specific evaluation is conducted. The wraparound zone concept is presented in more detail in Deviation Request No. 4. The buffer zone concept is used in the upper elevations of both Reactor Buildings where little or no safe shutdown equipment exists. Using the buffer zone concept, fire areas are separated by two intervening fire zones (buffer zones). Within these buffer zones, both redundant divisions of safe shutdown components and cables are required to be protected or justified by analysis. The combustible loading of the buffer zones is low and there is no specific combustible configurations which would act to propagate a fire between fire areas. Deviation Request No. 7 discusses the buffer zone concept in more detail. 6.1.2.2  Combustible LoadingA fire zone specific combustible loading analysis has been performed. This analysis identifies all in-situ combustible items within each fire zone and assigns each one a conservative heat load value. All of this heat load is summarized and divided by the area of the fire zone to yield an equivalent fire duration in minutes. This theoretical value is the time it would take for all the combustibles to be consumed by a fire in that fire zone assuming that the combustibles are evenly dispersed throughout the zone. In our combustible loading analysis, types of combustibles were grouped into five major categories: 1) mechanical items (i.e., lube oil in pumps or valves, charcoal, etc.), 2) cables in unwrapped or unqualified wrap cable tray, 3) Thermo-Lag raceway fire barriers, either qualified or unqualified wrap, 4)  electrical panels and cabinets and 5) miscellaneous items. Under the mechanical items category, the equipment name and number is listed and the quantity of combustibles is given for each piece of equipment in either gallons of lube oil, diesel fuel oil or pounds of charcoal. Gallons of lube, oil or diesel fuel oil is multiplied by 148,875 BTUs/gallon and charcoal quantity is multiplied by 14,730 BTUs/pound to establish the combustible content for each mechanical item. The combustible contents for all mechanical items are then added for the subtotal for each fire zone.
SSES-FPRRText Rev. 12 FPRR Rev. 17 6.1-3 For cable trays, the combustible loading for the cable insulation in each fire zone was compiled. Initially, the heat released value per sq. ft. was determined for each tray depth and all trays were considered to have maximum fill of 30% cable. The long term program evaluates the combustible loading on a per cable basis. This assures that the aggregate effect of all cables in each cable tray is evaluated against the fire area minimum boundary rating or other limitations which may exist. In accordance with NRC guidelines cables in metal conduits do not constitute combustibles and therefore, are not included in this analysis. NRC Information Notice 95-27 identified that Thermo-Lag was a combustible material. To address this concern, the combustible contribution from Thermo-Lag raceway fire barriers has been included in the combustible loading analysis. The heat of combustion value used for the Thermo-Lag material was derived from industry testing. Electrical panels and cabinets were listed by name and number. All cabinets were grouped according to size or type. The combustibles in each cabinet were conservatively estimated assuming that each cabinet was full of the maximum amount of combustible materials which that type of cabinet could contain. This part of the analysis was considered very conservative since most cabinets actually contain less combustibles than the worst case cabinet types. The combustible content for all electrical cabinets was subtotaled for each fire zone. In the miscellaneous item category, the combustible content for each combustible was established utilizing information from the National Fire Protection Association - Fire Protection
 
Handbook, 16 th Edition. Typical examples of these miscellaneous items are poly-propylene battery cases  (19,970 BTUs/pound), protective clothing (7,950 BTUs/pound) and hydrogen (61,064 BTU's/pound or 325 BTU's/ft3). All miscellaneous items were subtotaled for each fire zone.Our analysis adds the subtotals of the four categories of combustibles for each fire zone giving the total combustibles in BTUs. This value is divided by the fire zone floor area to yield the fire zone fire load in BTUs/sq. ft. The equivalent fire duration in minutes is then calculated based on a value of 80,000 BTUs/sq ft for a fire of 60 minutes duration. Although this classical approach is relied upon for a quantitative assessment of the fire severity in a given zone, it can be somewhat misleading due to the size of the zone and the location and configuration of the combustibles within the zone. In lieu of solely relying upon this method of fire loading severity, the specific combustible configurations within a zone or area and the heat release rate of those combustibles provide a more realistic determination of the fire hazards in
 
the zone. The purpose of the combustible loading analysis is to assure that the fire area boundaries are adequate to contain a fire within that fire area. Our combustible loading program at Susquehanna assures the integrity of our fire barriers and the compliance to deviation requests which rely on this information. Therefore, rather than expressing specific combustible numbers for each fire area discussed in Section 6.2, each fire area discussion outlines any severe combustible configurations in the area and shows that fire barriers of the area are able to contain the fire hazards associated with the area. 6.1.2.3  Fire Detection and Suppression SSES-FPRRText Rev. 12 FPRR Rev. 17 6.1-4 Fire detection and suppression (manual and automatic) systems are an integral part of the plant design. The descriptions of the types of detection and suppression systems employed at Susquehanna SES are described in detail in Section 4.0. Each fire area discussion within this section includes information as to the extent and location of detection and suppression systems in that fire area. The impact of the inadvertent operation or rupture of any fire suppression system in the plant has been evaluated and it has been determined that this condition would not affect the capability to achieve and maintain safe shutdown.
6.1.2.4  Consequences Of A Fire In Each Fire AreaEach fire area of the plant requires the availability of one of the safe shutdown paths as noted in Table 6.1-1. Our safe shutdown analysis and the specific supporting engineering studies evaluate and assure the availability of the required safe shutdown path systems, components and raceway for each fire area. Electrical cabling located in each fire area associated with the safe shutdown systems and components being used to achieve and maintain safe shutdown in the fire area has been specifically evaluated to assure that potential fire induced failures would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished by one of the following: a) evaluating the particular cable and determining that the worst case fire induced effects will not adversely impact the ability of the equipment to perform its required safe
 
shutdown function,b) by providing a manual operator action that can be used to accomplish the required safe shutdown function in the event that cabling for the equipment is damaged as a result of
 
the fire,c) by protecting the circuit concern with a fire rated barrier,  d) by physically separating the cable of concern from its redundant counterpart in accordance with the separation criteria provided in Appendix R Section III.G.2.b, or e) by documenting the acceptability of the existing condition in a deviation request or a fire hazards analysis. In each fire area evaluated, the safe shutdown components which are located in the fire zone and which would be relied upon for use in the event of a fire in that fire zone are listed. These safe shutdown components are referred to as the Category I components. As previously described, these are components which are required for safe shutdown in the event of a fire in the fire zone where the component is located. All Category I components have been addressed by a deviation request, an engineering analysis or plant modification. Each Category I component is listed by component name and number with a reference to the Deviation Request in which it is addressed or a brief description of the engineering analysis which justified its
 
acceptability.Cables required to perform a safe shutdown function have been evaluated per the methodology described in Section 3.0. Cables designated as cable hits as described in Subsection 3.3.1.5 have been resolved by performing a plant modification (i.e., installing fire protective wrapping, SSES-FPRRText Rev. 12 FPRR Rev. 17 6.1-5 cable relocation, circuit modification), a procedural action, an analysis which verified that fire-induced faults would not impact safe shutdown or by a deviation request or a fire hazards analysis. Each fire area description denotes which  path of safe shutdown system cables has been protected in that fire area. The entire unprotected safe shutdown path is assumed to be damaged by the fire unless specific justification to the contrary is provided. 6.1.2.5  Special FeaturesIn certain fire areas manual actions may be necessary to assure safe shutdown compliance to the Appendix R criteria. Each fire area description in Section 6.2 lists any specific manual actions required as the result of the Appendix R safe shutdown analysis. This section of the report also provides a description of any other features which may be unique to that fire area.
6.1.2.6  Deviation RequestsDue to specific configurations within the plant, certain conditions do not strictly conform to the regulations set forth in Appendix R. NRC Generic Letter 86-10 states that a licensee with a Standard License Condition consistent with that described in NRC Generic Letter 86-10 can decide whether or not to submit Deviations to the NRC for their review and acceptance. In the late 1980's prior to the issuance of the SSES Standard License Condition allowing changes to the approved fire protection program, all deviations were submitted to NRC for their review and acceptance. In the 1990's, subsequent to the issuance of the Standard License Condition for SSES Units 1 and 2, the NRC informed PPL that deviations and fire hazards analysis should be handled using the Standard License Condition. The purpose of a deviation request is to identify non-conforming conditions and to provide justification to demonstrate that the methods implemented at Susquehanna SES satisfy the intent of a specific Appendix R requirement. Section 7.0 provides a complete listing of Deviation Requests that affect the fire zones in each Fire Area.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 1 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES A-1 Outside/Yard Areas 1, 3  0-00 Outside/Yard Areas 1 and 3 RCIC and HPCI protected on Unit 2.
0-21B Freight Elevator & Stairwell No. 221 1 and 3 RCIC and HPCI protected on both units. CS-1 Freight Elevator & Stairwell No. 221 1, 3  0-29A Stairwell Vestibule 1 and 3 RCIC and HPCI protected on both units. 0-22B Passenger Elevator & Stairwell No. 120 1 and 3 RCIC and HPCI protected on both units. CS-2 Passenger Elevator & Stairwell No. 120 1, 3  0-29C Stairwell Vestibule 1 and 3 RCIC and HPCI protected on both units. 0-21A Common Equipment Area 1 RCIC protected on Unit 1. 0-22A Central Access Area 1 RCIC protected on Unit 1. 0-22C Entrance Corridor & Lobby 1 RCIC protected on Unit 1. 0-23 Control Structure. Egress Corridor 1 RCIC protected on Unit 1. 0-24A UPS Panel Room (U2) 1 RCIC protected on Unit 1. 0-24B Corridor (C-200, C-204) 1 RCIC protected on Unit 1. 0-24C UPS Panel Room (U1) 1 RCIC protected on Unit 1. CS-3 General Access Area 1  0-24E Computer Room 1 RCIC protected on Unit 1.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 2 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES CS-3 General Access Area 1  0-24F Computer Maintenance Room & Office 1 RCIC protected on Unit 1. 0-24I HVAC Duct Chase 1 and 3 RCIC and HPCI protected on Unit 1. 0-24K HVAC Duct Chase 1 and 3 RCIC and HPCI protected on Unit 1. 0-28S HVAC Duct Chase 1 and 3 RCIC and HPCI protected on Unit 1. 0-29B Fan Room & Associated HVAC Equipment 1 and 3 RCIC and HPCI protected on Unit 1.
0-29D Pipe & Duct Chase 1 and 3 RCIC and HPCI protected on Unit 1.
0-30A C.S. HVAC & SBGTS 1 and 3 RCIC and HPCI protected on Unit 1.
CS-4  HVAC Plenum, Fan Room and Duct Chases 1, 3  0-30B Stairwell No. 125 1 and 3 RCIC and HPCI protected on Unit 1. CS-5 U2 Div II Lower Relay Room 1 0-24G U2 Div II Lower Relay Room 1 RCIC protected on Unit 1.
0-24J South Electrical Cable Chase 3 HPCI protected on both units.
0-25B South Electrical Cable Chase 3 HPCI protected on both units.
0-26B South Electrical Cable Chase 3 HPCI protected on both units. CS-6 South Cable Chase 3 0-26S South Electrical Cable Chase 3 HPCI protected on both units.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 3 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES  0-27F South Electrical Cable Chase 3 HPCI protected on both units. CS-6 South Cable Chase 3 0-28P South Electrical Cable Chase 3 HPCI protected on both units.
0-24L Center Electrical Cable Chase 3 HPCI protected on Unit 2.
0-24M North Electrical Cable Chase 3 HPCI protected on Unit 2.
0-25C Center Electrical Cable Chase 3 HPCI protected on Unit 2.
0-25D North Electrical Cable Chase 3 HPCI protected on Unit 2. 0-26C Center Electrical Cable Chase 3 HPCI protected on Unit 2. 0-26D North Electrical Cable Chase 3 HPCI protected on Unit 2. 0-26T Center Electrical Cable Chase 3 HPCI protected on Unit 2. 0-26V North Electrical Cable Chase 3 HPCI protected on Unit 2. 0-27G Center Electrical Cable Chase 3 HPCI protected on Unit 2. 0-27H North Electrical Cable Chase 3 HPCI protected on Unit 2. CS-7 North and Center Cable Chases 3  0-28Q Center Electrical Cable Chase 3 HPCI protected on Unit 2.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 4 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES CS-7 North and Center Cable Chases 3 0-28R North Electrical Cable Chase 3 HPCI protected on Unit 2.
0-26A Copy Room 2 0-26E Locker Room 2 0-26F Vestibule (U1) 2 0-26G Shift Outage/STA Office 2 0-26H Control Room 2 0-26I Shift Supervisor's Office 2 0-26J Vestibule (U2) 2 0-26K Technical Support Center 2 0-26L TSC Conference Room/Library 2 0-26M TSC North Soffit 2 0-26N Control Room U1 Soffit 2  CS-9 Main Control Room 2 0-26P Control Room U2 Soffit 2 SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 5 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES CS-9 Main Control Room 2 0-26R TSC South Office Soffit 2 0-27C U1 Div I Upper Cable Spreading Room 3 HPCI protected on Unit 2. CS-10 U1 Div I Upper Cable Spreading Room 3  0-27D Electricians Office 3 HPCI protected on Unit 2. CS-11 U2 Div II Equipment Room 1 0-28A-I U2 Div II Equipment Room 1 RCIC protected on Unit 1. CS-12 U2 Div I 125V Battery Room 3 0-28C U2 Div I 125V Battery Room 3 HPCI protected on Unit 1. CS-13 U2 Div II 125V Battery Room 1 0-28E U2 Div II 125V Battery Room 1 RCIC protected on both units. CS-14 U2 Div II 250V Battery Room 1 0-28G U2 Div II 250V Battery Room 1 RCIC protected on Unit 1. CS-15 Cold Instrument Repair Shop 1 0-28H Cold Instrument Repair Shop 1 RCIC protected on Unit 2. CS-16 U1 Div II 250V Battery Room 1 0-28J U1 Div II 250V Battery Room 1 RCIC protected on Unit 2. CS-17 U1 Div II Equipment Room 1 0-28B-I U1 Div II Equipment Room 1 RCIC protected on Unit 2. CS-18 U1 Div II 125V Battery Room 1 0-28M U1 Div II 125V Battery Room 1 RCIC protected on both units. CS-19 U1 Div II 125V Battery Room 1 0-28N U1 Div II 125V Battery Room 1 RCIC protected on both units. CS-20 U2 Div I Equipment Room 3 0-28A-IIU2 Div I Equipment Room 3 HPCI protected on Unit 1.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 6 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES CS-21 U2 Div I 125V Battery Room 3  0-28T U2 Div I 125V Battery Room 3 HPCI protected on both units. CS-22 U2 Div II 125V Battery Room 1  0-28D U2 Div II 125V Battery Room 1 RCIC protected on both units. CS-23 U2 Div I 250V Battery Room 3  0-28F U2 Div I 250V Battery Room 3 HPCI protected on Unit 1. CS-24 U1 Div I Equipment Room 3  0-28B-IIU1 Div I Equipment Room 3 HPCI protected on Unit 2. CS-25 U1 Div I 250V Battery Room 3  0-28I U1 Div I 250V Battery Room 3 HPCI protected on Unit 2. CS-26 U1 Div I 125V Battery Room 3  0-28K U1 Div I 125V Battery Room 3 HPCI protected on both units. CS-27 U1 Div I 125V Battery Room 3  0-28L U1 Div I 125V Battery Room 3 HPCI protected on both units. CS-28 U1 Div II Lower Relay Room 1  0-24D U1 Div II Lower Relay Room 1 RCIC protected on Unit 2. CS-29 U2 Div II Lower Cable Spreading Room 1  0-25A U2 Div II Lower Cable Spreading Room 1 RCIC protected on Unit 1. CS-30 U1 Div II Lower Cable Spreading Room 1  0-25E U1 Div II Lower Cable Spreading Room 1 RCIC protected on Unit 2. CS-31 U2 Div I Upper Relay Room 3  0-27A U2 Div I Upper Relay Room 3 HPCI protected on Unit 1. CS-32 U2 Div I Upper Cable Spreading Room 3  0-27B U2 Div I Upper Cable Spreading Room 3 HPCI protected on Unit 1. CS-33 U1 Div I Upper Relay Room 3  0-27E U1 Div I Upper Relay Room 3 HPCI protected on Unit 2.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 7 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES D-1 Diesel Generator Bay A 3  0-41A Diesel Generator Bay A 3 HPCI protected on both units. D-2 Diesel Generator Bay B 1  0-41B Diesel Generator Bay B 1 RCIC protected on Unit 2. D-3 Diesel Generator Bay C 3  0-41C Diesel Generator Bay C 3 HPCI protected on both units. D-4 Diesel Generator Bay D 1  0-41D Diesel Generator Bay D 1 RCIC protected on both units. D-5 Diesel Generator "E" Bldg 1, 3  0-41E Diesel Generator "E" Bldg 1 and 3 RCIC and HPCI protected on both units. E-1 East Side Of ESSW Pumphouse 3  0-51 East Side Of ESSW Pumphouse 3 HPCI protected on both units. E-2 West Side Of ESSW Pumphouse 1  0-52 West Side Of ESSW Pumphouse 1 RCIC protected on both units.
* 0-6G Surge Tank Vault 1 and 3 RCIC and HPCI protected on Unit 2.
* 0-6H Cask Storage Pit 1 and 3 RCIC and HPCI protected on Unit 2.
* 0-8A Refueling Floor 1 and 3 RCIC and HPCI protected on Unit 2.
1-1A Core Spray "A" Pump Room 3 HPCI protected on Unit 2.
1-1F RHR "A" Pump Room 3 HPCI protected on Unit 2.
R-1A South Side of Unit 1 Reactor Building 3  1-1G Sump Room 3 HPCI protected on Unit 2.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 8 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES  1-2A Core Spray "A" Pump Room Access 3 HPCI protected on Unit 2. 1-2C Railroad Airlock/Access Shaft 3 HPCI protected on Unit 2. 1-3A Heat Exchanger. & Pump Room 3 HPCI protected on Unit 2. 1-3B-S Equipment Removal Area 3 HPCI protected on Unit 2.
* 1-3B-WEquipment Removal Area 1 and 3 RCIC and HPCI protected on Unit 2. 1-3C-S Equipment Access Area 3 HPCI protected on Unit 2.
* 1-3C-WEquipment Access Area 1 and 3 RCIC and HPCI protected on Unit 2. 1-4A-S Containment Access Area 3 HPCI protected on Unit 2.
* 1-4A-WContainment Access Area 1 and 3 RCIC and HPCI protected on Unit 2. 1-4E CRD Rebuild Room 3 HPCI protected on Unit 2. 1-5A-S Standby Liquid Control Area 3 HPCI protected on Unit 2.
* 1-5A-WAccess Corridor 1 and 3 RCIC and HPCI protected on Unit 2.
R-1A South Side of Unit 1 Reactor Building 3  1-5E Penetration Room 3 HPCI protected on Unit 2.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 9 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES  1-5H I&C Instrument Repair Shop 3 HPCI protected on Unit 2.
* 1-6B Load Center Room 1 and 3 RCIC and HPCI protected on Unit 2.
* 1-6C Electrical Equipment Room 1 and 3 RCIC and HPCI protected on Unit 2.
* 1-6D HVAC Equipment Room 1 and 3 RCIC and HPCI protected on Unit 2. 1-6E HVAC Plenum Area 3 HPCI protected on Unit 2.
* 1-6F Spent Fuel Pool 1 and 3 RCIC and HPCI protected on Unit 2.
* 1-7A HVAC Equipment Area 1 and 3 RCIC and HPCI protected on Unit 2.
R-1A South Side of Unit 1 Reactor Building 3
* 1-7B Recirculation Fan Room 1 and 3 RCIC and HPCI protected on Unit 2.
* 0-6G Surge Tank Vault 1 and 3 RCIC and HPCI protected on Unit 2.
* 0-6H Cask Storage Pit 1 and 3 RCIC and HPCI protected on Unit 2.
* 0-8A Refueling Floor 1 and 3 RCIC and HPCI protected on Unit 2. 1-1B Core Spray "B" Pump Room 1 RCIC protected on Unit 2.
R-1B North Side of Unit 1 Reactor Building 1  1-1C HPCI Pump Room 1 RCIC protected on Unit 2.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 10 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES  1-1D RCIC Pump Room 1 RCIC protected on Unit 2. 1-1E RHR "B" Pump Room 1 RCIC protected on Unit 2. 1-1I Elevator Shaft & Stairwell No. 102 1 RCIC protected on Unit 2.
* 1-1J Stairwell No. 101 1 and 3 RCIC and HPCI protected on Unit 2. 1-2B Access Corridor 1 RCIC protected on Unit 2. 1-2D Remote Shutdown Panel Room 1 RCIC protected on Unit 2. 1-3B-N Equipment Removal Area 1 RCIC protected on Unit 2.
* 1-3B-WEquipment Removal Area 1 and 3 RCIC and HPCI protected on Unit 2. 1-3C-N Equipment Access Area 1 RCIC protected on Unit 2.
* 1-3C-WEquipment Access Area 1 and 3 RCIC and HPCI protected on Unit 2. 1-4A-N Containment Access Area 1 RCIC protected on Unit 2.
* 1-4A-WContainment Access Area 1 and 3 RCIC and HPCI protected on Unit 2.
R-1B North Side of Unit 1 Reactor Building 1  1-4B Pipe Penetration Room 1 RCIC protected on Unit 2.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 11 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES  1-4G Main Steam Pipeway 1 RCIC protected on Unit 2. 1-5A-N General Access Area 1 RCIC protected on Unit 2.
* 1-5A-WAccess Corridor 1 and 3 RCIC and HPCI protected on Unit 2. 1-5C Reactor Backwash Receiving Tank Room1 RCIC protected on Unit 2.
* 1-5D RWCU Pump Room & Heat Exchanger Cells 1 and 3 RCIC and HPCI protected on Unit 2. 1-6A General Access Area & Pump Room 1 RCIC protected on Unit 2.
* 1-6B Load Center Room 1 and 3 RCIC and HPCI protected on Unit 2.
* 1-6C Electrical Equipment Room 1 and 3 RCIC and HPCI protected on Unit 2.
* 1-6D HVAC Equipment Room 1 and 3 RCIC and HPCI protected on Unit 2.
* 1-6F Spent Fuel Pool 1 and 3 RCIC and HPCI protected on Unit 2. 1-6I Fuel Pool Holding Pump Room 1 RCIC protected on Unit 2.
R-1B North Side of Unit 1 Reactor Building 1
* 1-7A HVAC Equipment Area 1 and 3 RCIC and HPCI protected on Unit 2. R-1C Unit 1 Primary Containment N/A  1-1H Suppression Chamber N/A SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 12 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES R-1C Unit 1 Primary Containment N/A  1-4F Drywell N/A  R-1D Valve Access Area 1  1-5B Valve Access Area 1 and 3 S/D Unit 1 with Path 1; RCIC for inventory control & RHR SDC for decay heat removal. S/D Unit 2 with
 
Path 3. R-1E 4.16KV Switchgear Room Div II 1  1-4C 4.16KV Switchgear Room Div II 1 RCIC protected on Unit 2. R-1F 4.16KV Switchgear Room Div I 3  1-4D 4.16KV Switchgear Room Div I 3 HPCI protected on Unit 2. R-1G 4.16KV Switchgear Room Div II 1  1-5F 4.16KV Switchgear Room Div II 1 RCIC protected on Unit 2. R-1H 4.16KV Switchgear Room Div I 3  1-5G 4.16KV Switchgear Room Div I 3 HPCI protected on Unit 2.
R-2A South Side of Unit 2 Reactor Building 3
* 0-8A Refueling Floor 1 and 3 RCIC and HPCI protected on Unit 2. 2-1B Core Spray "A" Pump Room 3 HPCI protected on Unit 1. 2-1F RHR "A" Pump Room 3 HPCI protected on Unit 1. 2-1G Sump Room 3 HPCI protected on Unit 1.
* 2-1I Elevator Shaft & Stairwell No. 202 1 and 3 RCIC and HPCI protected on Unit 1.
R-2A South Side of Unit 2 Reactor Building 3  2-2A Remote Shutdown Panel Room 3 HPCI protected on Unit 1.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 13 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES  2-2C Vehicle Airlock 3 HPCI protected on Unit 1. 2-3A Heat Exchanger Pump Room 3 HPCI protected on Unit 1. 2-3B-S Equipment Removal Area 3 HPCI protected on Unit 1.
* 2-3B-WEquipment Removal Area 1 and 3 RCIC and HPCI protected on Unit 1. 2-3C-S Equipment Access Area 3 HPCI protected on Unit 1.
* 2-3C-WEquipment Access Area 1 and 3 RCIC and HPCI protected on Unit 1. 2-4A-S Containment Access Area 3 HPCI protected on Unit 1.
* 2-4A-WContainment Access Area 1 and 3 RCIC and HPCI protected on Unit 1. 2-4E CRD Rebuild Room 3 HPCI protected on Unit 1. 2-4G Main Steam Pipeway 3 HPCI protected on Unit 1. 2-5A-S General Access Area 3 HPCI protected on Unit 1.
* 2-5A-WAccess Corridor 1 and 3 RCIC and HPCI protected on Unit 1.
R-2A South Side of Unit 2 Reactor Building 3  2-5C Reactor Backwash Receiving Tank Room3 HPCI protected on Unit 1.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 14 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES
* 2-5D RWCU Pump Room & Heat Exchanger Cells 1 and 3 RCIC and HPCI protected on Unit 1. 2-5E Pipe Penetration Room 3 HPCI protected on Unit 1.
* 2-5H I&C Instrument Repair Shop 1 and 3 RCIC and HPCI protected on Unit 1.
* 2-6B Load Center Room 1 and 3 RCIC and HPCI protected on Unit 1.
* 2-6D HVAC Equipment Room 1 and 3 RCIC and HPCI protected on Unit 1.
* 2-6E HVAC Plenum Area 1 and 3 RCIC and HPCI protected on Unit 1.
* 2-6F Spent Fuel Pool 1 and 3 RCIC and HPCI protected on Unit 1.
R-2A South Side of Unit 2 Reactor Building 3
* 2-7A HVAC Equipment Area 1 and 3 RCIC and HPCI protected on Unit 1.
* 0-8A Refueling Floor 1 and 3 RCIC and HPCI protected on Unit 2. 2-1A Core Spray "B" Pump Room 1 RCIC protected on Unit 1. 2-1C HPCI Pump Room 1 RCIC protected on Unit 1. 2-1D RCIC Pump Room 1 RCIC protected on Unit 1.
R-2B North Side of Unit 2 Reactor Building 1  2-1E RHR "B" Pump Room 1 RCIC protected on Unit 1.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 15 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES
* 2-1J Stairwell No. 201 1 and 3 RCIC and HPCI protected on Unit 1. 2-2B Personnel Access Corridor 1 RCIC protected on Unit 1. 2-3B-N Equipment Removal Area 1 RCIC protected on Unit 1.
* 2-3B-WEquipment Removal Area 1 and 3 RCIC and HPCI protected on Unit 1. 2-3C-N Equipment Access Area 1 RCIC protected on Unit 1.
* 2-3C-WEquipment Access Area 1 and 3 RCIC and HPCI protected on Unit 1. 2-4A-N Containment Access Area 1 RCIC protected on Unit 1.
* 2-4A-WContainment Access Area 1 and 3 RCIC and HPCI protected on Unit 1. 2-4B Pipe Penetration Room 1 RCIC protected on Unit 1. 2-5A-N Standby Liquid Control Area 1 RCIC protected on Unit 1.
* 2-5A-WAccess Corridor 1 and 3 RCIC and HPCI protected on Unit 1. 2-6A General Access Area & Pump Room 1 RCIC protected on Unit 1.
* 2-6B Load Center Room 1 and 3 RCIC and HPCI protected on Unit 1.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 16 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES  2-6C Electrical Equipment Room 1 RCIC protected on Unit 1.
* 2-6D HVAC Equipment Room 1 and 3 RCIC and HPCI protected on Unit 1.
* 2-6E HVAC Plenum Area 1 and 3 RCIC and HPCI protected on Unit 1.
* 2-6F Spent Fuel Pool 1 and 3 RCIC and HPCI protected on Unit 1.
R-2B North Side of Unit 2 Reactor Building 1
* 2-7A HVAC Equipment Area 1 and 3 RCIC and HPCI protected on Unit 1. 2-1H Suppression Chamber N/A  R-2C Unit 2 Primary Containment N/A  2-4F Drywell N/A  R-2D Valve Access Area 1  2-5B Valve Access Area 1 and 3 S/D Unit 2 with Path 1; RCIC for inventory control & RHR SDC for decay heat removal. S/D Unit 1 with
 
Path 3. R-2E 4.16KV Switchgear Room Div II 1  2-4C 4.16KV Switchgear Room Div II 1 RCIC protected on Unit 1. R-2F 4.16KV Switchgear Room Div I 3  2-4D 4.16KV Switchgear Room Div I 3 HPCI protected on Unit 1. R-2G 4.16KV Switchgear Room Div II 1  2-5F 4.16KV Switchgear Room Div II 1 RCIC protected on Unit 1. R-2H 4.16KV Switchgear Room Div I 3  2-5G 4.16KV Switchgear Room Div I 3 HPCI protected on Unit 1.
SSES - FPRR Table Rev. 13  TABLE 6.1-1  SUSQUEHANNA SES FIRE AREAS
* FIRE ZONES WITH AN "
*" IN THIS COLUMN ARE ANALYZED AS PART OF A PSEUDO FIRE AREA. THE REQUIRED SAFE SHUTDOWN PATH FOR THESE FIRE ZONES INCLUDES SHUTDOWN CAPABILITY IN ADDITION TO THE REQUIRED SAFE SHUTDOWN PATH FOR THE FIRE AREA.
FPRR Rev. 18 Page 17 of 17 FIRE AREA FIRE AREA DESCRIPTION FIRE AREA PATH
* FIRE ZONE FIRE ZONE DESCRIPTION PROTECTED SSD PATH NOTES T-1 Unit 1 and 2 Turbine Building 1, 2 ,3  ALL Unit 1 and 2 Turbine Building 1, 2 and 3 RCIC and HPCI protected on Unit 1. Path 2 is available for both Units. W-1 Radwaste Building 1, 3  ALL Radwaste Building 1 and 3 RCIC and HPCI protected on both units.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-1 6.2  FIRE AREA DESCRIPTION 6.2.1  FIRE AREA R-1A
 
6.2.1.1  General Description
 
Fire Area R-1A is located in the Unit 1 Reactor Building and is comprised of fire zones which generally occupy the southern half of the building. This fire area is shown on Drawings E-205949 thru E-205956 in Section 8.0. Fire Area R-1A predominately contains Division I equipment, components and cabling. Safe Shutdown Path 3, which is comprised primarily of Division II equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in this fire area. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.1.2  Fire Zones The following fire zones are located in Fire Area R-1A:
Fire Zone  Description 1-1A  Core Spray "A" Pump Room 1-1F  RHR "A" Pump Room 1-1G  Sump Room 1-2A  Core Spray "A" Pump Room Access 1-2C  Railroad Airlock/Access Shaft 1-3A  Heat Exch. & Pump Room 1-3B-S  Equipment Removal Area 1-3B-W * #  Equipment Removal Area 1-3C-S  Equipment Access Area 1-3C-W * #  Equipment Access Area 1-4A-S  Containment Access Area 1-4A-W * #  Containment Access Area 1-4-E  CRD Rebuild Room 1-5A-S  Standby Liquid Control Area  1-5A-W * #  Access Corridor 1-5E  Penetration Room 1-5H  I&C Instrument Repair Shop 1-6B ** #  Load Center Room 1-6C ** #  Electrical Equipment Room 1-6D ** #  HVAC Equipment Room 1-6E  HVAC Plenum Area 1-6F ** #  Spent Fuel Pool 1-7A ** #  HVAC Equipment Area 1-7B #  Recirculation Fan Room 0-6G ** #  Surge Tank Vault 0-6H ** #  Cask Storage Pit 0-8A ** #  Refueling Floor SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-2 Fire Zone  Description
* This fire zone is a wraparound area (see Deviation Request No. 4) ** This fire zone is a buffer zone (see Deviation Request No. 7) # This fire zone is analyzed as part of a pseudo fire area since protection of both Paths 1 and 3 is required in this zone. Fire Zones 1-1J and 1-5D that are also analyzed as a part of this pseudo-fire area are included in Fire Area R-1B.
 
6.2.1.3  Combustible Loading
 
The combustible loading for each fire zone within this fire area has been compiled and has been used for specific fire hazards analysis within this fire area. Specific combustible configurations in the fire area may also have been reviewed for their fire hazard severity and for their impact on fire barrier integrity. The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area R-1A are addressed in Deviation Requests 3, 4, 6, 7, 11, 12, 14, 25, 27, 29 and 42 as well as by several fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analyses have been prepared are identified on the Drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.1.4  Fire Detection/Suppression in the Fire Area Automatic fire detection is provided throughout Fire Area R-1A except in the following fire zones:
Fire Zone  Description 1-2C  Railroad Airlock/Access Shaft 1-4E  CRD Rebuild Room 1-6F  Spent Fuel Pool 1-7B  Recirculation Fan Room 0-6H  Cask Storage Pit The justification for lack of automatic detection in these fire zones is given in Deviation Request
 
No. 14.
Automatic fire suppression systems have been installed in local areas based upon fire hazards analysis. These systems are designed to control and suppress any fire which could develop in the fire zones which they protect. The fire zones listed below are equipped with full coverage of
 
an automatic suppression system.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-3 Fire Zone  Description 1-2C  Railroad Airlock/Access Shaft 1-3A  Heat Exchanger & Pump Room 1-3B-S  Equipment Removal Area 1-3B-W  Equipment Removal Area 1-4A-S  Containment Access Area 1-4A-W  Containment Access Area 1-5A-W  Access Corridor 1-5A-S  Standby Liquid Control Area 6.2.1.5  Consequences of a Fire in Fire Area R-1A
 
In the event of a fire in Fire Area R-1A, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-1A associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished by one of the methods described in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.1.5.1  Fire Zone 1-1A - Core Spray "A" Pump Room The following Category I components are located in Fire Zone 1-1A:
- Suppression Pool Filter Pump Suction Valve (HV-15766) - Fire induced spurious opening of this normally closed valve in conjunction with a fire induced spurious opening of normally closed valve HV-15768 could result in a flow diversion from the Suppression Pool. The fire induced spurious opening of HV-15768 is prevented for a fire in Fire Area R-1A. 
- Suppression Pool Filter Pump Suction Valve (HV-15768) - Fire induced spurious opening of this normally closed valve in conjunction with a fire induced spurious opening of normally closed valve HV-15766 could result in a flow diversion from the Suppression Pool. The fire induced hot short on the circuits for HV-15768 in Fire Zone 1-1A cannot cause a spurious opening of this valve. Any circuits with the potential to cause a spurious opening of HV-15768 in Fire Area R-1A are protected with fire rated barrier.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-1A is addressed in Deviation Request 3.
 
6.2.1.5.2  Fire Zone 1-1F - RHR "A" Pump Room
 
There are no Category I components located in Fire Zone 1-1F.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-1F is addressed in Deviation Requests 3 and 6.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-4 6.2.1.5.3  Fire Zone 1-1G - Sump Room There are no Category I components located in Fire Zone 1-1G.
 
6.2.1.5.4  Fire  Zone 1-2A - Core Spray "A" Pump Room Access
 
There are no Category I components located in Fire Zone 1-2A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-2A is addressed in Deviation Request 3.
6.2.1.5.5  Fire Zone 1-2C - Railroad Airlock/Access Shaft
 
There are no Category I components located in Fire Zone 1-2C.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-2C is affected by Deviation Request 14.
 
6.2.1.5.6  Fire Zone 1-3A - Heat Exchanger & Pump Room
 
The following Category I components are located in Fire Zone 1-3A:
- Core Spray Loop B Flow Transmitter (FT-E21-1N003B), Core Spray Loop B Minimum Flow Switch (FIS-E21-1N006B) - Addressed in Deviation Request No. 25.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3A is addressed in Deviation Requests 3, 6, 11 and 25. In addition, the fire hazards analysis identified on Drawing E-205951 in Section 8.0 of this document affects the allowable combustible configuration for this fire zone.
 
Deviation Request 25 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.1.5.7  Fire Zone 1-3B-S - Equipment Removal Area
 
There are no Category I components located in Fire Zone 1-3B-S.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3B-S is addressed in Deviation Request 4.
 
6.2.1.5.8  Fire Zone 1-3B-W- Equipment Removal Area
 
There are no Category I components located in Fire Zone 1-3B-W.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3B-W is addressed in Deviation Requests 4, 6 and
: 42. In addition, the fire hazards analysis identified on Drawing E-205951 in Section 8.0 of this document affects the allowable combustible configuration for this fire zone.
Deviation Request 42 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-5 6.2.1.5.9  Fire Zone 1-3C-S - Equipment Access Area
 
There are no Category I components located in Fire Zone 1-3C-S.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3C-S is addressed in Deviation Request 4.
 
6.2.1.5.10  Fire Zone 1-3C-W - Equipment Access Area The following Category I components are located in Fire Zone 1-3C-W:
- RHR Shutdown Cooling Outboard Isolation Valve (HV-E11-1F008) -
Addressed in Deviation Request No. 29.
- RHR Injection Inboard Isolation Valves (HV-E11-1F015A and HV-E11-1F015B) -
Addressed in Deviation Request No. 29.
- RHR Heat Exchanger Bypass Valves (HV-E11-1F048A and HV-E11-1F048B) -
Addressed in Deviation Request No. 29.
- RHR Heat Exchanger Outlet Temperature Elements (TE-E11-1N027A and TE-E11-1N027B) - Addressed in Deviation Request No. 29.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3C-W is addressed in Deviation Requests 4 and 29.
Deviation Request 29 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.1.5.11  Fire Zone 1-4A-S - Containment Access Area The following Category I components are located in Fire Zone 1-4A-S:
- CRD Hydraulic Control Units (1C0219, 1C0223, 1C0227, 1C0231, 1C0235, 1C0239, 1C0243, 1C0615, 1C0619, 1C0623, 1C0627, 1C0631, 1C0635, 1C0639, 1C0643, 1C0647, 1C1011, 1C1015, 1C1019, 1C1023, 1C1027, 1C1031, 1C1035, 1C1039, 1C1043, 1C1047, 1C1051, 1C1407, 1C1411, 1C1415, 1C1419, 1C1423, 1C1427, 1C1431, 1C1435, 1C1439, 1C1443, 1C1447, 1C1451, 1C1455, 1C1803, 1C1807, 1C1811, 1C1815, 1C1819, 1C1823, 1C1827, 1C1831, 1C1835, 1C1839, 1C1843, 1C1847, 1C1851, 1C1855, 1C1859, 1C2203, 1C2207, 1C2211, 1C2215, 1C2219, 1C2223, 1C2227, 1C2231, 1C2235, 1C2239, 1C2243, 1C2247, 1C2251, 1C2255, 1C2259, 1C2603, 1C2607, 1C2611, 1C2615, 1C2619, 1C2623, 1C2627, 1C2631, 1C2635, 1C2639, 1C2643, 1C2647, 1C2651, 1C2655, 1C2659, 1C3007, 1C3015, 1C3023, 1C3031, 1C3039, 1C3047, 1C3055) 
-  Fire damage to these components could affect the scram capability and the ability to isolate the scram discharge volume. An analysis has determined that damage to the HCU will not prevent scram. If required, the plant operator will isolate the scram discharge volume by manually venting the instrument air header.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-6 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-4A-S is addressed in Deviation Requests 3, 4, 6 and
: 11.
6.2.1.5.12  Fire Zone 1-4A-W - Containment Access Area The following Category I components are located in Fire Zone 1-4A-W:
 
- SCRAM Discharge Volume Vent and Drain Pilot Solenoid Valves (SV-C12-1F009 and SV-C12-1F182) - Fire induced damage to this component can affect the ability of the plant operator to isolate the scram discharge volume from the Control Room. The plant operator can isolate the scram discharge volume by manually venting the instrument air
 
header.  - Back-up SCRAM Valves (SV-C12-1F110A and SV-C12-1F110B) - An analysis has demonstrated that fire induced damage to these valves will not affect the ability to manually scram the reactor. The plant operator can isolate the scram discharge volume
 
by manually venting the instrument air header.
- ARI Vent and Block Valves (SV-14799, SV-147100, SV-147101 and SV-147102) - An analysis has demonstrated that fire induced damage to these valves will not affect the ability to manually scram the reactor and isolate the scram discharge volume.
- Appendix R Communication System Jackplate JP1102 - This component is a jackplate for Loop 1 of the Appendix R sound power communications system. There are no operator actions resulting from a fire in this Fire Area that require the use of this loop of the sound powered communications system. Therefore, this component is not required for post-fire safe shutdown in this Fire Area.
- Appendix R Communication System Jackplate JP1302 - This component is a jackplate for Loop 3 of the Appendix R sound power communications system. There are no operator actions resulting from a fire in this Fire Area that require the use of this loop of the sound powered communications system. Therefore, this component is not required for post-fire safe shutdown in this Fire Area.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-4A-W is addressed in Deviation Requests 4, 6 and
: 12.
 
6.2.1.5.13  Fire Zone 1-4E - CRD Rebuild Room
 
There are no Category I components located in Fire Zone 1-4E.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-4E is addressed in Deviation Request 14.
 
6.2.1.5.14  Fire Zone 1-5A-S - Standby Liquid Control Area
 
The following Category I components are located in Fire Zone 1-5A-S:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2 Reactor Vessel Level Indicating Switch LIS-B21-1N042B) - Addressed by Deviation Request No. 27.
- 120V AC Power Distribution Panel  (1Y201B) - Fire induced damage to this RPS  Electrical Distribution Panel can result in tripping of the Unit 1 Division II RHRSW  Pump (1P506B). If required, the plant operator can reset the trip from the Control Room and start the pump.
- Nuclear Boiler Instrumentation (Reactor Vessel Level Indicating Switches- LIS-B21-1N024C, LIS-B21-1N024D; Reactor Vessel Level Indicating Switches - LIS-B21-1N031B, LIS-B21-1N031D; Reactor Pressure Switches - PIS-B21-1N021B, PS-B21-1N023C, PS-B21-1N023D; Wide Range Level Transmitter - LT-14201B and Wide
 
Range Pressure Transmitter - PT-14201B) - Addressed by Deviation Request No. 27.
- Reactor Vessel High Pressure Switches (PS-B21-1N022A -H, J-N, P, R, S) - Fire damage to these components can result in spurious opening of an SRV. The capability to further depressurize the reactor, as required, and inject with Core Spray in the event of a spurious SRV opening is provided for the plant operator.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-5A-S is addressed in Deviation Requests 4, 6, 11, 12 and 27.
Deviation Request 27 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.1.5.15  Fire Zone 1-5A-W - Access Corridor There are no Category I components located in Fire Zone 1-5A-W.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-5A-W is addressed in Deviation Requests 3, 4, 11 and 12.
6.2.1.5.16  Fire Zone 1-5E - Penetration Room
 
There are no Category I components located in Fire Zone 1-5E.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-5E is addressed in Deviation Requests 3 and 11.
 
6.2.1.5.17  Fire Zone 1-5H - I&C Instr Repair Shop There are no Category I components located in Fire Zone 1-5H.
 
6.2.1.5.18  Fire Zone 1-6B - Load Center Room
 
There are no Category I components located in Fire Zone 1-6B.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6B is addressed in Deviation Request 7.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-8 6.2.1.5.19  Fire Zone 1-6C - Electrical Equipment Room
 
The following Category I components are located in Fire Zone 1-6C.
 
High Primary Containment Pressure Switches (PS-E11-1N010A and PS-E11-1N010C - The capability to manually depressurize the reactor, if required, using the keylock switches in the Unit 1 Upper and Lower Relay Rooms remains available.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6C is addressed in Deviation Request 7.
 
6.2.1.5.20  Fire Zone 1-6D - HVAC Equipment Room
 
There are no Category I components located in Fire Zone 1-6D:
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6D is addressed in Deviation Request 7.
 
6.2.1.5.21  Fire Zone 1-6E - HVAC Plenum Area There are no Category I components located in Fire Zone 1-6E.
 
A fire hazards analysis identified on Drawing E-205954 in Section 8.0 of this document affects the allowable combustible configuration for this fire zone.
 
6.2.1.5.22  Fire Zone 1-6F - Spent Fuel Pool There are no Category I components located in Fire Zone 1-6F.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6F is addressed in Deviation Requests 7 and 14.
6.2.1.5.23  Fire Zone 1-7A - HVAC Equipment Area
 
There are no Category I components located in Fire Zone 1-7A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-7A is addressed in Deviation Request 7.
 
6.2.1.5.24  Fire Zone 1-7B - Recirculation Fan Room
 
There are no Category I components located in Fire Zone 1-7B.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-7B is addressed in Deviation Request 14.
 
6.2.1.5.25  Fire Zone 0-6G - Surge Tank Vault
 
There are no Category I components located in Fire Zone 0-6G.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-9 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-6G is addressed in Deviation Request 7.
 
6.2.1.5.26  Fire Zone 0-6H - Cask Storage Pit There are no Category I components located in Fire Zone 0-6H.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-6H is addressed in Deviation Requests 7 and 14.
 
6.2.1.5.27  Fire Zone 0-8A - Refueling Floor There are no Category I components located in Fire Zone 0-8A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-8A is addressed in Deviation Request 7.
6.2.1.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 1-4A-S, 1-5A-S, 1-5A-W, 1-5E or 1-6C result in spuriously tripping the RHRSW Pump 1P506B, reset the pump trip logic by operating HS-11202B3 to the RESET position and start the pump from the Control Room.
: 2. Should a fire in Fire Zone 1-2A, 1-3A, 1-4A-S or 1-5A-S result in spurious Unit 1 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 1 Division II ADS and to inject water into the reactor using Unit 1 Division II Core Spray remains available from the Control Room.
: 3. Should a fire in Fire Zone 1-3A, 1-4A-S, 1-4A-W**, 1-5A-S or 1-5A-W* result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping the Motor-Generator Set supply breaker 1A10110
 
and/or 1A10210.
* Reactor Recirculation Pump 1P401A can be tripped from the Control Room. ** Reactor Recirculation Pump 1P401B can be tripped from the Control Room.
: 4. Fire Zone 1-4A-S or 1-4A-W, actions performed during plant start up lifts lead in Motor Control Center 1B236 cubicle 102 which disables Reactor Head Vent Valve HV-141-F001 preventing a reactor coolant flow diversion through spurious opening of both Head Vent Valves.
: 5. Should a fire in Fire Zone 1-4A-W result in loss of Unit 1 scram discharge volume isolation capability, isolate the scram discharge volume by manually venting the instrument air header in the Unit 1 Reactor Building.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-10 6. Should a fire in Fire Zone 1-4A-S or 1-5A-S result in loss of the ability to operate Unit 1 ADS from the Control Room, operate the Unit 1 Division II ADS valves individually using the key locked switches located in the Unit 1 Lower Relay Room.
: 7. Should a fire in Fire Zone 1-6C or 1-6D result in loss of the ability to operate Unit 1 ADS from the Control Room, operate the ADS valves individually using the key locked switches located in the Unit 1 Upper Relay Room for Division I or the Lower Relay Room
 
for Division II.
 
6.2.1.7  Deviation Requests Affecting Fire Area R-1A:
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-1A.
 
6.2.2 Fire Area R-1B
 
6.2.2.1  General
 
== Description:==
 
Fire Area R-1B is located in the Unit 1 Reactor Building and is comprised of fire zones which generally occupy the northern half of the building. This fire area is shown on Drawings E-205949 thru E-205956 in Section 8.0. Fire Area R-1B predominately contains Division II equipment, components and cabling. Safe Shutdown Path 1, which is comprised primarily of Division I equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in this fire area. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.2.2  Fire Zones
 
The following fire zones are located in Fire Area R-1B:
 
Fire Zone  Description 1-1B  Core Spray "B" Pump Room 1-1C  HPCI Pump Room 1-1D  RCIC Pump Room 1-1E  RHR "B" Pump Room 1-1I  Elevator Shaft & Stairwell No. 102 1-1J #  Stairwell No. 101 1-2B  Access Corridor 1-2D  Remote Shutdown Panel 1-3B-N  Equipment Removal Area 1-3B-W * #  Equipment Removal Area 1-3C-N  Equipment Access Area 1-3C-W * #  Equipment Access Area 1-4A-N  Containment Access Area 1-4A-W * #  Containment Access Area 1-4B  Pipe Penetration Room 1-4G  Main Steam Pipeway 1-5A-N  General Access Area 1-5A-W * #  Access Corridor 1-5C  Reactor Backwash Receiving Tank Room 1-5D #  RWCU Pump Room & Heat Exch. Cells SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-11 Fire Zone  Description 1-6A  General Access Area & Pump Room 1-6B ** #  Load Center Room 1-6C ** #  Electrical Equipment Room 1-6D ** #  HVAC Equipment Room 1-6F ** #  Spent Fuel Pool 1-6I  Fuel Pool Holding Pump Room 1-7A ** #  HVAC Equipment Area 0-6G ** #  Surge Tank Vault 0-6H ** #  Cask Storage Pit 0-8A ** #  Refueling Floor
* This fire zone is a wraparound area (see Deviation Request No. 4)
** This fire zone is a buffer zone (see Deviation Request No. 7)
# This fire zone is analyzed as part of a pseudo fire area since protection of both Paths 1 and 3 is required in this zone. Fire Zone 1-7B that is also analyzed as a part of this pseudo-fire area is included in Fire Area R-1A.
 
6.2.2.3  Combustible Loading
 
The combustible loading for each fire zone within this fire area has been compiled and has been used for specific fire hazards analysis within this fire area.
Specific combustible configurations in the fire area may also have been reviewed for their fire hazard severity and for their impact on fire barrier integrity. The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area R-1B are addressed in Deviation Requests 3, 4, 6, 7, 8, 11, 12, 13, 14, 29 and 42 as well as several fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the Drawings contained in Section 8.0 of this document. Any restrictions for a fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
6.2.2.4  Fire Detection/Suppression in the Fire Area
 
Automatic fire detection is provided throughout Fire Area R-1B except in the following fire zones:  Fire Zone  Description 1-1J  Stairwell No. 101 1-5C  Reactor Backwash Receiving Tank Room 1-6F  Spent Fuel Pool 0-6H  Cask Storage Pit The justification for lack of detection in these fire zones is presented in Deviation Request
 
No. 14.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-12 Automatic fire suppression systems are installed in local areas where fire hazards have the most severe potential. These systems are designed to control and suppress any fire which could develop in the fire zones which they protect. Fire suppression has been provided in the following fire zones:
 
Fire Zone Description1-2B  Access Corridor 1-3B-N  Equipment Removal Area  (Partial) 1-3B-W  Equipment Removal Area 1-4A-N  Containment Access Area  (Partial) 1-4A-W  Containment Access Area 1-5A-W  Access Corridor Automatic deluge systems are provided for the following equipment listed by fire zones:
Fire Zone Description1-1C  HPCI Pump 1-1D  RCIC Pump Manual deluge systems are provided for charcoal filters 1F217A, 1F217B, 1F257A, and 1F257B in Fire Zone 1-7A.
 
6.2.2.5  Consequences of a Fire in Fire Area R-1B In the event of a design basis fire in Fire Area R-1B, Safe Shutdown Path 1 systems will be available for safe shutdown. Electrical cabling located in Fire Area R-1B associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.2.5.1  Fire Zone 1-1B - Core Spray "B" Pump Room
 
There are no Category I components located in Fire Zone 1-1B.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-1B is addressed in Deviation Request 3.
 
6.2.2.5.2  Fire Zone 1-1C - HPCI Pump Room
 
The following Category I components are located in Fire Zone 1-1C:
 
- HPCI Turbine Auxiliary Oil Pump (1P213) - This component is not required in support of post-fire safe shutdown in Fire Area R-1B. A spurious operation of this component along with other HPCI system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the HPCI system in conjunction with the loss of the HPCI high water level trip in Fire Area R-1B can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-1F002).
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2 HPCI Steam Supply to Turbine Valve (HV-E41-1F001) - This component is not required in support of post-fire safe shutdown in Fire Area R-1B. A spurious operation of this component along with other HPCI system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the HPCI system in conjunction with the loss of the HPCI high water level trip in Fire Area R-1B can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-1F002).
- HPCI Turbine Trip Solenoid Valve (SV-15661) - This component is not required in support of post-fire safe shutdown in Fire Area R-1B. A spurious operation of HPCI system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the HPCI system in conjunction with the loss of the HPCI high water level trip in Fire Area R-1B can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-1F002).
 
6.2.2.5.3  Fire Zone 1-1D - RCIC Pump Room The following Category I components are located in Fire Zone 1-1D:
- RCIC Turbine Stop Valve (HV-15012) - This component is not required in support of post-fire safe shutdown in Fire Area R-1B. A spurious operation of this component along with other RCIC system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the RCIC system in conjunction with the loss of the RCIC high water level trip in Fire Area R-1B can be mitigated by using the protected safe shutdown path for Fire Area R-1B.
- RCIC Steam Supply Line Valve (HV-E51-1F045) - This component is not required in support of post-fire safe shutdown in Fire Area R-1B. A spurious operation of this component along with other RCIC system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the RCIC system in conjunction with the loss of the RCIC high water level trip in Fire Area R-1B can be mitigated by using the protected safe shutdown path for Fire Area R-1B.
6.2.2.5.4  Fire Zone 1-1E - RHR "B" Pump Room The following Category I components are located in Fire Zone 1-1E:
 
- RHR Pump B Shutdown Cooling Suction Valve (HV-E11-1F006B) - This valve must remain closed when RHR is running in the Shutdown Cooling Mode. RHR Shutdown Cooling is not a credited safe shutdown system in Fire Area R-1B.
- RHR Pump D Shutdown Cooling Suction Valve (HV-E11-1F006D) - This valve must remain closed when RHR is running in the Shutdown Cooling Mode. RHR Shutdown Cooling is not a credited safe shutdown system in Fire Area R-1B.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-1E is addressed in Deviation Requests 3 and 6.
 
6.2.2.5.5  Fire Zone 1-1I - Elevator Shaft & Stairwell No. 102
 
There are no Category I components located in Fire Zone 1-1I.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-14 6.2.2.5.6  Fire Zone 1-1J - Stairwell No. 101 There are no Category I components located in Fire Zone 1-1J.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-1J is addressed in Deviation Request 14.
 
6.2.2.5.7  Fire Zone 1-2B - Access Corridor
 
There are no Category I components located in Fire Zone 1-2B.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-2B is addressed in Deviation Request 3.
 
6.2.2.5.8  Fire Zone 1-2D - Remote Shutdown Panel There are no Category I components located in Fire Zone 1-2D.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-2D is addressed in Deviation Request 8.
 
6.2.2.5.9  Fire Zone 1-3B-N - Equipment Removal Area There are no Category I components located in Fire Zone 1-3B-N.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3B-N is addressed in Deviation Requests 3, 4, 11 and 13.
6.2.2.5.10  Fire Zone 1-3B-W - Equipment Removal Area
 
There are no Category I components located in Fire Zone 1-3B-W.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3B-W is addressed in Deviation Requests 4, 6 and
: 42. In addition, the fire hazards analysis identified on Drawing E-205951in Section 8.0 of this document affects the allowable combustible configuration for this fire zone.
 
Deviation Request 42 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.2.5.11 Fire Zone 1-3C-N - Equipment Access Area
 
There are no Category I components located in Fire Zone 1-3C-N.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3C-N is addressed in Deviation Request 4.
 
6.2.2.5.12  Fire Zone 1-3C- W - Equipment Access Area 
 
The following Category I components are located in Fire Zone 1-3C-W:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2 RHR Injection Inboard Isolation Valves (HV-E11-1F015A and HV-E11-1F015B) -
Addressed in Deviation Request No. 29.
- RHR Heat Exchanger Bypass Valves (HV-E11-1F048A and HV-E11-1F048B) -
Addressed in Deviation Request No. 29.
- RHR Shutdown Cooling Outboard Isolation Valve (HV-E11-1F008) - Addressed in Deviation Request No. 29.
- RHR Heat Exchanger Outlet Temperature Elements (TE-E11-1N027A and TE-E11-1N027B) - Addressed in Deviation Request No. 29.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-3C-W is addressed in Deviation Requests 4 and 29.
 
Deviation Request 29 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.2.5.13  Fire Zone 1-4A-N - Containment Access Area
 
The following Category I components are located in Fire Zone 1-4A-N:
-  CRD Hydraulic Control Units (1C3003, 1C3011, 1C3019, 1C3027, 1C3035, 1C3043, 1C3051, 1C3059, 1C3403, 1C3407, 1C3411, 1C3415, 1C3419, 1C3423, 1C3427, 1C3431, 1C3435, 1C3439, 1C3443, 1C3447, 1C3451, 1C3455, 1C3459, 1C3803, 1C3807 1C3811, 1C3815, 1C3819, 1C3823, 1C3827, 1C3831, 1C3835, 1C3839, 1C3843, 1C3847, 1C3851, 1C3855, 1C3859, 1C4203, 1C4207, 1C4211, 1C4215, 1C4219, 1C4223, 1C4227, 1C4231, 1C4235, 1C4239, 1C4243, 1C4247, 1C4251, 1C4255, 1C4259, 1C4607, 1C4611, 1C4615, 1C4619, 1C4623, 1C4627, 1C4631, 1C4635, 1C4639, 1C4643, 1C4647, 1C4651, 1C4655, 1C5011, 1C5015, 1C5019, 1C5023, 1C5027, 1C5031, 1C5035, 1C5039, 1C5043, 1C5051, 1C5415, 1C5419, 1C5423, 1C5427, 1C5431, 1C5435, 1C5439, 1C5443, 1C5447, 1C5819, 1C5823, 1C5827, 1C5831, 1C5835, 1C5839, 1C5843) 
-  Fire damage to this component could affect the scram capability and the ability to isolate the scram discharge volume. An analysis has determined that damage to this HCU will not prevent scram. If required, the plant operator will isolate the scram discharge volume by manually venting the instrument air header.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-4A-N is addressed in Deviation Requests 4, 6 and
: 13. 6.2.2.5.14  Fire Zone 1-4A-W - Containment Access Area
 
The following Category I components are located in Fire Zone 1-4A-W:
 
- SCRAM Discharge Volume Vent and Drain Pilot Solenoid Valves (SV-C12-1F009 and SV-C12-1F182) - Fire induced damage to this component can affect the ability of the plant operator to isolate the scram discharge volume from the Control Room. The plant SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-16 operator can isolate the scram discharge volume by manually venting the instrument air header.  - Back-up SCRAM Valves (SV-C12-1F110A and SV-C12-1F110B) - An analysis has demonstrated that fire induced damage to these valves will not affect the ability to manually scram the reactor. The plant operator can isolate the scram discharge volume by manually venting the instrument air header.
- ARI Vent and Block Valves (SV-14799, SV-147100, SV-147101 and SV-147102) - An analysis has demonstrated that fire induced damage to these valves will not affect the ability to manually scram the reactor and isolate the scram discharge volume.
- Appendix R Communication System Jackplate JP1102 - This component is a jackplate for Loop 1 of the Appendix R sound power communications system. Since this component is located in the Wraparound Area approximately 50 feet south of Fire Area
 
R-1B, a fire in Fire Area R-1B will not damage this component.
- Appendix R Communication System Jackplate JP1302 - This component is a jackplate for Loop 3 of the Appendix R sound power communications system. There are no operator actions resulting from a fire in this Fire Area that require the use of this loop of the sound powered communications system. Therefore, this component is not required for post-fire safe shutdown in this Fire Area.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-4A-W is addressed in Deviation Requests 4, 6 and
: 12. 6.2.2.5.15  Fire Zone 1-4B - Pipe Penetration Room
 
There are no Category I components located in Fire Zone 1-4B.
 
6.2.2.5.16  Fire Zone 1-4G - Main Steam Pipeway
 
The following Category I components are located in Fire Zone 1-4G:
 
- Main Steam Line Outboard Drain Isolation Valve (HV-B21-1F019) - For a fire in Fire Zone 1-4G closure of the Main Steam Line Drain Inboard Isolation Valve (HV-B21-1F016) has been assured in the event that isolation of the Main Steam Line Drain is required.
- HPCI Pump Discharge Valve (HV-E41-1F006) - This component is not required in support of post-fire safe shutdown in Fire Area R-1B. A spurious operation of this component along with other HPCI system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the HPCI system in conjunction with the loss of the HPCI high water level trip in Fire Area R-1B can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-1F002).
- Main Steam Line Outboard Isolation Valve HV-1F028A Pilot Solenoid Valves (SV-14129A1, SV-14129A2) - For a fire in Fire Zone 1-4G closure of the MSIV Inboard Isolation Valve (HV-1F022A) has been assured in the event that isolation of the MSL is
 
required.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-17
- Main Steam Line Outboard Isolation Valve HV-1F028B Pilot Solenoid Valves (SV-14129B1, SV-14129B2) - For a fire in Fire Zone 1-4G closure of the MSIV Inboard Isolation Valve (HV-1F022B) has been assured in the event that isolation of the MSL is
 
required.
- Main Steam Line Outboard Isolation Valve HV-1F028C Pilot Solenoid Valves (SV-14129C1, SV-14129C2) - For a fire in Fire Zone 1-4G closure of the MSIV Inboard Isolation Valve (HV-1F022C) has been assured in the event that isolation of the MSL is
 
required.
- Main Steam Line Outboard Isolation Valve HV 1F028D Pilot Solenoid Valves (SV-14129D1 and SV-14129D2) - For a fire in Fire Zone 1-4G closure of the MSIV Inboard Isolation Valve (HV-1F022D) has been assured in the event that isolation of the
 
MSL is required.
- RCIC Pump Injection Shutoff Valve (HV-E51-1F013) - This component is not required in support of post-fire safe shutdown in Fire Area R-1B. A spurious operation of this component along with other RCIC system components has been evaluated in regards to a reactor overfill condition. A fire induced spurious start of the RCIC system in conjunction with the loss of the RCIC high water level trip in Fire Area R-1B can be mitigated by using the protected safe shutdown path for Fire Area R-1B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-4G is addressed in Deviation Requests 3, 6 and 11.
 
6.2.2.5.17  Fire Zone 1-5A-N - General Access Area The following Category I components are located in Fire Zone 1-5A-N:
 
- Reactor Water Clean-up Pressure Switches (PSH-G33-1N014 and PSL-G33-1N013), Demin Dump Valve I/P Converter (HY-G33-1K001) and Demin Dump Solenoid Valve (SV-14433) - For a fire in Fire Zone 1-5A-N closure of the RWCU Inboard Isolation Valve (HV-G33-1F001) has been assured in the event that isolation of the RWCU is
 
required.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-5A-N is addressed in Deviation Requests 3, 4 and
: 11.
 
6.2.2.5.18  Fire Zone 1-5A-W - Access Corridor
 
There are no Category I components located in Fire Zone 1-5A-W.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-5A-W is addressed in Deviation Requests 3, 4, 11
 
and 12.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-18 6.2.2.5.19  Fire Zone 1-5C - Reactor Backwash Receiving Tank Room There are no Category components located in Fire Zone 1-5C.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-5C is addressed in Deviation Request 14.
 
6.2.2.5.20  Fire Zone 1-5D - RWCU Pump Room & Heat Exchanger Cells
 
The following Category I component is located in Fire Zone 1-5D:
- Reactor Water Cleanup Outboard Isolation Valve (HV-G33-1F004) - For a fire in Fire Zone 1-5D closure of the RWCU Inboard Isolation Valve (HV-G33-1F001) has been assured in the event that isolation of the RWCU is required.
 
6.2.2.5.21  Fire Zone 1-6A - General Access Area & Pump Room
 
There are no Category I Components located in Fire Zone 1-6A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6A is addressed in Deviation Request 12. In addition, the fire hazards analysis identified on Drawing E-205954 in Section 8.0 of this document affects the combustible configuration in this fire zone.
 
6.2.2.5.22  Fire Zone 1-6B - Load Center Room There are no Category I components located in Fire Zone 1-6B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6B is addressed in Deviation Request 7.
 
6.2.2.5.23  Fire Zone 1-6C - Electrical Equipment Room
 
The following Category I components are located in Fire Zone 1-6C.
 
High Primary Containment Pressure Switches (PS-E11-1N010A and PS-E11-1N010C -
The capability to manually depressurize the reactor, if required, using the keylock switches in the Unit 1 Upper and Lower Relay Rooms remains available.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6C is addressed in Deviation Request 7.
 
6.2.2.5.24  Fire Zone 1-6D - HVAC Equipment Room
 
There are no Category I components located in Fire Zone 1-6D:
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6D is addressed in Deviation Request 7.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-19 6.2.2.5.25  Fire Zone 1-6F - Spent Fuel Pool There are no Category I components located in Fire Zone 1-6F.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6F is addressed in Deviation Requests 7 and 14.
 
6.2.2.5.26  Fire Zone 1-6I - Fuel Pool Holding Pump Room
 
There are no Category I components located in Fire Zone 1-6I.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-6I is addressed in Deviation Request 13. In addition, the fire hazards analysis identified on Drawing E-205954 in Section 8.0 of this document affects the combustible configuration in this fire zone.
 
6.2.2.5.27  Fire Zone 1-7A - HVAC Equipment Area There are no Category I components located in Fire Zone 1-7A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-7A is addressed in Deviation Request 7.
 
6.2.2.5.28  Fire Zone 0-6G - Surge Tank Vault
 
There are no Category I components located in Fire Zone 0-6G.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-6G is addressed in Deviation Request 7.
 
6.2.2.5.29  Fire Zone 0-6H - Cask Storage Pit There are no Category I components located in Fire Zone 0-6H.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-6H is addressed in Deviation Request 7 and 14.
 
6.2.2.5.30  Fire Zone 0-8A - Refueling Floor There are no Category I components located in Fire Zone 0-8A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-8A is addressed in Deviation Request 7.
6.2.2.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 1-3B-N, 1-4A-N*, 1-4A-W**, 1-4B*, or 1-5A-W* result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-20 and/or 1P401B by manually tripping the Motor-Generator Set supply breaker 1A10110 and/or 1A10210.
* Reactor Recirculation Pump 1P401A can be tripped from the Control Room.
** Reactor Recirculation Pump 1P401B can be tripped from the Control Room.
: 2. Should a fire in Fire Zone 1-2B, 1-2D, 1-3B-N, 1-4A-N or 1-4B result in spurious Unit 1 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 1 Division I ADS and to inject water into the reactor using Unit 1 Division I Core Spray remains available from the Control Room.
: 3. Should a fire in Fire Zone 1-3B-N result in HPCI spuriously starting while disabling the 54" high water level trip, manually take control of HPCI from the Control Room or close the HPCI Turbine Steam Supply Inboard Isolation Valve HV-155-F002.
: 4. Should a fire in Fire Zone 1-4A-W result in loss of Unit 1 scram discharge volume isolation capability, isolate the scram discharge volume by manually venting the instrument air header in the Unit 1 Reactor Building.
: 5. Should a fire in Fire Zone 1-5A-W or 1-6C result in spuriously tripping the RHRSW Pump 1P506B, reset the pump trip logic by operating HS-11202B3 to the RESET position and start the pump from the Control Room.
: 6. Fire Zone 1-4A-W, actions performed during plant start up lifts lead in Motor Control Center 1B236 cubicle 102 which disables Reactor Head Vent Valve HV-141-F001 preventing a reactor coolant flow diversion through spurious opening of both Head Vent Valves. 
: 7. Should a fire in Fire Zone 1-6C or 1-6D result in loss of the ability to operate Unit 1 ADS from the Control Room, operate the ADS valves individually using the key locked switches located in the Unit 1 Upper Relay Room for Division I or the Lower Relay Room
 
for Division II.
: 8. Should a fire in Fire Zone 1-2B or 1-2D result in loss of the ability to operate Unit 1 ADS from the Control Room, operate the Unit 1 Division 1 ADS valves individually using the key locked switches located in the Unit 1 Upper Relay Room.
6.2.2.7  Deviation Requests Affecting Fire Area R-1B:
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-1B.
 
6.2.3  Fire Area R-1C 6.2.3.1  General Description Fire Area R-1C is the Unit 1 Primary Containment. Its location is shown on Drawings E-205949 thru E-205954 in Section 8.0. Primary Containment has an inerted nitrogen environment during normal operation. Based on this inerted environment, the potential for a fire while at full power operation is not possible. Therefore, equipment damage due to fire while operating is not postulated and the ability to achieve and maintain safe shutdown is assured.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-21 6.2.3.2  Fire Zones The following fire zones are located in Fire Area R-1C:
 
Fire Zone Description1-1H  Suppression Chamber 1-4F  Drywell
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-22 6.2.3.3 Combustible Loading The inerted nitrogen atmosphere inside Primary Containment will prevent combustion at power operation.
 
6.2.3.4  Fire Detection/Suppression in the Fire Area Due to the normally inerted nitrogen environment, there is no automatic fire detection or suppression in Primary Containment. Manual hose reels and portable extinguishers are located just outside the containment entrance. During extended outages, additional portable extinguishers are available at the drywell entrance.
 
6.2.3.5  Consequences of a Fire in Fire Area R-1C
 
The inerted nitrogen atmosphere of Primary Containment will prevent combustion at power operation.
6.2.3.6  Special Features
 
Primary Containment has an inerted nitrogen atmosphere. 
 
There are no special features in Fire Area R-1C. There are no manual actions required.
 
6.2.3.7  Deviation Requests Affecting Fire Area R-1C
 
Section 7.0 provides a complete listing of Deviation Requests that affect the fire zones in Fire Area R-1C.
 
6.2.4  Fire Area R-1D
 
6.2.4.1  General Description Fire Area R-1D is the Unit 1 Valve Access Area located in the Unit 1 Reactor Building at Elevation 761'-10". This fire area is a single room. Its location is shown on Drawing E-205953 in Section 8.0. Fire Area R-1D predominately contains Division II equipment, components and cabling. Safe Shutdown Path 1, which is comprised primarily of Division I equipment, components and cabling, with the following system substitutions can be used to achieve safe shutdown in the event of a fire:
 
a) Since both Core Spray Injection Valves for both divisions are located in this fire area, Core Spray is not available for Path 1, and
 
b) In its place, RCIC is used for reactor vessel inventory control and RHR shutdown cooling is used for decay heat removal on Path 1.
 
c) For Unit 2, the non-fire unit for this fire area, Path 3 is available to achieve and maintain safe shutdown.
Deviation Request No. 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown is applicable, in general, to this fire area. In this fire area, ADS and RHR LPCI in the Alternate Shutdown Cooling Mode may be used to achieve and SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-23 maintain post-fire safe shutdown in the event that fire damage occurs that effects RCIC and/or RHR Shutdown Cooling.
 
6.2.4.2  Fire Zones The following fire zone is located in Fire Area R-1D:
Fire Zone Description1-5B  Valve Access Area 6.2.4.3  Combustible Loading The combustible loading in Fire Area R-1D is low and the only combustible material in the room is lube oil from the valves in the room. There are minimal unwrapped cables in this room.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Area R-1D (Fire Zone 1-5B) is addressed in Deviation Requests 3, 6, 11 and 13. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
6.2.4.4  Fire Detection/Suppression in the Fire Area
 
The fire area has heat detectors which alarm in the main control room. There is no automatic suppression in the room, however, portable extinguishers and manual hose reels are located just outside the room. 
 
6.2.4.5  Consequences of a Fire in Fire Area R-1D
 
Electrical cabling located in Fire Area R-1D associated with Unit 1 Path 1 and Unit 2 Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition for a fire in this Fire Area. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.4.5.1  Fire Zone 1-5B - Valve Access Area The following Category I components are located in Fire Zone 1-5B:
 
- Core Spray Outboard Injection Valves (HV-E21-1F004A and HV-E21-1F004B) and Core Spray Inboard Injection Valves (HV-E21-1F005A and HV-E21-1F005B) - The inboard and outboard isolation valves for both divisions of Core Spray are located in Fire Area R-1D. Therefore, Core Spray is not credited for post-fire safe shutdown in Fire Area R-1D.
RCIC is protected to perform the inventory make up function for Fire Area R-1D. RHR Shutdown Cooling is protected for the decay heat removal function in Fire Area R-1D.
- RHR Drywell Spray Outboard Isolation Valve (HV-E11-1F016B) - This valve is normally closed and required to remain closed in support of post-fire safe shutdown on Safe Shutdown Path 3. Safe Shutdown Path 1 is credited for post-fire safe shutdown for SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-24 Unit 1 in Fire Area R-1D. Safe Shutdown Path 3 is credited for post-fire safe shutdown for Unit 2 in Fire Area R-1D. Fire induced damage to this valve has no impact on Safe
 
Shutdown Path 3 for Unit 2.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 1-5B is addressed in Deviation Requests 3, 6, 11 and 13. In addition, the fire hazards analysis identified on Drawing E-205953 in Section 8.0 of this document affects the allowable combustible configuration for this fire zone.
 
6.2.4.6  Special Features
 
There are no special features in Fire Area R-1D. There are no manual actions required.
 
6.2.4.7  Deviation Requests Affecting Fire Area R-1D
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-1D.
6.2.5  Fire Area R-1E
 
6.2.5.1  General Description Fire Area R-1E is the Division II 4.16 KV Switchgear Room on Elevation 719'-1" in the Unit 1 Reactor Building. This fire area consists of a single room. Its location is shown on Drawing E-205952 in Section 8.0. Fire Area R-1E predominately contains Division II equipment, components and cabling. Safe Shutdown Path 1, which is comprised primarily of Division I equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in this fire area. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.5.2  Fire Zones
 
The following fire zone is located in Fire Area R-1E:
Fire Zone Description1-4C  4.16 KV Switchgear Room Div II 6.2.5.3  Combustible Loading
 
The combustible loading in Fire Area R-1E is well below the fire barrier rating of the fire area boundary. The prime contributor to the combustible loading in this fire area is cables in cable tray. Switchgear panels, motor control centers and load centers also contribute to the overall combustible loading. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.5.4  Fire Detection/Suppression in the Fire Area Fire Area R-1E is equipped with ionization smoke detectors which alarm in the main control room. The fire area does not have an automatic suppression system due to the nature of the SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-25 electrical equipment in the room. However, manual hose reels and portable fire extinguishers are located nearby.
 
6.2.5.5  Consequences of a Fire in Fire Area R-1E In the event of a fire in Fire Area R-1E, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-1E associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.5.5.1  Fire Zone 1-4C - 4.16 KV Switchgear Room Div II
 
There are no Category I components located in Fire Zone 1-4C.
6.2.5.6  Special Features
 
There are no special features in Fire Area R-1E. There is no manual actions required.
 
6.2.5.7  Deviation Requests Affecting Fire Area R-1E Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-1E.
 
6.2.6  Fire Area R-1F
 
6.2.6.1  General Description
 
Fire Area R-1F is the Division I 4.16 KV Switchgear Room at Elevation 719'-1" in the Unit 1 Reactor Building. This fire area consists of a single room. Its location is shown on Drawing E-205952 in Section  8.0. Fire Area R-1F predominately contains Division I equipment, components and cabling. Safe Shutdown Path 3, which is comprised primarily of Division II equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in this area. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.6.2  Fire Zones The following fire zone is located in Fire Area R-1F:
 
Fire Zone Description1-4D  4.16 KV Switchgear Room Div I
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-26 6.2.6.3  Combustible Loading The combustible loading in Fire Area R-1F is well below the fire barrier rating of the fire area boundary. The prime contributor to the combustible loading in this fire area is cables in cable tray. Switchgear panels, motor control centers and load centers also contribute to the overall combustible loading. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible
 
restrictions.
 
6.2.6.4  Fire Detection/Suppression in the Fire Area Fire Area R-1F is equipped with ionization smoke detectors which alarm in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, manual hose reels and portable fire extinguishers are located nearby.
6.2.6.5  Consequences of a Fire in Fire Area R-1F
 
In the event of a fire in Fire Area R-1F, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-1F associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished by one of the methods described in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
6.2.6.5.1  Fire Zone 1-4D - 4.16 KV Switchgear Room Div I
 
There are no Category I components located in Fire Zone 1-4D.
 
6.2.6.6  Special Features
 
There are no special features in Fire Area R-1F. There are no manual actions required.
 
6.2.6.7  Deviation Requests Affecting Fire Area R-1F Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-1F.
 
6.2.7  Fire Area R-1G
 
6.2.7.1  General Description Fire Area R-1G is the Division II 4.16 KV Switchgear Room at Elevation 749'-1" in the Unit 1 Reactor Building. This fire area consists of a single room. Its location is shown on Drawing E-205953 in Section 8.0. Fire Area R-1G predominately contains Division II equipment, components and cabling. Safe Shutdown Path 1, which is comprised primarily of Division I equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in this fire area. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-27 6.2.7.2  Fire Zones The following fire zone is located in Fire Area R-1G:
 
Fire Zone Description1-5F  4.16 KV Switchgear Room Div II 6.2.7.3  Combustible Loading
 
The combustible loading in Fire Area R-1G is well below the fire barrier rating of the fire area boundary. The principle contributor to the combustible loading in this fire area is cables in cable tray. Switchgear panels, motor control centers and load centers also contribute to the overall combustible loading. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible
 
restrictions.
6.2.7.4  Fire Detection/Suppression in the Fire Area
 
Fire Area R-1G is equipped with ionization smoke detectors which alarm in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, manual hose reels and portable fire extinguishers are located nearby.
 
6.2.7.5  Consequences of a Fire in Fire Area R-1G In the event of a fire in Fire Area R-1G, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-1G associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.7.5.1  Fire Zone 1-5F - 4.16 KV Switchgear Room Div II
 
There are no Category I components located in Fire Zone 1-5F.
6.2.7.6  Special Features
 
The following manual action may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 1-5F result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping the Motor-Generator Set supply breaker 1A10110 and/or 1A10210.
 
6.2.7.7  Deviation Requests Affecting Fire Area R-1G
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-1G.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-28 6.2.8  Fire Area R-1H 6.2.8.1  General Description
 
Fire Area R-1H is the Division  I 4.16 KV Switchgear Room at Elevation 749'-1" in the Unit 1 Reactor Building. This fire area consists of a single room. Its location is shown on Drawing E-205953 in Section 8.0. Fire Area R-1H predominately contains Division I equipment, components and cabling. Safe Shutdown Path 3, which is comprised primarily of Division II equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in this fire area. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.8.2  Fire Zones
 
The following fire zone is located in Fire Area R-1H:
 
Fire Zone Description1-5G  4.16 KV Switchgear Room Div I 6.2.8.3  Combustible Loading The combustible loading in Fire Area R-1H is well below the fire barrier rating of the fire area boundary. The principle contributor to the combustible loading in this fire area is cables in cable tray. Switchgear panels, motor control centers and load centers also contribute to the overall combustible loading. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.8.4  Fire Detection/Suppression in the Fire Area
 
Fire Area R-1H is equipped with ionization smoke detectors which alarm in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, manual hose reels and portable fire extinguishers are located nearby.
 
6.2.8.5  Consequences of a Fire in Fire Area R-1H
 
In the event of a fire in Fire Area R-1H, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-1H associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.8.5.1  Fire Zone 1-5G - 4.16 KV Switchgear Room Div I There are no Category I components located in Fire Zone 1-5G.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-29 6.2.8.6  Special Features The following manual action may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 1-5G** result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping
 
the Motor-Generator Set supply breaker 1A10110 and/or 1A10210.
 
** Reactor Recirculation Pump 1P401B can be tripped from the Control Room.
6.2.8.7  Deviation Requests Affecting Fire Area R-1H
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-1H.
 
6.2.9  Fire Area R-2A
 
6.2.9.1  General Description
 
Fire Area R-2A is located in the Unit 2 Reactor Building and is comprised of fire zones which generally occupy the southern half of the building. This fire area is shown on Drawings E-205957 thru E-205964, E-205967 and E-213485 in Section 8.0. Fire Area R-2A predominately contains Division I equipment, components and cabling. Safe Shutdown Path 3, which is comprised primarily of Division II equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in Fire Area R-2A. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.9.2  Fire Zones
 
The following fire zones are located in Fire Area R-2A:
 
Fire Zone Description2-1B  Core Spray "A" Pump Room 2-1F  RHR "A" Pump Room 2-1G  Sump Room 2-1I #  Elevator Shaft & Stairwell No. 202 2-2A  Remote Shutdown Panel Room 2-2C  Vehicle Airlock 2-3A  Heat Exchanger Pump Room 2-3B-S  Equipment Removal Area 2-3B-W * #  Equipment Removal Area 2-3C-S  Equipment Access Area 2-3C-W * #  Equipment Access Area 2-4A-S  Containment Access Area 2-4A-W * #  Containment Access Area 2-4E  CRD Rebuild Room 2-4G  Main Steam Pipeway 2-5A-S  General Access Area 2-5A-W * #  Access Corridor SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-30 2-5C  Reactor Backwash Receiving Tank Room 2-5D #  RWCU Pump Room & Heat Exchanger Cells 2-5E  Pipe Penetration Room 2-5H #  I&C Instrument Repair Shop 2-6B ** #  Load Center Room 2-6D ** #  HVAC Equipment Room 2-6E ** #  HVAC Plenum Area 2-6F ** #  Spent Fuel Pool 2-7A ** #  HVAC Equipment Area 0-8A ** #  Refueling Floor
* This fire zone is a wraparound area (see Deviation Request No. 4)
** This fire zone is a buffer zone (see Deviation Request No. 7)
# This fire zone is analyzed as part of a pseudo fire area since protection of both Paths 1 and 3 is required in this zone. Fire Zone 2-1J that is also analyzed as a part of this pseudo-fire area is included in Fire Area R-2B.
 
6.2.9.3  Combustible Loading
 
The combustible loading for each fire zone within this fire area has been compiled and has been used for specific fire hazards analysis within this fire area. Specific combustible configurations in the fire area may also have been reviewed for their fire hazard severity and for their impact on fire barrier integrity. The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area R-2A are addressed in Deviation Requests 3, 4, 6, 7, 11, 12, 13, 14, 24, 29, 38 and 42 as well as by several fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the Drawings contained in Section 8.0 of this document. Any restrictions for a fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone. 6.2.9.4  Fire Detection/Suppression in the Fire Area
 
Automatic fire detection is provided throughout Fire Area R-2A except in the following fire zones:  Fire Zone  Description 2-2C  Vehicle Airlock 2-4E  CRD Rebuild Room 2-6F  Spent Fuel Pool The justification for lack of detection in these fire zones is presented in Deviation Request
 
No. 14.
Automatic fire suppression systems have been installed in local areas where fire hazards have the most severe potential. These systems are designed to control and suppress any fire which could develop in the fire zones which they protect.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-31 Fire suppression has been provided in the following fire zones:
Fire Zone  Description 2-2C  Vehicle Airlock 2-3B-S  Equipment Removal Area 2-3B-W  Equipment Removal Area 2-4A-S  Containment Access Area  (Partial) 2-4A-W  Containment Access Area 2-5A-W  Access Corridor 2-5A-S  General Access Area  (Partial)
Automatic deluge systems are provided for the following equipment listed by fire zones:
 
Fire Zone  Description 2-1C  HPCI Pump 2-1D  HPCI Pump Manual deluge systems are provided for charcoal filters 2F217A, 2F217B, 2F257A, and 2F257B in Fire Zone 2-7A.
 
6.2.9.5  Consequences of a Fire in Fire Area R-2A
 
In the event of a design basis fire in Fire Area R-2A, Safe Shutdown Path 3 systems will be available for safe shutdown. Electrical cabling located in Fire Area R-2A associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished using one of the methods outlined in Section 6.1.2.4. 
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.9.5.1  Fire Zone 2-1B - Core Spray "A" Pump Room
 
The following Category I components are located in Fire Zone 2-1B:
 
- Suppression Pool Filter Pump Suction Valve (HV-25766) - Fire induced spurious opening of this normally closed valve in conjunction with a fire induced spurious opening of normally closed valve HV-25768 could result in a flow diversion from the Suppression Pool. Fire induced spurious opening of HV-25768 is prevented for a fire in Fire Area R-2A.  - Suppression Pool Filter Pump Suction Valve (HV-25768) - Fire induced spurious opening of this normally closed valve in conjunction with a fire induced spurious opening of normally closed valve HV-25766 could result in a flow diversion from the Suppression Pool. A fire induced hot short on the circuits for HV-25768 in Fire Zone 2-1B cannot cause a spurious opening of this valve. Any circuits with the potential to cause a spurious opening of HV-25768 in Fire Area R-2A are protected with fire rated barrier.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-1B is addressed in Deviation Request 3.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-32 6.2.9.5.2  Fire Zone 2-1F - RHR "A" Pump Room There are no Category I components located in Fire Zone 2-1F.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-1F is addressed in Deviation Requests 3 and 6.
 
6.2.9.5.3  Fire Zone 2-1G - Sump Room
 
There are no Category I components located in Fire Zone 2-1G.
6.2.9.5.4  Fire Zone 2-1I - Elevator Shaft & Stairwell No. 202
 
There are no Category I components located in Fire Zone 2-1I.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-1I is addressed in Deviation Request 3.
 
6.2.9.5.5  Fire Zone 2-2A - Remote Shutdown Panel Room
 
There are no Category I components located in Fire Zone 2-2A.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-2A is addressed in Deviation Request 3. In addition, the fire hazards analysis identified on Drawing E-205959 in Section 8.0 of this document affects the combustible configuration in this fire zone.
6.2.9.5.6  Fire Zone 2-2C - Vehicle Airlock
 
There are no Category I components contained in Fire Zone 2-2C.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-2C is addressed in Deviation Request 14.
 
6.2.9.5.7  Fire Zone 2-3A - Heat Exchanger Pump Room
 
There are no Category I components located in Fire Zone 2-3A.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3A is addressed in Deviation Request 3. In addition, the fire hazards analysis identified on Drawing E-205959 in Section 8.0 of this document affects the combustible configuration in this fire zone.
 
6.2.9.5.8  Fire Zone 2-3B-S - Equipment Removal Area There are no Category I components located in Fire Zone 2-3B-S.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3B-S is addressed in Deviation Request 4.
 
6.2.9.5.9  Fire Zone 2-3B-W - Equipment Removal Area SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-33 There are no Category I components located in Fire Zone 2-3B-W.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3B-W is addressed in Deviation Requests 4, 6 and 42. In addition, the fire hazards analysis identified on Drawing E-205959 in Section 8.0 of this document affects the allowable combustible configuration for this fire zone.
 
Deviation Request 42 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.9.5.10  Fire Zone 2-3C-S - Equipment Access Area
 
There are no Category I components located in Fire Zone 2-3C-S.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3C-S is addressed in Deviation Request 4. In addition, the fire hazards analysis identified on Drawing E-205959 in Section 8.0 of this document affects the combustible configuration in this fire zone.
 
6.2.9.5.11  Fire Zone 2-3C-W - Equipment Access Area
 
The following Category I components are located in Fire Zone 2-3C-W:
 
- RHR Shutdown Cooling Outboard Isolation Valve (HV-E11-2F008) - Addressed by Deviation Request No. 29.
- RHR Injection Inboard Isolation Valves (HV- E11-2F015A and HV-E11-2F015B) - Addressed by Deviation Request No. 29.
- RHR Heat Exchanger Bypass Valves (HV-E11-2F048A and HV-E11-2F048B) - Addressed by Deviation Request No. 29.
- RHR Heat Exchanger Outlet Temperature Elements (TE-E11-2N027A and TE-E11-2N027B) - Addressed by Deviation Request No. 29.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3C-W is addressed in Deviation Requests 4 and 29.
 
Deviation Request 29 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.9.5.12  Fire Zone 2-4A-S - Containment Access Area
 
The following Category I components are located in Fire Zone 2-4A-S:
 
- CRD Hydraulic Control Units (2C0219, 2C0223,  2C0227, 2C0231, 2C0235, 2C0239, 2C0243, 2C0615, 2C0619, 2C0623, 2C0627,  2C0631, 2C0635, 2C0639, 2C0643, 2C0647, 2C1011, 2C1015,  2C1019, 2C1023, 2C1027, 2C1031, 2C1035, 2C1039, 2C1043, 2C1047, 2C1051, 2C1407, 2C1411, 2C1415, 2C1419, 2C1423, SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-34  2C1427, 2C1431, 2C1435, 2C1439 2C1443, 2C1447, 2C1451,  2C1455, 2C1803, 2C1807, 2C1811, 2C1815, 2C1819, 2C1823, 2C1827, 2C1831, 2C1835, 2C1839 2C1843, 2C1847, 2C1851, 2C1855, 2C1859, 2C2203, 2C2207, 2C2211, 2C2215, 2C2219, 2C2223, 2C2227, 2C2231, 2C2235, 2C2239, 2C2243, 2C2247,  2C2251, 2C2255, 2C2259, 2C2603, 2C2607, 2C2611, 2C2615,  2C2619, 2C2623, 2C2627, 2C2631, 2C2635, 2C2639, 2C2643, 2C2647, 2C2651, 2C2655, 2C2659, 2C3007, 2C3015, 2C3023, 2C3031, 2C3039, 2C3047, 2C3055)   
                - Fire damage to this component could affect the scram capability and the ability to isolate the scram discharge volume. An analysis has determined that damage to the HCU will not prevent scram. If required, the plant operator will isolate the scram discharge volume by manually venting the instrument air header.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-4A-S is addressed in Deviation Requests 3, 4, 6, 11, 12 and 13.
 
6.2.9.5.13  Fire Zone 2-4A-W - Containment Access Area The following Category I components are located in Fire Zone 2-4A-W:
 
- SCRAM Discharge Volume Vent and Drain Pilot Solenoid Valves (SV-C-2F009A and SV-C12-2F009B) - Fire induced damage to this component can affect the ability of the plant operator to isolate the scram discharge volume from the Control Room. The plant operator can isolate the scram discharge volume by manually venting the instrument air
 
header.  - Back-up SCRAM Valves (SV-C12-2F110A and SV-C12-2F110B) - An analysis has demonstrated that fire induced damage to these valves will not affect the ability to manually scram the reactor. The plant operator can isolate the scram discharge volume
 
by manually venting the instrument air header.
- ARI Vent and Block Valves (SV-24799, SV-247100, SV-247101 and SV-247102) - An analysis has demonstrated that fire induced damage to these valves will not affect the ability to manually scram the reactor and isolate the scram discharge volume.
- Appendix R Communication System Jackplate JP2102 - This component is not required for post-fire safe shutdown in this Fire Area. This component is a jackplate for Loop 1 of the Appendix R sound powered communications system. There are no operator actions resulting from a fire in this Fire Area that require the use of this loop of the sound powered communications system.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-4A-W is addressed in Deviation Requests 4 and 6.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-35 6.2.9.5.14  Fire Zone 2-4E - CRD Rebuild Room There are no Category I components located in Fire Zone 2-4E.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-4E is addressed in Deviation Request 14.
 
6.2.9.5.15  Fire Zone 2-4G - Main Steam Pipeway
 
The following Category I component is located in Fire Zone 2-4G:
- Main Steam Line Outboard Drain Isolation Valve (HV-B21-2F019) - Fire induced damage to the Main Steam Inboard and Outboard Drain Isolation Valves can result in a flow diversion from the reactor coolant system when Alternate Shutdown Cooling is being used. If required, the plant operator can manually close HV-B21-2F019.
- Main Steam Line Outboard Isolation Valve HV-241-F028A, HV-241-F028B, HV-241-F028C and HV-241-F028D Pilot Solenoid Valves (SV-24129A1, SV-24129A2, SV-24129B1, SV-24129B2, SV-24129C1, SV-24129C2, SV-24129D1 and SV-24129D2) -
Addressed by Deviation Request 38.
- HPCI Pump Discharge Valve (HV-E41-2F006) - This component is not required in support of post-fire safe shutdown in Fire Area R-2A. A spurious operation of this component along with other HPCI System components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the HPCI System is not possible in this fire area.
- RCIC Pump Injection Shutoff Valve (HV-E51-2F013) - This component is not required in support of post-fire safe shutdown in Fire Area R-2A. A spurious operation of this component along with other RCIC System components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the RCIC System in conjunction with the loss of the RCIC high water level trip in Fire Area R-2A can be mitigated by the protected safe shutdown path for Fire Area R-2A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-4G is addressed in Deviation Requests 3, 6, 11 and
: 38. 6.2.9.5.16  Fire Zone 2-5A-S - General Access Area
 
The following Category I components are located in Fire Zone 2-5A-S:
 
- RWCU Demin Dump Valve I/P Converter (HY-G33-2K001); RWCU Pressure Switches (PSH-G33-2N014, PSL-G33-2N013) and RWCU Demin Dump Solenoid Valve (SV-24433) - For a fire in Fire Zone 2-5A-S closure of the RWCU Outboard Isolation Valve (HV-G33-2F004) has been assured in the event that isolation of the RWCU is required.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-5A-S is addressed in Deviation Requests 3, 4, 6 and
: 11.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-36 6.2.9.5.17  Fire Zone 2-5A-W - Access Corridor There are no Category I components located in Fire Zone 2-5A-W.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-5A-W is addressed in Deviation Requests 3, 4, 11 and 12.
 
6.2.9.5.18  Fire Zone 2-5C - Reactor Backwash Receiving Tank Room There are no Category I components located in Fire Zone 2-5C.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-5C is addressed in Deviation Requests 6 and 13. In addition, the fire hazards analysis identified on Drawing E-205961 in Section 8.0 of this document affects the combustible configuration in this fire zone.
6.2.9.5.19  Fire Zone 2-5D - RWCU Pump Room & Heat Exchanger Cells
 
The following Category I component is located in Fire Zone 2-5D:
 
- RWCU Outboard Isolation Valve (HV-G33-2F004) - Addressed by Deviation Request No. 24.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-5D is addressed in Deviation Request 24.
6.2.9.5.20  Fire Zone 2-5E - Pipe Penetration Room
 
There are no Category I components located in Fire Zone 2-5E.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-5E is addressed in Deviation Requests 3 and 11.
 
6.2.9.5.21  Fire Zone 2-5H - I&C Instrument Repair Shop
 
There are no Category I components located in Fire Zone 2-5H.
6.2.9.5.22  Fire Zone 2-6B - Load Center Room
 
There are no Category I components located in Fire Zone 2-6B. 
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6B is addressed in Deviation Request 7.
 
6.2.9.5.23  Fire Zone 2-6D - HVAC Equipment Room
 
There are no Category I components located in Fire Zone 2-6D:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-37 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6D is addressed in Deviation Request 7.
 
6.2.9.5.24  Fire Zone 2-6E - HVAC Plenum Area There are no Category I components located in Fire Zone 2-6E.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6E is addressed in Deviation Request 7.
 
6.2.9.5.25  Fire Zone 2-6F - Spent Fuel Pool There are no Category I components located in Fire Zone 2-6F. 
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6F is addressed in Deviation Request 7 and 14.
6.2.9.5.26  Fire Zone 2-7A - HVAC Equipment Area
 
There are no Category I components located in Fire Zone 2-7A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-7A is addressed in Deviation Request 7.
 
6.2.9.5.27  Fire Zone 0-8A - Refueling Floor There are no Category I components located in Fire Zone 0-8A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-8A is addressed in Deviation Request 7.
 
6.2.9.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 2-3A, 2-4A-S**, 2-4A-W**, 2-4G***, 2-5A-W**, 2-5A-S***  or 2-5E*** result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator
 
Set supply breaker 2A10110 and/or 2A10210.
* Reactor Recirculation Pump 2P401A can be tripped from the Control Room.
** Reactor Recirculation Pump 2P401B can be tripped from the Control Room. *** Reactor Recirculation Pumps 2P401A and 2P401B can be tripped from the Control Room.
: 2. Should a fire in Fire Zone 2-2A, 2-3A, 2-4A-S or 2-4G result in spurious Unit 2 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 2 Division II ADS and to inject water into the reactor using Unit 2 Division II Core Spray remains available from the Control Room.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-38 3. Should a fire in Fire Zone 2-5A-W or 2-5D result in spuriously tripping the RHRSW Pump 2P506A, reset the pump trip logic by operating HS-21202A3 to the RESET position and start pump 2P506A from the Control Room.
: 4. Fire Zone 2-4A-W, actions performed during plant start up lifts lead in Motor Control Center 2B236 cubicle 102 which disables the Reactor Head Vent Valve HV-241-F001 preventing a reactor coolant flow diversion through spurious opening of both Head Vent
 
Valves. 
: 5. Should a fire in Fire Zone 2-4A-W result in loss of Unit 2 scram discharge volume isolation capability, isolate the scram discharge volume by manually venting the instrument air header in the Unit 2 Reactor Building.
: 6. Should a fire in Fire Zone 2-4G result in a Unit 2 Reactor Coolant System flow diversion when operating in the alternate shutdown cooling mode caused by the MSIV drain valves "Spuriously Opening ", open Unit 2 250 VDC Motor Control Center 2D274 Breaker 041 and manually close MSIV Drain Valve HV-241-F019.
 
6.2.9.7  Deviation Requests Affecting Fire Area R-2A
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-2A.
6.2.10 Fire Area R-2B
 
6.2.10.1  General Description Fire Area R-2B is located in the Unit 2 Reactor Building and is comprised of fire zones which generally occupy the northern half of the building and are shown on Drawings E-205957 thru
 
E-205964 in Section 8.0. Fire Area R-2B predominantly contains Division II equipment, components and cabling. Safe Shutdown Path 1, which is comprised primarily of Division I equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in Fire Area R-2B. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.10.2  Fire Zones
 
The following fire zones are located in Fire Area R-2B:
Fire Zone  Description 2-1 A  Core S p ra y "B" Pum p Room2-1C  HPCI Pum p Room2-1D  RCIC Pum p Room2-1E  RHR "B" Pum p Room2-1J #  Stairwell No. 2012-2B  Personnel Access Corrido r2-3B-N  E q ui pment Removal Area2-3B-W * #  E q ui pment Removal Area2-3C-N  E q ui pment Access Area2-3C-W * #  E q ui pment Access Area 2-4 A-N  Containment Access Area 2-4 A-W * #  Containment Access Area SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-39 Fire Zone  Description 2-4B  Pi p e Penetration Room 2-5 A-N  Standb y Li quid Control Area 2-5 A-W * #  Access Corrido r 2-6 A  General Access Area & Pum p Room2-6B ** #  Load Center Room2-6C  Electrical E q ui p ment Room2-6D ** #  HVAC E q ui pment Room2-6E ** #  HVAC Plenum Area2-6F ** #  S p ent Fuel Pool2-7A ** #  HVAC E q ui p ment Area0-8A ** #  Refuelin g Floo r
* This fire zone is a wraparound area (see Deviation Request No. 4)
** This fire zone is a buffer zone (see Deviation Request No. 7)
# This fire zone is analyzed as part of a pseudo fire area since protection of both Paths 1 and 3 is required in this zone. Fire Zone 2-1I, 2-5D and 2-5H that are also analyzed as a part of this pseudo-fire area are included in Fire Area R-2A.
6.2.10.3  Combustible Loading The combustible loading for each fire zone within this fire area has been compiled and has been used for specific fire hazards analysis within this fire area. Specific combustible configurations in the fire area may also have been reviewed for their fire hazard severity and for their impact on fire barrier in integrity. The fire rating of the fire area is established based on the lowest fire
 
rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and f3, 4, 6, 7, 11, 12, 13, 14, 26, 28, 29 and 42 as well as by several fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analyses have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.10.4  Fire Detection/Suppression in the Fire Area
 
Automatic fire detection is provided throughout Fire Area R-2B except in the following fire zones:  Fire Zone  Description 2-1J  Stairwell No. 201 2-6F  Spent Fuel Pool The justification for lack of detection in these fire zones is presented in Deviation Request
 
No. 14. Automatic fire suppression systems have been installed in local areas based upon fire hazards.
These systems are designed to control and suppress any fire which could develop in the fire zones which they protect. Fire suppression has been provided in the following fire zones:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-40 Fire Zone  Description 2-3B-N  Equipment Removal Area  (Partial) 2-3B-W  Equipment Removal Area 2-4A-N  Containment Access Area 2-4A-W  Containment Access Area 2-5A-N  Standby Liquid Control Area 2-5A-W  Access Corridor Automatic deluge systems are provided for the equipment listed by fire zone below:
Fire Zone  Description 2-1C  HPCI Pump 2-1D  HPCI Pump 6.2.10.5  Consequences of a Fire in Fire Area R-2B In the event of a design basis fire in Fire Area R-2B, Safe Shutdown Path 1 systems will be available for safe shutdown. Electrical cabling located in Fire Area R-2B associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This has been accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.10.5.1  Fire Zone 2-1A - Core Spray "B" Pump Room There are no Category I components located in Fire Zone 2-1A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-1A is addressed in Deviation Requests 3 and 6.
 
6.2.10.5.2  Fire Zone 2-1C - HPCI Pump Room
 
The following Category I components are located in Fire Zone 2-1C:
 
- HPCI Turbine Auxiliary Oil Pump (2P213) - This component is not required in support of post-fire safe shutdown in Fire Area R-2B. A spurious operation of this component along with other HPCI system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the HPCI system in conjunction with the loss of the HPCI high water level trip in Fire Area R-2B can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-2F002).
- HPCI Steam Supply to Turbine Valve (HV-E41-2F001) - This component is not required in support of post-fire safe shutdown in Fire Area R-2B. A spurious operation of this component along with other HPCI system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the HPCI system in conjunction with the loss of the HPCI high water level trip in Fire Area R-2B can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-2F002).
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2 HPCI Turbine Trip Solenoid Valve (SV-25661) - This component is not required in support of post-fire safe shutdown in Fire Area R-2B. A spurious operation of HPCI system components has been evaluated in regards to a reactor vessel overfill condition.
A fire induced spurious start of the HPCI system in conjunction with the loss of the HPCI high water level trip in Fire Area R-2B can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-2F002).
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-1C is addressed in Deviation Request 6.
 
6.2.10.5.3  Fire Zone 2-1 D - RCIC Pump Room The following Category I components are located in Fire Zone 2-1D:
 
- RCIC Turbine Stop Valve (HV-25012) - This component is not required in support of post-fire safe shutdown in Fire Area R-2B. A spurious operation of this component along with other RCIC system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the RCIC system in conjunction with the loss of the RCIC high water level trip in Fire Area R-2B can be mitigated by using the protected safe shutdown path for Fire Area R-2B.
- RCIC Steam Supply Line Valve (HV-E51-2F045) - This component is not required in support of post-fire safe shutdown in Fire Area R-2B. A spurious operation of this component along with other RCIC system components has been evaluated in regards to a reactor vessel overfill condition. A fire induced spurious start of the RCIC system in conjunction with the loss of the RCIC high water level trip in Fire Area R-2B can be mitigated by using the protected safe shutdown path for Fire Area R-2B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-1D is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205957 and E205958 in Section 8.0 of this document affects the combustible configuration in this fire zone.
6.2.10.5.4  Fire Zone 2-1E - RHR "B" Pump Room
 
The following Category I components are located in Fire Zone 2-1E:
 
- RHR Pump B Shutdown Cooling Suction Valve (HV-E11-2F006B) - This valve must remain closed when RHR is running in the Shutdown Cooling Mode. RHR Shutdown Cooling is not a credited safe shutdown system in Fire Area R-2B.
- RHR Pump D Shutdown Cooling Suction Valve (HV-E11-2F006D) - This valve must remain closed when RHR is running in the Shutdown Cooling Mode. RHR Shutdown Cooling is not a credited safe shutdown system in Fire Area R-2B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-1E is addressed in Deviation Requests 3 and 6.
 
6.2.10.5.5  Fire Zone 2-1J - Stairwell No. 201 There are no Category I components located in Fire Zone 2-1J.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-42 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-1J is addressed in Deviation Request 14.
 
6.2.10.5.6  Fire Zone 2-2B - Personnel Access Corridor
 
There are no Category I components located in Fire Zone 2-2B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-2B is addressed in Deviation Request 3. In addition, the fire hazards analysis identified on Drawing E205958 in Section 8.0 of this document affects the combustible configuration in this fire zone.
 
6.2.10.5.7  Fire Zone 2-3B-N - Equipment Removal Area
 
The following Category I components are located in Fire Zone 2-3B-N:
- Reactor Low Pressure Permissive Switch for RHR System (PIS-B31-2N018A) - Addressed by Deviation Request No. 26.
- Core Spray System Loop A Flow Transmitter (FT-E21-2N003A) and Core Spray Minimum Flow Switch (FIS-E21-2N006A) - Addressed by Deviation Request No. 26.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3B-N is addressed in Deviations Requests 3, 4, 6,13 and 26. In addition, the fire hazards analysis identified on Drawing E-205959 in Section 8.0 of this document affects the combustible configuration in this fire zone.
 
Deviation Request 26 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.10.5.8  Fire Zone 2-3B-W - Equipment Removal Area
 
There are no Category I components located in Fire Zone 2-3B-W.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3B-W is addressed in Deviation Requests 4, 6 and 42. In addition, the fire hazards analysis identified on Drawing E-205959 in Section 8.0 of this document affects the allowable combustible configuration for this fire zone.
 
Deviation Request 42 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
: 6. 2.10.5.9    Fire Zone 2-3C-N - Equipment Access Area There are no Category I components located in Fire Zone 2-3C-N.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3C-N is addressed in Deviation Request 4.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-43 6.2.10.5.10  Fire Zone 2-3C-W - Equipment Access Area The following Category I components are located in Fire Zone 2-3C-W:
 
- RHR Injection Inboard Isolation Valves (HV-E11-2F015A and HV-E11-2F015B) - Addressed by Deviation Request No. 29.
- RHR Shutdown Cooling Outboard Isolation Valve (HV-E11-2F008) - Addressed by Deviation Request No. 29.
- RHR Heat Exchanger Outlet Temperature Elements (TE-E11-2N027A and TE-E11-2N027B) - Addressed by Deviation Request No. 29.
- RHR Heat Exchanger Bypass Valves (HV-E11-2F048A and HV-E11-2F048B) - Addressed by Deviation Request No. 29.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-3C-W is addressed in Deviation Requests 4 and 29.
 
Deviation Request 29 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.10.5.11  Fire Zone 2-4A-N - Containment Access Area
 
The following Category I components are located in Fire Zone 2-4A-N:
 
- CRD Hydraulic Control Units (2C3003, 2C3011, 2C3019, 2C3027, 2C3035,  2C3043, 2C3051, 2C3059, 2C3403, 2C3407, 2C3411, 2C3415, 2C3419, 2C3423, 2C3427, 2C3431, 2C3435, 2C3439, 2C3443, 2C3447, 2C3451, 2C3455, 2C3459, 2C3803, 2C3807, 2C3811, 2C3815, 2C3819, 2C3823, 2C3827, 2C3831, 2C3835, 2C3839, 2C3843, 2C3847, 2C3851, 2C3855, 2C3859, 2C4203, 2C4207, 2C4211, 2C4215, 2C4219, 2C4223, 2C4227,  2C4231, 2C4235, 2C4239, 2C4243, 2C4247, 2C4251, 2C4255, 2C4259,  2C4607, 2C4611, 2C4615, 2C4619, 2C4623, 2C4627, 2C4631, 2C4635, 2C4639, 2C4643, 2C4647, 2C4651, 2C4655, 2C5011, 2C5015, 2C5019, 2C5023, 2C5027, 2C5031, 2C5035, 2C5039, 2C5043, 2C5047, 2C5051, 2C5415, 2C5419, 2C5423, 2C5427, 2C5431, 2C5435, 2C5439, 2C5443,  2C5447, 2C5819, 2C5823, 2C5827, 2C5831, 2C5835, 2C5839, 2C5843)         
- Fire damage to this component could affect the scram capability and the ability to isolate the scram discharge volume. An analysis has determined that damage to this HCU will not prevent scram. If required, the plant operator will isolate the scram discharge volume by manually venting the instrument air header.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-4A-N is addressed in Deviation Requests 4 and 6.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-44 6.2.10.5.12  Fire Zone 2-4A-W - Containment Access Area The following Category I components are located in Fire Zone 2-4A-W:
 
- SCRAM Discharge Volume Vent and Drain Pilot Solenoid Valves (SV-C12-2F009A and SV-C12-2F009B) - Fire induced damage to this component can affect the ability of the plant operator to isolate the scram discharge volume from the Control Room. The plant operator can isolate the scram discharge volume by manually venting the instrument air
 
header.  - Back-up SCRAM Valves (SV-C12-2F110A and SV-C12-2F110B) - An analysis has demonstrated that fire induced damage to these valves will not affect the ability to manually scram the reactor. The plant operator can isolate the scram discharge volume
 
by manually venting the instrument air header.
- ARI Vent and Block Valves (SV-24799, SV-247100, SV-247101 and SV-247102) - An analysis has demonstrated that fire induced damage to these valves will not affect the ability to manually scram the reactor and isolate the scram discharge volume.
- Appendix R Communication System Jackplate JP2102 - This component is not required for post-fire safe shutdown in this Fire Area. This component is a jackplate for Loop 1 of the Appendix R sound powered communications system. There are no operator actions resulting from a fire in this Fire Area that require the use of this loop of the sound
 
powered communications system.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-4A-W is addressed in Deviation Requests 4 and 6.
 
6.2.10.5.13  Fire Zone 2-4B - Pipe Penetration Room
 
There are no Category I components located in Fire Zone 2-4B.
 
6.2.10.5.14  Fire Zone 2-5A-N - Standby Liquid Control Area The following Category I components are located in Fire Zone 2-5A-N:
 
- Reactor Vessel Level Indicating Switch (LIS-B21-2N042A) - Addressed by Deviation Request No. 28.
- 120V AC Power Distribution Panel (2Y201A) - Fire induced damage to this RPS Electrical Distribution Panel can result in tripping of the Unit 2 Division I RHRSW Pump (2P506A). If required, the plant operator can reset the trip from the Control Room and start the pump.
- Nuclear Boiler Instrumentation (Reactor Vessel Level Switches- LIS-B21-2N024A, LIS-B21-2N024B; Reactor Vessel Level Switches - LIS-B21-2N031A, LIS-B21-2N031C;
 
Reactor Pressure Switches - PIS-B21-2N021A, PS-B21-2N023A, PS-B21-2N023B; Wide Range Level Transmitter - LT-24201A and Wide Range Pressure Transmitter - PT-24201A) - Addressed by Deviation Request No. 28.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2 Reactor Vessel High Pressure Switches (PS-B21-2N022A-H, J-N, P, R, S) - Fire damage to this component can result in spurious opening of an SRV. The capability to further depressurize the reactor, as required, and inject with Core Spray in the event of spurious SRV opening is provided for the plant operator.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-5A-N is addressed in Deviation Requests 4, 6, 11, 13 and 28. In addition, the fire hazards analysis identified on Drawing E-205961 in Section 8.0 of this document affects the combustible configuration in this fire zone.
 
Deviation Request 28 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.10.5.15  Fire Zone 2-5A-W - Access Corridor
 
There are no Category I components located in Fire Zone 2-5A-W.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-5A-W is addressed in Deviation Requests 3, 4, 11
 
and 12.
6.2.10.5.16  Fire Zone 2-6A - General Access Area & Pump Room There are no Category I components located in Fire Zone 2-6A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6A is addressed in Deviation Requests 3, 6 and 13. In addition, the fire hazards analysis identified on Drawing E-205962 in Section 8.0 of this document affects the combustible configuration in this fire zone.
 
6.2.10.5.17  Fire Zone 2-6B - Load Center Room There are no Category I components located in Fire Zone 2-6B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6B is addressed in Deviation Request 7.
 
6.2.10.5.18  Fire Zone 2-6C - Electrical Equipment Room The following Category I components are located in Fire Zone 2-6C.
 
- High Primary Containment Pressure Switches (PS-E11-2N010A and PS-E11-2N010C) - The capability to manually depressurize the reactor, if required, using keylock switches in the Unit 2 Upper Relay Room remains available.
 
6.2.10.5.19  Fire Zone 2-6D - HVAC Equipment Room
 
There are no Category I components located in Fire Zone 2-6D:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-46 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6D is addressed in Deviation Request 7.
 
6.2.10.5.20  Fire Zone 2-6E - HVAC Plenum Area There are no Category I components located in Fire Zone 2-6E.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6E is addressed in Deviation Request 7.
 
6.2.10.5.21  Fire Zone 2-6F - Spent Fuel Pool There are no Category I components located in Fire Zone 2-6F.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-6F is addressed in Deviation Requests 7 and 14.
6.2.10.5.22  Fire Zone 2-7A - HVAC Equipment Area
 
There are no Category I components located in Fire Zone 2-7A.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 2-7A is addressed in Deviation Request 7.
 
6.2.10.5.23  Fire Zone 0-8A - Refueling Floor
 
There are no Category I components located in Fire Zone 0-8A.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-8A is addressed in Deviation Request 7.
 
6.2.10.6  Special Features The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 2-5A-N, 2-5A-W or 2-6A result in spuriously tripping the RHRSW Pump 2P506A, reset the pump trip logic by operating HS-21202A3 to the RESET position and start pump 2P506A from the Control Room.
: 2. Should a fire in Fire Zone 2-4A-N, 2-4B or 2-5A-N result in spurious Unit 2 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 2 Division I ADS and to inject water into the reactor using Unit 2 Division I Core Spray remains available from the Control Room.
: 3. Should a fire in Fire Zone, 2-3B-N, 2-4A-N,* 2-4A-W**, 2-4B, 2-5A-N or 2-5A-W** result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator Set supply breaker
 
2A10110 and/or 2A10210.
* Reactor Recirculation Pump 2P401A can be tripped from the Control Room.
** Reactor Recirculation Pump 2P401B can be tripped from the Control Room.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-47
: 4. Should a fire in Fire Zone 2-3B-N result in HPCI spuriously starting while disabling the 54" high water level trip, manually take control of HPCI from the Control Room or close the HPCI Turbine Steam Supply Inboard Isolation Valve HV-255-F002.
: 5. Should a fire in Fire Zone 2-4A-W result in loss of Unit 2 scram discharge volume isolation capability, isolate the scram discharge volume by manually venting the instrument air header in the Unit 2 Reactor Building.
: 6. Fire Zone 2-4A-N, 2-4A-W or 2-5A-N, actions performed during plant start up lifts lead in Motor Control Center 2B236 cubicle 102 which disables the Reactor Head Vent Valve HV-241-F001 preventing a reactor coolant flow diversion through spurious opening of
 
both Head Vent Valves.
: 7. Should a fire in Fire Zone 2-5A-N or 2-6C result in loss of the ability to operate Unit 2 ADS from the Control Room, operate the Unit 2 Division I ADS valves individually using the key locked switches located in the Unit 2 Upper Relay Room.
 
6.2.10.7  Deviation Requests Affecting Fire Area R-2B Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-2B.
 
6.2.11 Fire Area R-2C
 
6.2.11.1  General Description
 
Fire Area R-2C is the Unit 2 Primary Containment. Its location is shown on Drawings E-205957 thru E-205962 in Section  8.0. Primary containment has an inerted nitrogen environment during normal operation. Based on this inerted environment, the potential for a fire while at full power operation is not possible. Therefore, equipment damage due to fire while operating is not postulated and the ability to achieve and maintain safe shutdown is assured.
6.2.11.2  Fire Zones
 
The following fire zones are located in Fire Area R-2C:
 
Fire Zone  Description 2-1H  Suppression Chamber 2-4F  Drywell 6.2.11.3  Combustible Loading
 
The inerted nitrogen atmosphere inside Primary Containment will prevent combustion at power operation.
 
6.2.11.4  Fire Detection/Suppression in the Fire Area
 
Due to the normally inerted nitrogen environment, there is no automatic fire detection or suppression in Primary Containment. Manual hose reels and portable extinguishers are located SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-48 just outside the containment entrance. During extended outages, additional portable extinguishers are available at the drywell entrance.
 
6.2.11.5  Consequences of a Fire in Fire Area R-2C The inerted nitrogen atmosphere of Primary Containment will prevent combustion at power operation.
 
6.2.11.6  Special Features Primary Containment has an inerted nitrogen atmosphere. There are no special features in Fire Area R-2C. There are no manual actions required.
 
6.2.11.7  Deviation Requests Affecting Fire Area R-2C
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-2C.
6.2.12  Fire Area R-2D
 
6.2.12.1  General Description Fire Area R-2D is the Valve Access Area located in the Unit 2 Reactor Building at Elevation 761'-10". This fire area is a single room. Its location is on Drawing E-205961  in Section 8.0. Fire Area R-2D predominately contains Division II equipment, components and cabling. Safe shutdown Path 1, which is comprised primarily of Division I equipment, components and cabling, with the following system substitutions can be used to achieve safe shutdown in the event of a fire:
 
a) Since both Core Spray Injection Valves for both divisions are located in this fire area, Core Spray is not available for Path 1, and
 
b) In its place, RCIC is used for reactor vessel inventory control and RHR shutdown cooling is used for decay heat removal on Path 1.
 
c) For Unit 1, the non-fire unit for this fire area, Path 3 is available to achieve and maintain safe shutdown.
Deviation Request No. 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown is applicable, in general, to this fire area. In this fire area, ADS and RHR LPCI in the Alternate Shutdown Cooling Mode may be used to achieve and maintain post-fire safe shutdown in the event that fire damage occurs that effects RCIC and/or RHR Shutdown Cooling.
 
6.2.12.2  Fire Zones The following fire zone is located in Fire Area R-2D:
 
Fire Zone  Description 2-5B Valve Access Area 6.2.12.3  Combustible Loading SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-49 The combustible loading in Fire Area R-2D is low. The only combustible material in the room is a small amount of lube oil from the valves in the room, minimal cable insulation and protective
 
fire barriers.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Area R-2D (Fire Zone 2-5B) is addressed in Deviation Requests 3, 6 and 11. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.12.4  Fire Detection/Suppression in the Fire Area
 
The fire area has photoelectric smoke detectors which alarm in the main control room.
Automatic sprinkler protection is provided. Portable extinguishers and manual hose reels are located nearby the area. This equipment is not located inside the fire area since it is a high radiation area during normal operation.
 
6.2.12.5  Consequences of a Fire in Fire Area R-2D Electrical cabling located in Fire Area R-2D associated with Unit 2 Path 1 and Unit 1 Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition for a fire in this Fire Area. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
6.2.12.5.1  Fire Zone 2-5B - Valve Access Area The following Category I components are located in Fire Zone 2-5B:
 
- Core Spray Outboard Injection Valves (HV-E21-2F004A and HV-E21-2F004B) and Core Spray Inboard Injection Valves (HV-E21-2F005A and HV-E21-2F005B) - The inboard and outboard isolation valves for both divisions of Core Spray are located in Fire Area R-2D. Therefore, Core Spray is not credited for post-fire safe shutdown in Fire Area R-2D.
RCIC is protected to perform the inventory make up function for Fire Area R-2D. RHR Shutdown Cooling is protected for the decay heat removal function in Fire Area R-2D. 
- RHR Drywell Spray Outboard Isolation Valve (HV-E11-2F016B) - This valve is normally closed and required to remain closed in support of post-fire safe shutdown on Safe Shutdown Path 3. Safe Shutdown Path 1 is credited for post-fire safe shutdown for Unit 2 in Fire Area R-2D. Safe Shutdown Path 3 is credited for post-fire safe shutdown for Unit 1 in Fire Area R-2D. Fire induced damage to this valve has no impact on Safe
 
Shutdown Path 3 for Unit 1.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Area R-2D (Fire Zone 2-5B) is addressed in Deviation
 
Requests 3, 6 and 11.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-50 6.2.12.6  Special Features There are no special features in Fire Area R-2D. There are no manual actions required.
 
6.2.12.7  Deviation Requests Affecting Fire Area R-2D
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-2D.
 
6.2.13  Fire Area R-2E 6.2.13.1  General Description Fire Area R-2E is the Division II 4.16 KV Switchgear Room at Elevation 719'-1" in the Unit 2 Reactor Building. This fire area consists of a single room. Its location is shown on Drawing
 
E-205960 in Section 8.0. Fire Area R-2E predominately contains Division II equipment, components and cabling. Safe Shutdown Path 1, which is comprised primarily of Division I equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in Fire Area R-2E. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.13.2  Fire Zones
 
The following fire zone is located in Fire Area R-2E:
 
Fire Zone  Description 2-4C 4.16 KV Switchgear Room Div II 6.2.13.3  Combustible Loading
 
The combustible loading in Fire Area R-2E is well below the fire barrier rating of the fire area boundary. The principle contributor to the combustible loading in this fire area is cables in cable tray. Switchgear panels, motor control centers and load centers also contribute to the overall combustible loading. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible
 
restrictions.
 
6.2.13.4  Fire Detection/Suppression in the Fire Area Fire Area R-2E is equipped with ionization smoke detectors which alarm in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, manual hose reels and portable fire extinguishers are located nearby.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-51 6.2.13.5 Consequences of a Fire in Fire Area R-2E In the event of a fire in Fire Area R-2E, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-2E associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished by one of the methods described in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.13.5.1  Fire Zone 2-4C - 4.16 KV Switchgear Room Div II There are no Category I components located in Fire Zone 2-4C.
 
6.2.13.6  Special Features There are no special features in Fire Area R-2E. There are no manual actions required.
 
6.2.13.7  Deviation Requests Affecting Fire Area R-2E
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-2E.
6.2.14  Fire Area R-2F
 
6.2.14.1  General Description Fire Area R-2F is the Division I 4.16 KV Switchgear Room at Elevation 719'-1" in the Unit 2 Reactor Building. This fire area consists of a single room. Its location is shown on Drawing E-205960 in Section  8.0. Fire Area R-2F predominately contains Division I equipment, components and cabling. Safe Shutdown Path 3, which is comprised primarily of Division II equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in Fire Area R-2F. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.14.2  Fire Zones
 
The following fire zone is located in Fire Area R-2F:
Fire Zone  Description 2-4D 4.16 KV Switchgear Room Div I 6.2.14.3  Combustible Loading The combustible loading in Fire Area R-2F is well below the fire barrier rating of the fire area boundary. The principle contributor to the combustible loading in this fire area is cables in cable tray. Switchgear panels, motor control centers and load centers also contribute to the overall combustible loading. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-52 6.2.14.4  Fire Detection/Suppression in the Fire Area Fire Area R-2F is equipped with ionization smoke detectors which alarm in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, manual hose reels and portable fire extinguishers are located nearby.
 
6.2.14.5  Consequences of a Fire in Fire Area R-2F
 
In the event of a fire in Fire Area R-2F, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-2F associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished by one of the methods described in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
: 6. 2.14.5.1  Fire Zone 2-4D - 4.16 KV Switchgear Room Div I
 
There are no Category I components located in Fire Zone 2-4D.
 
6.2.14.6  Special Features There is no special features in Fire Area R-2F. There are no manual actions required.
 
6.2.14.7  Deviation Requests Affecting Fire Area R-2F Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-2F.
 
6.2.15  Fire Area R-2G
 
6.2.15.1  General Description Fire Area R-2G is the Division II 4.16 KV Switchgear Room at Elevation 749'-1" in the Unit 2 Reactor Building. This fire area consists of a single room. Its location is shown on Drawing E-205961 in Section  8.0. Fire Area R-2G predominately contains Division II equipment, components and cabling. Safe Shutdown Path 1, which is comprised primarily of Division I equipment, components and cabling, can be used to achieve safe shutdown in the event of a fire in Fire Area R-2G. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.15.2  Fire Zones
 
The following fire zone is located in Fire Area R-2G:
Fire Zone  Description 2-5F 4.16 KV Switchgear Room Div II 6.2.15.3  Combustible Loading
 
The combustible loading in Fire Area R-2G is well below the fire barrier rating of the fire area boundary. The prime contributor to the combustible loading in this fire area is cables in cable SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-53 tray. Switchgear panels, motor control centers and load centers also contribute to the overall combustible loading. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible
 
restrictions.
6.2.15.4  Fire Detection/Suppression in the Fire Area
 
Fire Area R-2G is equipped with ionization smoke detectors which alarm in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, manual hose reels and portable fire extinguishers are located nearby.
 
6.2.15.5  Consequences of a Fire in Fire Area R-2G
 
In the event of a fire in Fire Area R-2G, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-2G associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished by one of the methods described in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.15.5.1  Fire Zone 2-5F - 4.16 KV Switchgear Room Div II
 
There are no Category I components contained in Fire Zone 2-5F.
6.2.15.6  Special Features
 
The following manual action may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 2-5F* result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping
 
the Motor-Generator Set supply breaker 2A10110 and/or 2A10210.
* Reactor Recirculation Pump 2P401A can be tripped from the Control Room.
6.2.15.7  Deviation Requests Affecting Fire Area R-2G
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-2G.
 
6.2.16  Fire Area R-2H
 
6.2.16.1  General Description
 
Fire Area R-2H is the Division I 4.16 KV Switchgear Room at Elevation 749'-1" in the Unit 2 Reactor Building. This fire area consists of a single room. Its location is shown on Drawing E-205961 Section  8.0. Fire Area R-2H predominately contains Division I equipment, components and cabling. Safe Shutdown Path 3, which is comprised primarily of Division II equipment, components and cabling, can be used to achieve safe shutdown in the event of a SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-54 fire in Fire Area R-2H. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.16.2  Fire Zones The following fire zone is located in Fire Area R-2H:
Fire Zone  Description 2-5G 4.16 KV Switchgear Room Div I 6.2.16.3  Combustible Loading The combustible loading in Fire Area R-2H is well below the fire barrier rating of the fire area boundary. The principle contributor to the combustible loading in this fire area is cables in cable tray. Switchgear panels, motor control centers and load centers also contribute to the overall combustible loading. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible
 
restrictions.
 
6.2.16.4  Fire Detection/Suppression in the Fire Area
 
Fire Area R-2H is equipped with ionization smoke detectors which alarm in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, manual hose reels and portable fire extinguishers are located nearby.
6.2.16.5  Consequences of a Fire in Fire Area R-2H
 
In the event of a fire in Fire Area R-2H, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area R-2H associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished by one of the methods described in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.16.5.1 Fire Zone 2-5G - 4.16 KV Switchgear Room Div I There are no Category I components located in Fire Zone 2-5G. 
 
6.2.16.6  Special Features The following manual action may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 2-5G** result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator Set supply breaker 2A10110 and/or 2A10210.
 
*
* Reactor Recirculation Pump 2P401B can be tripped from the Control Room.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-55 6.2.16.7  Deviation Requests Affecting Fire Area R-2H
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area R-2H.
 
6.2.17  Fire Area CS-1 6.2.17.1  General Description
 
Fire Area CS-1 is the Control Structure freight elevator and access stairway. It extends from elevation 656'-0" to 825'-0". The location of this fire area is shown on Drawings E-205985 thru E-205995 in Section 8.0. Safe Shutdown Path 1 or 3 can be used to achieve safe shutdown in the event of a fire in Fire Area CS-1. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire
 
area.
6.2.17.2  Fire Zones The following fire zones are located in Fire Area CS-1:
 
Fire Zone  Description 0-21B Freight Elevator & Stairwell No. 221 0-29A Stairwell Vestibule 6.2.17.3  Combustible Loading
 
There are minimal combustibles in this fire area. The fire area boundaries are adequate to contain any fire initiated in Fire Area CS-1. Any specific Fire Hazard Analyses applicable to the fire zones in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.17.4  Fire Detection/Suppression in the Fire Area
 
Due to minimal amounts of combustibles, there is no automatic suppression in the fire area. Although there is no fire detection in this fire area, the ionization detectors located in the foyer at each elevation would serve to alert control room personnel of a fire in this fire area.
 
6.2.17.5  Consequences of a Fire in Fire Area CS-1 In the event of a fire in Fire Area CS-1, Safe Shutdown Paths 1 or 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-1 associated with Path 1 or 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-56 6.2.17.5. 1  Fire Zone 0-21 B - Freight Elevator & Stairwell No. 221 The fire hazards analysis identified on Drawing E-205986 in Section 8.0 of this document affects the allowable combustible configuration for this fire zone.
There are no Category I components located in Fire Zone 0-21B.
6.2.17.5.2  Fire Zone 0-29A - Stairwell Vestibule
 
There are no Category I components located in Fire Zone 0-29A.
 
6.2.17.6  Special Features There are no special features in Fire Area CS-1. There are no manual actions required.
 
6.2.17.7  Deviation Requests Affecting Fire Area CS-1
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-1.
 
6.2.18  Fire Area CS-2
 
6.2.18.1  General Description
 
Fire Area CS-2 is the Control Structure passenger elevator and access stairway. It extends from elevation 656'-0" to 806'-0". The location of this fire area is shown on Drawings E-205985 thru E-205994 in Section 8.0. Safe Shutdown Path 1 or 3 can be used to achieve safe shutdown in the event of a fire in Fire Area CS-2. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.18.2  Fire Zones
 
The following fire zones are located in Fire Area CS-2:
Fire Zone  Description 0-22B Passenger Elevator & Stairwell No. 120 0-29C Stairwell Vestibule 6.2.18.3  Combustible Loading There are minimal combustibles in this fire area. The fire area boundaries are adequate to contain any fire initiated in Fire Area CS-2. Any specific Fire Hazard Analyses applicable to the fire zones in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-57 6.2.18.4  Fire Detection/Suppression in the Fire Area Due to the minimal amount of combustibles, there is no automatic fire suppression in the fire area. Although there is no fire detection in this fire area, the ionization detectors located in the foyer at each elevation would serve to alert control room personnel of a fire in this fire area.
6.2.18.5  Consequences of a Fire in Fire Area CS-2
 
In the event of a fire in Fire Area CS-2, Safe Shutdown Path 1 or 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-2 associated with Path 1 or 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.18.5.1  Fire Zone 0-22B - Passenger Elevator & Stairwell No. 120 There are no Category I components located in Fire Zone 0-22B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-22B is addressed in Deviation Request 6.
 
6.2.18.5.2  Fire Zone 0-29C - Stairwell Vestibule
 
There are no Category I components located in Fire Zone 0-29C.
6.2.18.6  Special Features
 
There are no special features in Fire Area CS-2. There are no manual actions required.
 
6.2.18.7  Deviation Requests Affecting Fire Area CS-2
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-2.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-58 6.2.19  Fire Area CS-3
 
6.2.19.1  General Description Fire Area CS-3 is comprised of the Computer Room (located on Elevation 698'-0"), and is a general access area comprising some of the lower level rooms in the Control Structure from elevation 656'-0" to 714'-0". Its location is shown on Drawings E-205985 thru E-205988 in Section 8.0. Safe Shutdown Path 1 would be available to achieve safe shutdown in the event of a fire in Fire Area CS-3. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.19.2  Fire Zones
 
The following fire zones are located in Fire Area CS-3:
 
Fire Zone  Description 0-21A Common Equipment Area 0-22A Central Access Area 0-22C Entrance Corridor & Lobby 0-23 Control Structure Egress Corridor 0-24A UPS Panel Room (U2) 0-24B Corridor (C-200, C-204) 0-24C UPS Panel Room (U1) 0-24E Computer Room 0-24F Computer Maintenance Room & Office 6.2.19.3  Combustible Loading
 
The combustibles in this fire area are primarily computer and electrical panels and cables in cable tray in those fire zones containing the UPS equipment. Although the combustibles are low in these areas, the small area of these zones drives the equivalent fire duration to a value that is unrepresentative of the low combustible quantities in each zone.
 
In Fire Zone 0-24E, the cable insulation in the Computer Room underfloor area is considered in the combustible loading for this area even though the General Electric Fire hazards analysis in Licensing Topical Report NEDO-10466A dated February 1979 which describes that even in a degraded condition with two floor plates removed, a fire does not propagate along the cables.
Ionization type detectors in the PGCC floor provide an alarm in the Control Room and grates are installed in the floor to allow the CO 2 automatic flooding system in the room to migrate to the underfloor area. The flooring in this Fire Zone is no longer considered to be a PGCC Floor system.
In any case, the fire barrier rating of the fire area boundary is adequate to contain any fire initiated within the fire area and to prevent the propagation of the fire to any other fire area in the plant. The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of the fire zones in Fire Area CS-3 is addressed in Deviation Request 6. Any SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-59 specific Fire Hazard Analyses applicable to the fire zones in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.19.4  Fire Detection/Suppression in the Fire Area Fire area CS-3 has fire detection and suppression in those portions of the area where potential fire hazards exist. In the UPS panel rooms there are heat detectors and ionization detectors.
These rooms also have a total flooding CO 2  system for fire suppression. Computer service areas are provided with only ionization detectors. In addition to these automatic suppression systems in the UPS panel rooms, manual hose reels and portable fire extinguishers are located throughout the fire area for use.
 
Fire Zone 0-24E is equipped with ionization type smoke detectors and heat detectors.
Ionization detectors are located within the PGCC flooring system. An automatic total flooding
 
CO 2 extinguishing system is located inside the room.
Manual deluge systems are provided for charcoal filters OF135, OF138, OF141, and OF144 in Fire Zone 0-22A.
 
6.2.19.5  Consequences of a Fire in Fire Area CS-3 In the event of a fire in Fire Area CS-3, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-3 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.19.5.1 Fire Zone 0-21A - Common Equipment Area
 
There are no Category I components located in Fire Zone 0-21A.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-21A is addressed in Deviation Request 6.
 
6.2.19.5.2  Fire Zone 0-22A - Central Access Area
 
There are no Category I components located in Fire Zone 0-22A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-22A is addressed in Deviation Request 6.
 
6.2.19.5.3  Fire Zone 0-22C - Entrance Corridor & Lobby There are no Category I components located in Fire Zone 0-22C.
 
6.2.19.5.4  Fire Zone 0 Control Structure Egress Corridor
 
There are no Category I components located in Fire Zone 0-23.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-60 6.2.19.5.5  Fire Zone 0-24A - UPS Panel Room (U2)
There are no Category I components located in Fire Zone 0-24A.
 
6.2.19.5.6  Fire Zone 0-24B - Corridor (C-200, C-204)
 
There are no Category I components located in Fire Zone 0-24B.
 
6.2.19.5.7 Fire Zone 0-24C - UPS Panel Room (U1)
There are no Category I components located in Fire Zone 0-24C.
 
6.2.19.5.8  Fire Zone 0-24E - Computer Room
 
There are no Category I components located in Fire Zone 0-24E.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-24E is addressed in Deviation Request 6.
 
6.2.19.5.9  Fire Zone 0-24F - Computer Maintenance Room & Office There are no Category I components located in Fire Zone 0-24F.
 
6.2.19.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-24B, 0-24E or 0-24F result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by
 
manually tripping the Motor-Generator set supply breaker 2A10110 and/or 2A10210.
: 2. Should a fire in Fire Zone 0-24B, 0-24E or 0-24F result in disabling the low condenser vacuum signal which prevents the Unit 1 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main Steam Line Drains.
: 3. Should a fire in Fire Zone 0-24B, 0-24E or 0-24F result in disabling the low condenser vacuum signal which prevents the Unit 2 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main Steam Line Drains.
 
6.2.19.7  Deviation Requests Affecting Fire Area CS-3
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-3.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-61 6.2.20  Fire Area CS-4 6.2.20.1  General Description
 
Fire Area CS-4 consists of the HVAC Plenum, Fan Room and Duct chases in the Control Structure. The location of the fan rooms and the plenum is shown on Drawings E-205988 thru E-205995. The duct chases run vertically through various elevations along the west side of the Control Structure. Safe Shutdown Path 1 or 3 can be used in the event of a fire in Fire Area CS- 4. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.20.2  Fire Zones
 
The following fire zones are located in Fire Area CS-4:
 
Fire Zone  Description 0-24I HVAC Duct Chase 0-24K HVAC Duct Chase 0-28S HVAC Duct Chase 0-29B Fan Room & Associated HVAC Equipment 0-29D Pipe & Duct Chase 0-30A Control Structure HVAC & SBGTS 0-30B Stairwell No. 125 6.2.20.3  Combustible Loading The HVAC duct chases in this Fire Area have no combustible materials and they are isolated from other fire areas in the plant by fire rated dampers. The combustibles in Fire Zone 0-29B are minimal and consist of cables in electrical panels and cable tray. The major combustible materials in Fire Zone 0-30A are the charcoal in the Standby Gas Treatment System Filters and the charcoal in the Emergency Outside Air Filters. The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of the fire zones in Fire Area CS-4 is addressed in Deviation Request 6. Any specific Fire Hazard Analyses applicable to the fire zones in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
6.2.20.4  Fire Detection/Suppression in the Fire Area
 
Fire detection is located throughout this fire area except in the HVAC duct chases and the stairway. The charcoal filter beds for the Standby Gas Treatment System and the Emergency Outside Air Filters have deluge systems specifically designed for the fire hazard posed by the charcoal. Additionally, Fire Zone 0-29B and 0-30A have an automatic suppression system installed throughout each zone. Manual hose reels and portable extinguishers are located
 
throughout the fire area.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-62 6.2.20.5  Consequences of a Fire in Fire Area CS-4 In the event of a fire in Fire Area CS-4, safe shutdown Path 1 or 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-4 associated with Path 1 or 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.20.5.1  Fire Zone 0-24I - HVAC Duct Chase There are no Category I components located in Fire Zone 0-24I.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-24I is addressed in Deviation Request 6.
6.2.20.5.2  Fire Zone 0-24K - HVAC Duct Chase
 
There are no Category I components located in Fire Zone 0-24K.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-24K is addressed in Deviation Request 6.
 
6.2.20.5.3  Fire Zone 0-28S - HVAC Duct Chase There are no Category I components located in Fire Zone 0-28S.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28S is addressed in Deviation Request 6.
 
6.2.20.5.4  Fire Zone 0-29B - Fan Room & Associated HVAC Equip
 
The following Category I components are located in Fire Zone 0-29B:
 
- Appendix R Communication System Jackplate JP1105 - This component is a jackplate for Loop 1 of the Appendix R sound powered communications system. There are no operator actions resulting from a fire in Fire Area CS-4 that require the use of this loop of the sound powered communications system. Therefore, this component is not required for post-fire safe shutdown in this fire area.
- Appendix R Communication System Jackplate JP1305 - This component is a jackplate for Loop 3 of the Appendix R sound powered communications system. There are no operator actions resulting from a fire in Fire Area CS-4 that require the use of this loop of the sound powered communications system. Therefore, this component is not required for post-fire safe shutdown in this fire area.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-29B is addressed in Deviation Request 6.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-63 6.2.20.5.5  Fire Zone 0-29D - Pipe & Duct Chase There are no Category I components located in Fire Zone 0-29D.
 
6.2.20.5.6  Fire Zone 0-30A - Control Structure HVAC & SBGTS
 
There are no Category I components located in Fire Zone 0-30A.
 
6.2.20.5.7  Fire Zone 0-30B - Stairwell No. 125 There are no Category I components located in Fire Zone 0-30B.
 
6.2.20.6  Special Features
 
There are no special features in Fire Area CS-4. There are no manual actions required.
 
6.2.20.7  Deviation Requests Affecting Fire Area CS-4 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-4.
 
6.2.21  Fire Area CS-5
 
6.2.21.1  General Description
 
Fire Area CS-5 is the Unit 2 Lower Relay Room located on elevation 698'-0" of the control structure. This fire area is a single room fire zone which primarily contains Division II equipment. The location of this fire area is shown on Drawing E-205988 in Section 8.0. Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area CS-5. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.21.2  Fire Zones
 
The following fire zone is located in Fire Area CS-5:
 
Fire Zone  Description 0-24G U2 Div II Lower Relay Room 6.2.21.3  Combustible Loading
 
Fire Zone 0-24G is its own Fire Area CS-5. The principle combustibles in Fire Zone 0-24G are cables located in electrical panels and underfloor ducts and a limited amount of non-metallic PGCC floor paneling. There is no mechanical equipment (i.e. pumps, valves, etc.) in Fire Zone 0-24G. Fire Zone 0-24G is constructed in a manner that is similar to the PGCC design originally supplied by General Electric and described in the GE Fire Hazards Analysis in Licensing Topical Report NEDO 10466A dated February 1979. This NEDO Document describes the separation of Class 1E systems in the floor with 3/16" steel barriers, utilization of semi-permanent fire stop material, provision of heat detectors in the PGCC flooring and rooms and unitized halon system in the PGCC underfloor. Based on these characteristics the NEDO Document provides a reasonable basis for excluding the cable insulation in the PGCC underfloor area from the combustible loading for this fire zone. Due to a difference in the amount of non-metallic floor SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-64 paneling used in Fire Zone 0-24G as compared to the NEDO Document, the cable insulation in the underfloor area has been included in the combustible loading analysis for Fire Zone 0-24G.
Additional fire suppression beyond that discussed in the NEDO Document is provided in Fire Zone 0-24G. Fire Zone 0-24G includes a CO 2 automatic total room flooding system. This additional fire suppression is available to rapidly extinguish any fire that might originate in Fire Zone 0-24G. 
 
The fire area boundaries are adequate to contain the effects of any fire originating in Fire Zone 0-24G. The level of combustible in Fire Zone 0-24G, including the contribution from the
 
underfloor cable insulation in the PGCC floor and the non-metallic PGCC floor paneling, is maintained to assure that the total combustible loading does not exceed the fire resistance rating for the boundaries of Fire Area CS-5. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.21.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-5 is equipped with ionization detectors and heat detectors. The fire area has a Halon extinguishing system located in the PGCC modules which protect the safety related cabinets with the exception of panels 2C636 and 2C699B. The room is also equipped with an automatic total flooding CO 2 system. With the exception of panels 2C636 and 2C699B, safety related cabinets are protected with Halon. In addition, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.21.5  Consequences of a Fire in Fire Area CS-5 In the event of a fire in Fire Area CS-5, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-5 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.21.5.1  Fire Zone 0-24G - U2 Div II Lower Relay Room
 
The following Category I components are located in Fire Zone 0-24G:
- Unit 2 HPCI Division II Automatic Actuation Logic - This component is the automatic initiation logic for the HPCI system. Automatic initiation of safety systems in support of post-fire safe shutdown is not required. The automatic initiation logic is evaluated for the potential affects of a spurious initiation of the system. A fire induced spurious start of the HPCI system in conjunction with the loss of the HPCI high water level trip in Fire Area CS-5 can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-2F002).
- Unit 2 RCIC Division II Automatic Actuation Logic - This component is the automatic initiation logic for the RCIC system. Automatic initiation of safety systems in support of post-fire safe shutdown is not required. The automatic initiation logic is evaluated for the potential affects of a spurious initiation of the system. A fire induced spurious start of the RCIC system in conjunction with the loss of the RCIC high water level trip in Fire Area SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-65 CS-5 can be mitigated by closing the RCIC Outboard Steam Line Isolation Valve (HV-E51-2F008).
 
6.2.21.6  Special Features The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-24G result in loss of Unit 2 reactor scram capability and/or scram discharge volume isolation capability from the Control Room, scram Unit 2 and isolate the scram discharge volume by manually isolating and venting the instrument air header in the Unit 2 Reactor Building.
: 2. Should a fire in Fire Zone 0-24G result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B from the Control Room.
: 3. Should a fire in Fire Zone 0-24G result in spurious Unit 2 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 2 Division I ADS and to inject water into the reactor using Unit 2 Division I Core Spray remains available from the Control Room.
: 4. Should a fire in Fire Zone 0-24G spuriously open the Unit 2 RHR Injection Isolation Valve HV-251-F015A, close the RHR Injection Control Valve HV-251-F017A from the Control Room.
: 5. Should a fire in Fire Zone 0-24G result in Unit 2 HPCI spuriously starting while disabling the 54" high water level trip, manually take control of HPCI from the Control Room or close the HPCI Turbine Steam Supply Inboard Isolation Valve HV-255-F002.
: 6. Should a fire in Fire Zone 0-24G result in disabling the low condenser vacuum signal which prevents the Unit 2 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main Steam Line Drains.
 
6.2.21.7  Deviation Requests Affecting Fire Area CS-5
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-5.
6.2.22 Fire Area CS-6
 
6.2.22.1  General Description
 
Fire Area CS-6 is a vertical electrical cable chase which extends from elevation 698'-0" to 783'-0" along the west wall of the control structure. The location of this fire area is shown on Drawings E-205988 thru E-205993 in Section 8.0. Safe Shutdown Path 3 would be available in the event of a fire in Fire Area CS-6. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire
 
area. 6.2.22.2  Fire Zones
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-66 The following fire zones are located in Fire Area CS-6:
Fire Zone  Description 0-24JSouth Electrical Cable Chase 0-25B South Electrical Cable Chase 0-26B South Electrical Cable Chase 0-26S South Electrical Cable Chase 0-27F South Electrical Cable Chase 0-28P South Electrical Cable Chase 6.2.22.3  Combustible Loading
 
The combustible materials in this fire area are cables. Due to the nature of this fire area, the standard method of expressing the combustible loading in equivalent fire severity (in minutes) yields unrealistic results. This is due to the small cross-sectional floor area of each of the fire zones in this area. This cable chase is a vertical shaft with sealed barriers at each main floor elevation for the purpose of limiting fire spread and controlling the concentration of carbon dioxide if the fire protection system is activated. This cable chase is essentially 'gas tight' between each fire zone. Early detection and actuation of the CO 2 systems that protect these fire zones would quickly extinguish a fire within any fire zone and would prevent fire propagation into an adjacent fire zone or into another fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of the fire zones in Fire Area CS-6 is addressed in Deviation Request 37. Any specific Fire Hazard Analyses applicable to the fire zones in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.22.4  Fire Detection/Suppression in the Fire Area
 
Fire Zones 0-24J, 0-25B, 0-26S, 0-27F and 0-28P contain one heat detector each and an automatic total flooding CO 2 extinguishing system. Fire Zone 0-26B is on the same elevation as the main control room, contains one ionization smoke detector each and a manual spurt CO 2 system. 6.2.22.5  Consequences of a Fire in Fire Area CS-6
 
In the event of a fire in Fire Area CS-6, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-6 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.22.5.1  Fire Zone 0-24J - South Electrical Cable Chase There are no Category I components located in Fire Zone 0-24J.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-67 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-24J is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.22.5.2  Fire Zone 0-25B - South Electrical Cable Chase
 
There are no Category I components located in Fire Zone 0-25B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-25B is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.22.5.3  Fire Zone 0-26B - South Electrical Cable Chase There are no Category I components located in Fire Zone 0-26B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26B is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.22.5.4  Fire Zone 0-26S - South Electrical Cable Chase There are no Category I components located in Fire Zone 0-26S.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26S is addressed in Deviation Request 37.
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.22.5.5  Fire Zone 0-27F - South Electrical Cable Chase
 
There are no Category I components located in Fire Zone 0-27F.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27F is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.22.5.6  Fire Zone 0-28P - South Electrical Cable Chase There are no Category I components located in Fire Zone 0-28P.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-68 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28P is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.22.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-24J or 0-27F result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator set supply breaker 2A10110 and/or 2A10210.
: 2. Fire Zones 0-26B, 0-26S and 0-27F, actions performed during plant start up lifts lead in Motor Control Center 2B236 cubicle 102 which disables Reactor Head Vent Valve HV-241-F001 preventing a reactor coolant flow diversion through spurious opening of
 
both Head Vent Valves.
: 3. Should a fire in Fire Zone 0-24J result in disabling the low condenser vacuum signal which prevents the Unit 2 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the
 
Main Steam Line Drains.
 
6.2.22.7  Deviation Requests Affecting Fire Area CS-6
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-6.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-69 6.2.23  Fire Zone CS-7 6.2.23.1  General Description
 
Fire Area CS-7 is a vertical electrical cable chase which extends from elevation 698'-0" to 783'-0" along the west wall of the control structure. The location of this fire area is shown on Drawings E-205988 thru E-205993 in Section 8.0. Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-7. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this
 
fire area.
6.2.23.2  Fire Zones
 
The following fire zones are located in Fire Area CS-7:
 
Fire Zone  Description 0-24L Center Electrical Cable Chase 0-24M North Electrical Cable Chase 0-25C Center Electrical Cable Chase 0-25D North Electrical Cable Chase  0-26C Center Electrical Cable Chase 0-26D North Electrical Cable Chase 0-26T Center Electrical Cable Chase 0-26V North Electrical Cable Chase Fire Zone  Description 0-27G Center Electrical Cable Chase 0-27H North Electrical Cable Chase 0-28Q Center Electrical Cable Chase 0-28R North Electrical Cable Chase 6.2.23.3  Combustible Loading The combustible materials in this fire area are cables. Due to the nature of this fire area, the standard method of expressing the combustible loading in equivalent fire severity in minutes yields unrealistic results. This is due to the small cross-sectional with sealed barriers at each main floor elevation for the purpose of limiting fire spread floor area of each of the fire zones in this area. These cable chases are vertical shafts and controlling the concentration of carbon dioxide if the fire protection system is activated. These cable chases are essentially 'gas-tight' between each fire zone. Early detection and actuation of the CO 2 systems that protect these fire zones would quickly extinguish a fire within any zone and would prevent fire propagation into an adjacent fire zone or into another fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of the fire zones in Fire Area CS-7 is addressed in Deviation Request 37. Any specific Fire Hazard Analyses applicable to the fire zones in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions. 
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-70 6.2.23.4  Fire Detection/Suppression in the Fire Area Fire Zones 0-24L, 0-24M, 0-25C, 0-25D, 0-26T, 0-26V, 0-27G, 0-27H, 0-28Q and 0-28R contain one heat detector each and an automatic total flooding CO 2 extinguishing system. Fire Zones 0-26C and 0-26D which are on the same elevations as the main control room fire area, contain one ionization smoke detector each and a manual spurt CO 2 extinguishing system.
 
6.2.23.5  Consequences of a Fire in Fire Area CS-7
 
In the event of a fire in Fire Area CS-7, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-7 associated with Path 3 safe shutdown systems and components or has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
6.2.23.5.1  Fire Zone 0-24L - Center Electrical Cable Chase
 
There are no Category I components located in Fire Zone 0-24L.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-24L is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.23.5.2  Fire Zone 0-24M - North Electrical Cable Chase
 
There are no Category I components located in Fire Zone 0-24M.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-24M is addressed in Deviation Request 37.
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.5.3  Fire Zone 0-25C - Center Electrical Cable Chase
 
There are no Category I components located in Fire Zone 0-25C.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-25C is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.5.4  Fire Zone 0-25D - North Electrical Cable Chase There are no Category I components located in Fire Zone 0-25D.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-71 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-25D is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.23.5.5  Fire Zone 0-26 C - Center Electrical Cable Chase
 
There are no Category I components located in Fire Zone 0-26C.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26C is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.5.6  Fire Zone 0-26D - North Electrical Cable Chase There are no Category I components located in Fire Zone 0-26D.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26D is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.5.7  Fire Zone 0-26T - Center Electrical Cable Chase There are no Category I components located in Fire Zone 0-26T.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26T is addressed in Deviation Request 37.
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.5.8  Fire Zone 0-26V - North Electrical Cable Chase
 
There are no Category I components located in Fire Zone 0-26V.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26V is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.5.9  Fire Zone 0- 27G - Center Electrical Cable Chase There are no Category I components located in Fire Zone 0-27G.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-72 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27G is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.23.5.10  Fire Zone 0-27 H - North Electrical Cable Chase
 
There are no Category I components located in Fire Zone 0-27H.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27H is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.5.11  Fire Zone 0-28Q - Center Electrical Cable Chase There are no Category I components located in Fire Zone 0-28Q.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28Q is addressed in Deviation Request 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.5.12  Fire Zone 0-28R - North Electrical Cable Chase There are no Category I components located in Fire Zone 0-28R.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28R is addressed in Deviation Request 37.
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.23.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zones 0-26D, 0-26V or 0-27H result in spurious Unit 1 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 1 Division II ADS and to inject water into the reactor using Unit 1 Division II Core Spray remains available from the Control Room.
: 2. Should a fire in Fire Zone 0-24L result in disabling the low condenser vacuum signal which prevents the Unit 1 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main Steam Line Drains.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-73 6.2.23.7  Deviation Requests Affecting Fire Area CS-7 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-7.
 
6.2.24 Fire Area CS-8
 
Fire Area CS-8 is eliminated. Fire Area CS-8 contained Fire Zone 0-24E, Computer Room.
Fire Zone 0-24E is included in Fire Area CS-3.
 
6.2.25  Fire Area CS-9
 
6.2.25.1  General Description
 
Fire Area CS-9 is the Main Control Room and associated fire zones. The floor of the Main Control Room is at elevation 729'-1" of the Control Structure and the overlooking mezzanine Technical Support Center is at elevation 741'-1". This fire area is shown on Drawings E-205990 and E-205991 in Section 8.0. Safe Shutdown Path 2 would be available for use in the event of a fire in Fire Area CS-9. Deviation Request No. 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown is applicable, in general, to this fire area.
In this fire area, ADS/SRVs and RHR LPCI in the Alternate Shutdown Cooling Mode may be used to achieve and maintain post-fire safe shutdown in the event that fire damage occurs that effects RCIC and/or RHR Shutdown Cooling.
 
6.2.25.2  Fire Zones
 
The following fire zones are located in Fire Area CS-9:
Fire Zone  Description 0-26A Copy Room 0-26E Locker Room 0-26F Vestibule (U1) 0-26G Shift Outage/STA Office 0-26H Control Room 0-26I Shift Supervisor's Office 0-26J Vestibule (U2) 0-26K Technical Support Center 0-26L TSC Conference Room/Library 0-26M TSC North Soffit Fire Zone  Description 0-26N Control Room U1 Soffit 0-26P Control Room U2 Soffit 0-26R TSC South Office Soffit 6.2.25.3  Combustible Loading
 
The combustible loading in Fire Area C-9 consists primarily of cables in panels, cabinets and tray. Control Room reference manuals and drawings contribute a small portion to the combustible loading. Any fire initiated within this fire area will not propagate to any other fire area in the Control Structure.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-74 The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of the fire zones in Fire Area CS-9 is addressed in Deviation Requests 2, 6, 23 and 37. Any specific Fire Hazard Analyses applicable to the fire zones in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.25.4  Fire Detection/Suppression in the Fire Area
 
Fire detection is located throughout Fire Area CS-9. The control room has a manual spurt CO 2 system located under the floor and portable fire extinguishers. Manual hose reels are located outside the control room. Since the control room is constantly staffed, the early detection and suppression of any fire is assured.
 
6.2.25.5  Consequences of a Fire in Fire Area CS-9 In the event of a fire in Fire Area CS-9 which would cause evacuation of control room personnel, control room operators would manually scram both units, close the MSIVs on each unit, trip the reactor feed pump turbine on each unit, close the reactor feed pump discharge valves on each unit and man each unit's remote shutdown panels. From each remote shutdown panel (Fire Zone 1-2D in Unit 1 and 2-2A in Unit 2) the operator could control each unit and maintain it in a safe shutdown condition. Due to the unique nature of this fire area, the standard format will not be used. Rather, a description of the detailed analysis performed for the above mentioned scenario follows.
 
In order to properly achieve and maintain safe shutdown in the event of a fire which causes evacuation of the main control room, the availability of all of the Path 2 components and cables was examined. The objective of this study was to ensure that any systems required for Path 2 shutdown from each units Remote Shutdown Panel would not be affected by a fire in Fire Area CS-9.
 
Our control room fire analysis assures that a fire in the main control room or any of its associated fire zones in Fire Area CS-9 would be contained within Fire Area CS-9 and would not propagate to any other fire area in the plant.
 
6.2.25.5.1  Fire Zone 0-26A - Copy Room There are no Category I components located in Fire Zone 0-26A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26A is addressed in Deviation Requests 6 and 23.
 
6.2.25.5.2  Fire Zone 0-26E - Locker Room
 
There are no Category I components located in Fire Zone 0-26E.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26E is addressed in Deviation Requests 6 and 23.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-75 6.2.25.5.3  Fire Zone 0-26F - Vestibule (U1)
There are no Category I components located in Fire Zone 0-26F.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26F is addressed in Deviation Requests 2, 6, 23 and
: 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.25.5.4  Fire Zone 0-26G - Shift Outage/STA Office
 
There are no Category I components located in Fire Zone 0-26G.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26G is addressed in Deviation Requests 2, 6, 23 and
: 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.25.5.5  Fire Zone 0-26H - Control Room
 
The following Category I components are located in Fire Zone 0-26H:
- Nuclear Steam Supply Shutoff System Instrument Power Supplies (B21H1T1, B21H1T2) - Fire induced damage to this 24 VDC Instrument Power Supply has been determined to have no impact on any safe shutdown components or functions. Instrument loops powered by this power supply are not required for post-fire safe shutdown and these loops are properly isolated from any required safe shutdown loops.
- Suppression Pool Temperature Indicators (TIAH-15751, TIAH-15752, TIAH-25751, TIAH-25752), Suppression Pool Water Temperature Transducers (TX-15751, TX-15752, TX-25751, TX25752) - Addressed in Deviation Request No. 2.
- RHR Leak Detection System Temperature Switches (TSH-E11-2N600A, TSH-E11-2N600B, TSH-E11-2N600C, TSH-E11-2N600D, TDSH-E11-2N601A, TDSH-E11-2N601B, TDSH-E11-2N601C, TDSH-E11-2N601D) - This isolation function is bypassed when the transfer switch is actuated at the Remote Shutdown Panel. Therefore, a fire induced failure of this component will have no impact on post-fire safe shutdown.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26H is addressed in Deviation Requests 2, 6, 23 and
: 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-76 6.2.25.5.6  Fire Zone 0-26I - Shift Supervisor's Office There are no Category I components located in Fire Zone 0-26I.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26I is addressed in Deviation Requests 2, 6, 23 and 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.25.5.7 Fire Zone 0-26J - Vestibule (U2)
 
There are no Category I components located in Fire Zone 0-26J.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26J is addressed in Deviation Requests 2, 6, 23 and
: 37.
 
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
6.2.25.5.8  Fire Zone 0-26K - Technical Support Center
 
There are no Category I components located in Fire Zone 0-26K.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26K is addressed in Deviation Requests 6 and 23.
 
6.2.25.5.9  Fire Zone 0-26L - TSC Conference Room/Library
 
There are no Category I components located in Fire Zone 0-26L.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26L is addressed in Deviation Requests 6 and 23.
 
6.2.25.5.10  Fire Zone 0-26M - TSC North Soffit
 
There are no Category I components located in Fire Zone 0-26M.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26M is addressed in Deviation Requests 2, 6, 23 and
: 37. Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.25.5.11  Fire Zone 0-26N - Control Room U1 Soffit
 
There are no Category I components located in Fire Zone 0-26N.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-77 The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26N is addressed in Deviation Requests 6 and 23.
 
6.2.25.5.12  Fire Zone 0-26P - Control Room U2 Soffit There are no Category I components located in Fire Zone 0-26P.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26P is addressed in Deviation Requests 6 and 23.
 
6.2.25.5.13  Fire Zone 0-26R - TSC South Office Soffit There are no Category I components located in Fire Zone 0-26R. 
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-26R is addressed in Deviation Requests 6, 23 and
: 37.
Deviation Request 37 justifies limiting the protection of certain equipment and/or cabling for the required safe shutdown path in this fire zone.
 
6.2.25.6  Special Features The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-26H result in spurious actuation of Unit 1 SRVs as indicated by low RPV pressure and/or level, one of the following actions can be taken.
: a. If SRVs A, B, or C spuriously actuate, operate transfer switch to LOCAL at the Unit 1 Remote Shutdown Panel to preclude spurious operation.
: b. If SRVs D, E, F, G, H, J, K, L, M, N, P, R or S spuriously actuate, provide makeup as necessary with RCIC or LPCI.
: 2. Should a fire in Fire Zones 0-26H, 0-26I or 0-26R result in spurious actuation of Unit 2 SRVs as indicated by low RPV pressure and/or level, one of the following actions can be taken. a. If SRVs A, B, or C spuriously actuate, operate transfer switch to LOCAL at the Unit 2 Remote Shutdown Panel to preclude spurious operation.
: b. If SRVs D, E, F, G, H, J, K, L, M, N, P, R or S spuriously actuate, provide makeup as necessary with RCIC or LPCI.
: 3. Should a fire in Fire Zone 0-26H result in the Unit 1 SRVs A, B and C being unavailable for RPV de-pressurization due to depletion of their accumulators, operate the Unit 1 ADS valves sequentially using the key locked switches located in the Unit 1 Upper Relay Room.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-78 4. Should a fire in Fire Zone 0-26H result in the Unit 2 SRVs A, B and C being unavailable for RPV de-pressurization due to depletion of their accumulators, operate the Unit 2 ADS valves sequentially using the key locked switches located in the Unit 2 Upper Relay Room. 5. Should a fire in Fire Zones 0-26G, 0-26H or 0-26M result in the spurious starting of the Unit 1 RHR Pump 1P202A, trip Pump 1P202A by manually tripping Unit 1 4.16 KV Switchgear breaker 1A20102. This action is performed in order to operate the Unit 2 RHR Pump 2P202A.
: 6. Should a fire in Fire Zone 0-26H result in spurious starting of the Unit 2 RHR Pump 2P202B, trip Pump 2P202B by manually tripping Unit 2 4.16 KV Switchgear breaker 2A20202. This action is performed in order to operate the Unit 1 RHR Pump 1P202B.
: 7. Should a fire in Fire Zone 0-26H result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping the Motor-Generator set supply breaker 1A10110 and/or 1A10210.
: 8. Fire Zone 0-26H, actions performed during plant start up lifts lead in Motor Control Center 1B236 cubicle 102 which disables Reactor Head Vent Valve HV-141-F001 preventing a reactor coolant flow diversion through spurious opening of both Head Vent Valves. 
: 9. Fire Zone 0-26H, actions performed during plant start up lifts lead in Motor Control Center 2B236 cubicle 102 which disables Reactor Head Vent Valve HV-241-F001 preventing a reactor coolant flow diversion through spurious opening of both Head Vent Valves. 
: 10. Should a fire in Fire Zones 0-26G, 0-26H or 0-26M result in loss of Unit 1 scram discharge volume isolation capability, isolate the scram discharge volume by manually venting the instrument air header in the Unit 1 Reactor Building.
: 11. Should a fire in Fire Zones 0-26H, 0-26I, 0-26J or 0-26R result in loss of Unit 2 scram discharge volume isolation capability, isolate the scram discharge volume by manually venting the instrument air header in the Unit 2 Reactor Building.
: 12. Should a fire in Fire Zones 0-26H or 0-26M result in failure of the RWCU Inlet Outboard Isolation Valve HV-144-F004 causing loss of isolation capability of the RWCU System at the Unit 1 Remote Shutdown Panel, open the Unit 1 Distribution Panel 1Y219 Breaker 18 to close the RWCU Filter Demineralizer Outlet Valve HV-144-F033 and prevent potential RPV inventory loss.
: 13. Should a fire in Fire Zones 0-26H, 0-26I or 0-26R result in failure of the RWCU Inlet Inboard Isolation Valve HV-244-F001 causing loss of isolation capability of the RWCU System at the Unit 2 Remote Shutdown Panel, open the Unit 2 Distribution Panel 2Y219 Breaker 18 to close the RWCU Filter Demineralizer Outlet Valve HV-244-F033 and
 
prevent potential RPV inventory loss.
: 14. Should a fire in Fire Zones 0-26H or 0-26N result in spurious opening of the Unit 1 Suppression Pool Inboard/Outboard Drain Valves HV-15766/68 as indicated by decreasing Suppression Pool Level, locally close manual valve 157025.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-79
: 15. Should a fire in Fire Zones 0-26H, 0-26I or 0-26R result in spurious opening of the Unit 2 Suppression Pool Inboard/Outboard Drain Valves HV-25766/68 as indicated by decreasing Suppression Pool Level, locally close manual valve 257025.
: 16. Should a fire in Fire Zones 0-26H, 0-26G or 0-26M result in loss of the automatic and manual close capability from the Control Room for the Unit 1 and/or Unit 2 Diesel
 
Generator 4.16 KV supply breakers 1A20104, 1A20204, 1A20304, 1A20404, 2A20104, 2A20204, 2A20304 or 2A20404, locally close the breaker at the 4.16 KV Switchgear.
: 17. Should a fire in Fire Zones 0-26H or 0-26M result in a Unit 1 Reactor Coolant System flow diversion when operating in the alternate shutdown cooling mode caused by the MSIV drain valves "Spuriously Opening", one of the following actions can be taken to
 
prevent the flow diversion.
: a. Open Unit 1 250 VDC Motor Control Center 1D274 Breaker 041 and manually close MSIV Drain Valve HV-141-F019, or
: b. Open Unit 1 480 VAC Motor Control Centers 1B216 Breaker 112 and 1B217 Breaker 024 and manually close Main Steam Line Drain to Condenser Valve HV-141-F021, Main Steam Line Warm-up Valve HV-141-F020 and Main Steam Line Drain Valve to Condenser Bypass Valve 141F033.
: 18. Should a fire in Fire Zones 0-26H, 0-26I or 0-26R result in a Unit 2 Reactor Coolant System flow diversion when operating in the alternate shutdown cooling mode caused by the MSIV drain valves "Spuriously Opening", one of the following action can be taken to prevent the flow diversion.
: a. Open Unit 2 250 VDC Motor Control Center 2D274 Breaker 041 and manually close MSIV Drain Valve HV-241-F019, or
: b. Open Unit 2 480 VAC Motor Control Centers 2B227 Breaker 081 and 2B217 Breaker 024 and manually close Main Steam Line Drain to Condenser Valve HV-241-F021, Main Steam Line Warm-up Valve HV-241-F020 and Main Steam
 
Line Drain Valve to Condenser Bypass Valve 241F033.
: 19. Should a fire in Fire Zones 0-26H, result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator set supply breaker 2A10110 and/or 2A10210.
 
6.2.25.7  Deviation Requests Affecting Fire Area CS-9
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-9.
6.2.26  Fire Area CS-10
 
6.2.26.1  General Description Fire Area CS-10 is the Unit 1 Division I Upper Cable Spreading Room at elevation 754'-0" of the control structure. Its location is shown on Drawing E-205992 in Section 8.0. Safe Shutdown Path 3 is available for use in the event of a fire in Fire Area CS-10. Deviation Request 33 that SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-80 justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.26.2  Fire Zones The following fire zones are located in Fire Area CS-10:
Fire Zone  Description 0-27C U1 Div I Upper Cable Spreading Room 0-27D Electricians Office 6.2.26.3  Combustible Loading
 
The principle combustibles in Fire Area CS-10 are cables in cable tray and are dispersed throughout the fire area. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire
 
area.
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of the zones in Fire Area CS-10 is affected by the fire hazards analysis for specific configurations.
Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.26.4  Fire Detection/Suppression in the Fire Area Fire Area CS-10 is equipped with ionization type smoke detectors and heat detectors. The entire area is covered by a pre-action sprinkler system, and manual hose reels and portable fire extinguishers are available.
 
6.2.26.5  Consequences of a Fire in Fire Area CS-10 In the event of a fire in Fire Area CS-10, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-10 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.26.5.1  Fire Zone 0-27C - U1 Div I Upper Cable Spreading Room There are no Category I components located in Fire Zone 0-27C.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27C is affected by the fire hazards analysis identified
 
on Drawing E-205992 in Section 8.0.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-81 6.2.26.5.2  Fire Zone 0-27D - Electricians Office There are no Category I components located in Fire Zone 0-27D.
 
6.2.26.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-27C result in loss of Unit 1 reactor scram capability and/or scram discharge volume isolation capability from the Control Room, scram Unit 1 and isolate the scram discharge volume by manually venting the instrument air header in the
 
Unit 1 Reactor Building.
: 2. Should a fire in Fire Zone 0-27C result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B from the Control Room.
: 3. Should a fire in Fire Zone 0-27C result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B from the Control Room.
: 4. Should a fire in Fire Zone 0-27C result in spurious Unit 1 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 1 Division II ADS and to inject water into the reactor using Unit 1 Division II Core Spray remains available from the Control Room.
: 5. Should a fire in Fire Zone 0-27C spuriously open the Unit 1 RHR Injection Isolation Valve HV-151-F015B, close the RHR Injection Control Valve HV-151-F017B from the Control Room.
: 6. Should a fire in Fire Zone 0-27C result in disabling the low condenser vacuum signal which prevents the Unit 1 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main Steam Line Drains.
 
6.2.26.7  Deviation Requests Affecting Fire Area CS-10
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-10.
6.2.27  Fire Area CS-11
 
6.2.27.1  General Description
 
Fire Area CS-11 is the Unit 2 Equipment Room which contains Division II load centers, battery chargers and distribution panels. It is located on elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0. Safe Shutdown Path 1 would be available in the event of a fire in Fire Area CS-11. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.27.2  Fire Zones
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-82 The following fire zone is located in Fire Area CS-11:
Fire Zone  Description 0-28A-I U2 Div II Equipment Room 6.2.27.3  Combustible Loading The combustible loading is relatively low in this fire area and any fire initiated within the fire area would be contained by the fire boundary. The principle combustibles in this area are cables in electrical panels. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) in Fire Area CS-11 are addressed in Deviation Requests 6 and 15, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.27.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-11 has ionization smoke detection which alarms in the main control room. The fire area does not have automatic suppression due to the nature of the electrical equipment in the area. However, a manual hose station and portable fire extinguishers are located nearby.
 
Deviation Request No. 15 further addresses the lack of an automatic suppression system in this fire area.
 
6.2.27.5  Consequences of a Fire in Fire Area CS-11
 
In the event of a fire in Fire Area CS-11, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-11 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.27.5.1  Fire 0-28A U2 Div II Equipment Room
 
There are no Category I components located in Fire Zone 0-28A-I.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28A-I is addressed in Deviation Requests 6 and 15.
In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-83 6.2.27.6  Special Features There are no special features in Fire Area CS-11. There are no manual actions required in this
 
fire area.
 
6.2.27.7  Deviation Requests Affecting Fire Area CS-11 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-11.
 
6.2.28  Fire Area CS-12
 
6.2.28.1  General Description
 
Fire Area CS-12 is the Unit 2 Division I 125V Battery Room located on elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-12. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.28.2  Fire Zones The following fire zone is located in Fire Area CS-12:
Fire Zone  Description 0-28C U2 Div I 125V Battery Room 6.2.28.3  Combustible Loading The combustible loading in Fire Area CS-12 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell material. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire
 
area. The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-12 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.28.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-12 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
6.2.28.5  Consequences of a Fire in Fire Area
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-84 In the event of a fire in Fire Area CS-12, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-12 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.28.5.1  Fire Zone 0-28C - U2 Div I 125V Battery Room There are no Category I components located in Fire Zone 0-28C.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28C is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
6.2.28.6  Special Features
 
There are no special features in Fire Area CS-12. There are no manual actions required.
 
6.2.28.7  Deviation Requests Affecting Fire Area CS-12 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-12.
 
6.2.29  Fire Area CS-13
 
6.2.29.1  General Description
 
Fire Area CS-13 is the Unit 2 Division II 125V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area CS-13. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.29.2  Fire Zones The following fire zone is located in Fire Area CS-13:
Fire Zone  Description 0-28E U2 Div II 125V Battery Room 6.2.29.3  Combustible Loading
 
The combustible loading in Fire Area CS-13 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell materials. There is no mechanical equipment (i.e., pumps, valves, etc.) in this
 
fire area.
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-85 barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) in Fire Area CS-13 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.29.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-13 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.29.5  Consequences of a Fire in Fire Area CS-13 In the event of a fire in Fire Area CS-13, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-13 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.29.5.1  Fire Zone 0-28E - U2 Div II 125V Battery Room There are no Category I components located in Fire 0-28E.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28E is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
6.2.29.6  Special Features
 
There are no special features in Fire Area CS-13. There are no manual actions required.
 
6.2.29.7  Deviation Requests Affecting Fire Area CS-13 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-13.
 
6.2.30  Fire Area CS-14 6.2.30.1  General Description Fire Area CS-14 is the Unit 2 Division II 250V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area CS-14. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-86 6.2.30.2  Fire Zones The following fire zone is located in Fire Area CS-14:
 
Fire Zone  Description 0-28G U2 Div II 250V Battery Room 6.2.30.3  Combustible Loading
 
The combustible loading in Fire Area CS-14 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell materials. There is no mechanical equipment (i.e.,  pumps, valves, etc.) in this
 
fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-14 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.30.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-14 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.30.5  Consequences of a Fire in Fire Area CS-14 In the event of a fire in Fire Area CS-14, a Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-14 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown is detailed below.
 
6.2.30.5.1  Fire Zone 0-28G - U2 Div II 250V Battery Room
 
There are no Category I components located in Fire Zone 0-28G.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28G is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
6.2.30.6  Special Features
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-87 There are no special features in Fire Area CS-14. There are no manual actions required.
 
6.2.30.7  Deviation Requests Affecting Fire Area CS-14
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-14.
6.2.31  Fire Area CS-15 
 
6.2.31.1  General Description Fire Area CS-15 is the Cold Instrument Repair Shop located on Elevation 771'-0" of the control structure. The location of this Fire Area is shown on Drawing E-205993 in Section 8.0. Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area CS-15. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.31.2  Fire Zones The following fire zone is located in Fire Area CS-15:
 
Fire Zone  Description 0-28H  Cold Instrument Repair Shop 6.2.31.3  Combustible Loading
 
There are minimal combustibles in this fire area. All cables in this area are in conduits and those conduits with safe shutdown cables are protected with fire wrapping material as required.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) in Fire Area CS-15 are addressed in Deviation Request 6 and 8, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.31.4  Fire Detection/Suppression in the Fire Area This fire area has ionization smoke detectors. Manual hose reels and portable fire extinguishers are also located nearby.
 
6.2.31.5  Consequences of a Fire in Fire Area CS-15
 
In the event of a fire in Fire Area CS-15, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-15 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-88 6.2.31.5.1  Fire Zone 0-28H - Cold Instrument Repair Shop
 
There are no Category I components located in Fire Zone 0-28H.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28H is addressed in Deviation Requests 6 and 8.
In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.31.6  Special Features The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-28H result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping the Motor-Generator set supply breaker 1A10110 and/or 1A10210.
: 2. Should a fire in Fire Zone 0-28H result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator set supply breaker 2A10110 and/or 2A10210.
 
6.2.31.7  Deviation Requests Affecting Fire Area CS-15
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-15.
6.2.32  Fire Area CS-16
 
6.2.32.1  General Description
 
Fire Area CS-16 is the Unit 1 Division II 250V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0. Safe Shutdown Path 1 is available for use in the event of a fire in Fire Area CS-16. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.32.2  Fire Zones The following fire zone is located Fire Area CS-16: 
 
Fire Zone  Description 0-28J U1 Div II 250V Battery Room
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-89 6.2.32.3  Combustible Loading The combustible loading in Fire Area CS-16 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell materials. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-16 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.32.4  Fire Detection/Suppression in the Fire Area Fire Area CS-16 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.32.5  Consequences of a Fire in Fire Area CS-16
 
In the event of a fire in Fire Area CS-16, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-16 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
6.2.32.5.1  Fire Zone 0-28J - U1 Div II 250V Battery Room
 
There are no Category I components located in Fire Zone 0-28J.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28J is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.32.6  Special Features
 
There are no special features in Fire Area CS-16. There are no manual actions required.
 
6.2.32.7  Deviation Requests Affecting Fire Area CS-16 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-16.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-90 6.2.33  Fire Area CS-17 6.2.33.1  General Description
 
Fire Area CS-17 is the Unit 1 Equipment Room which contains Division II load centers, battery chargers and distribution panels. It is located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0. Safe Shutdown Path 1 is available for use in the event of a fire in Fire Area CS-17. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.33.2  Fire Zones
 
The following fire zone is located in Fire Area CS-17:
 
Fire Zone  Description 0-28B-I U1 Div II Equipment Room 6.2.33.3  Combustible Loading
 
The combustible loading is relatively low in this fire area and any fire initiated within the fire area would be contained by the construction of the fire area boundary. The principle combustibles in this area are cables in electrical panels. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-17 are addressed in Deviation Requests 6 and 8, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.33.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-17 has ionization smoke detection which alarms in the main control room. The fire area does not have automatic suppression due to the nature of the electrical equipment in the area. However, a manual hose station and portable fire extinguishers are located in the vicinity.
Deviation Request No. 8 further addresses the lack of an automatic fire suppression system in this fire area.
 
6.2.33.5  Consequences of a Fire in Fire Area CS-17
 
In the event of a fire in Fire Area CS-17, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-17 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-91 6.2.33.5.1  Fire Zone 0-28B-I - U1 Div II Equipment Room
 
There are no Category I components located in Fire Zone 0-28B-I.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28B-I is addressed in Deviation Requests 6 and 8.
In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.33.6  Special Features There are no special features in Fire Area CS-17. There are no manual actions required.
 
6.2.33.7  Deviation Requests Affecting Fire Area CS-17 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-17.
 
6.2.34  Fire Area CS-18
 
6.2.34.1  General Description
 
Fire Area CS-18 is the Unit 1 Division II 125V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 1 is available for use in the event of a fire in Fire Area CS-18. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.34.2  Fire Zones
 
The following fire zone is located in Fire Area CS-18:
 
Fire Zone  Description 0-28M U1 Div II 125V Battery Room 6.2.34.3  Combustible Loading The combustible loading in Fire Area CS-18 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell materials. There is no mechanical equipment (i.e., pumps, valves, etc.) in this
 
fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-18 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-92 6.2.34.4  Fire Detection/Suppression in the Fire Area Fire Area CS-18 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.34.5  Consequences of a Fire in Fire Area CS-18
 
In the event of a fire in Fire Area CS-18, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-18 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
6.2.34.5.1  Fire Zone 0-28M - U1 Div II 125V Battery Room
 
There are no Category I components located in Fire Zone 0-28M.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28M is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.34.6  Special Features There are no special features in Fire Area CS-18. There are no manual actions required
 
6.2.34.7  Deviation Requests Affecting Fire Area CS-18 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-18.
 
6.2.35  Fire Area CS-19
 
6.2.35.1  General Description
 
Fire Area CS-19 is the Unit 1 Division II 125V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 1 is available for use in the event of a fire in Fire Area CS-19. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.35.2  Fire Zones
 
The following fire zone is located in Fire Area CS-19:
 
Fire Zone  Description 0-28N U1 Div II 125V Battery Room
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-93 6.2.35.3  Combustible Loading The combustible loading in Fire Area CS-19 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell materials. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-19 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.35.4  Fire Detection/Suppression in the Fire Area Fire Area CS-19 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.35.5  Consequences of a Fire in Fire Area CS-19
 
In the event of a fire in Fire Area CS-19, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-19 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
6.2.35.5.1  Fire Zone 0-28N - U1 Div II 125V Battery Room
 
There are no Category I components located in Fire Zone 0-28N.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28N is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.35.6  Special Features
 
There are no special features in Fire Area CS-19. There are no manual actions required.
 
6.2.35.7  Deviation Requests Affecting Fire Area CS-19 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-19.
 
6.2.36  Fire Area CS-20 SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-94 6.2.36.1  General Description
 
Fire Area CS-20 is the Unit 2 Equipment Room which contains Division I load centers, battery chargers and distribution panels. It is located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0. Safe Shutdown Path 3 is available for use in the event of a fire in Fire Area CS-20. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.36.2  Fire Zones The following fire zone is located in Fire Area CS-20:
 
Fire Zone  Description 0-28A-II U2 Div I Equipment Room 6.2.36.3  Combustible Loading
 
The combustible loading is relatively low in this fire area and any fire initiated within the fire area would be contained by the construction of the fire area boundary. The principle combustibles in this area are cables in electrical panels. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-20 are addressed in Deviation Requests 6 and 15, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
6.2.36.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-20 has ionization smoke detection which alarms in the main control room. The fire area does not have automatic suppression due to the nature of the electrical equipment in the area. However, a manual hose station and portable fire extinguishers are located nearby.
 
Deviation Request No. 15 further addresses the lack of an automatic suppression system in this
 
fire area.
 
6.2.36.5  Consequences of a Fire in Fire Area CS-20
 
In the event of a fire in Fire Area CS-20, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-20 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-95 6.2.36.5.1  Fire Zone 0-28A-II - U2 Div I Equipment Room
 
The following Category I components are located in Fire Zone 0-28A-II:
 
- 125V DC Distribution Panels (2D624 and 2D644) - This 125 VDC Electrical Distribution Panel is enclosed in a 1 hour rated fire barrier.
- Core Spray System and HPCI Relay Logic (2D624 Breaker 01) - This sub-fused circuit is contained within 2D624 which is enclosed in a 1 hour rated fire barrier.
- RCIC and RHR Relay Logic, HPCI Control Power (2D624 Breaker 06) - This sub-fused circuit is contained within 2D624 which is enclosed in a 1 hour rated fire barrier.
- ADS Relay Logic, ADS Valves, Backup SCRAM Valve (2D624 Breaker 11) - This sub-fused circuit is contained within 2D624 which is enclosed in a 1 hour rated fire barrier.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28A-II is addressed in Deviation Requests 6 and 15.
In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
6.2.36.6  Special Features
 
The following manual action may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-28A-II result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator set supply breaker 2A10110 and/or 2A10210.
 
6.2.36.7  Deviation Requests Affecting Fire Area CS-20
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-20.
 
6.2.37  Fire Area CS-21 6.2.37.1  General Description Fire Area CS-21 is the Unit 2 Division I 125V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-21.
Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.37.2  Fire Zones
 
The following fire zone is located in Fire Area CS-21:
Fire Zone  Description 0-28T U2 Div I 125V Battery Room SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-96 6.2.37.3  Combustible Loading
 
The combustible loading in Fire Area CS-21 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell materials. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-21 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
6.2.37.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-21 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.37.5  Consequences of a fire in Fire Area CS-21 In the event of a fire in Fire Area CS-21, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-21 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.37.5.1  Fire Zone 0-28T - U2 Div I 125V Battery Room
 
There are no Category I components located in Fire Zone 0-28T.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28T is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.37.6  Special Features There are no special features in Fire Area CS-21. There are no manual actions required.
 
6.2.37.7  Deviation Requests Affecting Fire Area  CS-21
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-21.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-97 6.2.38  Fire Area CS-22 6.2.38.1  General Description
 
Fire Area CS-22 is the Unit 2 Division II 125V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0. Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area CS-22.
Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.38.2  Fire Zones The following fire zone is located in Fire Area CS-22:
 
Fire Zone  Description 0-28D U2 Div II 125V Battery Room 6.2.38.3  Combustible Loading
 
The combustible loading in Fire Area CS-22 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell material. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-22 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
6.2.38.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-22 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.38.5  Consequences of a Fire in Fire Area CS-22
 
In the event of a fire in Fire Area CS-22, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-22  associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-98 6.2.38.5.1  Fire Zone 0-28D - U2 Div II 125V Battery Room There are no Category I components located in Fire Zone 0-28D.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28D is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.38.6  Special Features
 
There are no special features in Fire Area CS-22. There are no manual actions required.
 
6.2.38.7  Deviation Requests Affecting Fire Area CS-22
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-22.
6.2.39  Fire Area CS-23
 
6.2.39.1  General Description Fire Area CS-23 is the Unit 2 Division I 250V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-23.
Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.39.2  Fire Zones
 
The following fire zone is located in Fire Area CS-23:
 
Fire Zone  Description 0-28F U2 Div I 250V Battery Room 6.2.39.3  Combustible Loading
 
The combustible loading in Fire Area CS-23 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell material. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire
 
area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-23 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.39.4  Fire Detection/Suppression in the Fire Area SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-99 Fire Area CS-23 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
6.2.39.5  Consequences of a Fire in Fire Area CS-23
 
In the event of a fire in Fire Area CS-23, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-23 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.39.5.1  Fire Zone 0-28F - U2 Div I 250V Battery Room There are no Category I components located in Fire Zone 0-28F.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28F is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.39.6  Special Features
 
The following manual action may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-28F result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator set supply breaker 2A10110 and/or 2A10210, 6.2.39.7  Deviation Requests Affecting Fire Area CS-23
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-23.
6.2.40  Fire Area CS-24
 
6.2.40.1  General Description
 
Fire Area CS-24 is the Unit 1 Equipment Room which contains Division I load centers, battery chargers and distribution panels. It is located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0. Safe Shutdown Path 3 is available for use in the event of a fire in Fire Area CS-24. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.40.2  Fire Zones
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-100 The following fire zone is located in Fire Area CS-24:
Fire Zone  Description 0-28-B-11 U1 Div I Equipment Room 6.2.40.3  Combustible Loading The combustible loading is relatively low in this fire area and any fire initiated within the fire area would be contained by the construction of the fire area boundary. The principle combustibles in this area are cables in electrical panels. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-24 are addressed in Deviation Requests 6 and 8, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.40.4  Fire Detection/Suppression in the Fire Area Fire Area CS-24 has ionization smoke detection which alarms in the main control room. The fire area does not have automatic suppression due to the nature of the electrical equipment in the area. However, a manual hose station and portable fire extinguishers are located nearby.
Deviation Request No. 8 further addresses the lack of an automatic fire suppression system in this fire area.
 
6.2.40.5  Consequences of a Fire in Fire Area CS-24 In the event of a fire in Fire Area CS-24, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-24 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.40.5.1  Fire Zone 0-28B-II - U1 Div I Equipment Room
 
The following Category I components are located in Fire Zone 0-28B-II:
- 125V DC Distribution Panels (1D624 and 1D644) - This 125 VDC Electrical Distribution Panel is enclosed in a 1 hour rated fire barrier.
- 125V DC Distribution Panels (1D625 and 1D645) - This component is required for offsite power. Offsite power is not used for shutdown in Fire Area CS-24.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-101 - Core Spray System and HPCI Relay Logic (1D624 Breaker 01) - This sub-fused circuit is contained within 1D624 which is enclosed in a 1 hour rated fire barrier.
- RCIC and RHR Relay Logic, HPCI Control Power (1D624 Breaker 06) - This sub-fused circuit is contained within 1D624 which is enclosed in a 1 hour rated fire barrier.
- ADS Relay Logic, ADS Valves, Backup SCRAM Valve (1D624 Breaker 11) - This sub-fused circuit is contained within 1D624 which is enclosed in a 1 hour rated fire barrier.
 
- 4.16 KV Bus 1A202 Breaker Control (1D624 Breaker 34) - This sub-fused circuit is contained within 1D624 which is enclosed in a 1 hour rated fire barrier.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28B-II is addressed in Deviation Requests 6 and 8.
In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
6.2.40.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-28B-II result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping the Motor-Generator set supply breaker 1A10110 and/or 1A10210.
6.2.40.7  Deviation Requests Affecting Fire Area CS-24 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-24.
 
6.2.41  Fire Area CS-25 6.2.41.1  General Description Fire Area CS-25 is the Unit 1 Division I 250V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 3 is available for use in the event of a fire in Fire Area CS-25. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.41.2  Fire Zones
 
The following fire zone is located in Fire Area Area CS-25:
Fire Zone  Description 0-28I U1 Div I 250V Battery Room 6.2.41.3  Combustible Loading
 
The combustible loading in Fire Area CS-25 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-102 the battery cell material. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-25 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.41.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-25 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.41.5  Consequences of a Fire in Fire Area CS-25 In the event of a fire in Fire Area CS-25, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-25 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.41.5.1  Fire Zone 0-28I - U1 Div I 250V Battery Room
 
There are no Category I components located in Fire Zone 0-28I.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28I is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
6.2.41.6  Special Features
 
The following manual action may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-28 I result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping the Motor-Generator set supply breaker 1A10110 and/or 1A10210.
 
6.2.41.7  Deviation Requests Affecting Fire Area CS-25
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-25.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-103 6.2.42  Fire Area CS-26 6.2.42.1  General Description
 
Fire Area CS-26 is the Unit 1 Division I 125V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0. Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-26.
Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.42.2  Fire Zones The following fire zone is located in Fire Area CS-26:
 
Fire Zone  Description 0-28K U1 Div I 125V Battery Room 6.2.42.3  Combustible Loading
 
The combustible loading in Fire Area CS-26 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables battery cell material. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-26 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
6.2.42.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-26 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.42.5  Consequences of a Fire in Fire Area CS-26
 
In the event of a fire in Fire Area CS-26, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS- 26 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-104 6.2.42.5.1  Fire Zone 0-28K - U1 Div I 125V Battery Room There are no Category I components located in Fire Zone 0-28K.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28K is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.42.6  Special Features
 
There are no special features in Fire Area CS-26. There are no manual actions required.
 
6.2.42.7  Deviation Requests Affecting Fire Area CS-26
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-26.
6.2.43  Fire Area CS-27
 
6.2.43.1  General Description Fire Area CS-27 is the Unit 1 Division I 125V Battery Room located on Elevation 771'-0" of the control structure. The location of this fire area is shown on Drawing E-205993 in Section 8.0.
Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-27.
Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.43.2  Fire Zones
 
The following fire zone is located in Fire Area CS-27:
 
Fire Zone  Description 0-28L U1 Div I 125V Battery Room 6.2.43.3  Combustible Loading
 
The combustible loading in Fire Area CS-27 is well below the fire barrier rating of the fire area boundary. The principle contributors to the combustible loading in this fire area are cables and the battery cell material. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire
 
area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area CS-27 are addressed in Deviation Request 6, as well as, by some fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-105 6.2.43.4  Fire Detection/Suppression in the Fire Area Fire Area CS-27 is equipped with ionization smoke detection which alarms in the main control room. The fire area does not have an automatic suppression system due to the nature of the electrical equipment in the room. However, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.43.5  Consequences of a Fire in Fire Area CS-27
 
In the event of a fire in Fire Area CS-27, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-27 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
6.2.43.5.1  Fire Zone 0-28L - U1 Div I 125V Battery Room
 
There are no Category I components located in Fire Zone 0-28L.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-28L is addressed in Deviation Request 6. In addition, the fire hazards analysis identified on Drawing E-205993 in Section 8.0 affects the combustible configuration in this fire zone.
 
6.2.43.6  Special Features There are no special features in Fire Area CS-27. There are no manual actions required.
 
6.2.43.7  Deviation Requests Affecting Fire Area CS-27 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-27.
 
6.2.44  Fire Area CS-28
 
6.2.44.1  General Description
 
Fire Area CS-28 is the Unit 1 Lower Relay Room located on Elevation 698'-0" of the control structure. This fire area is a single room fire zone which primarily contains Division II equipment. The location of this fire area is shown on Drawing E-205988 in Section 8.0. Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area CS-28. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.44.2  Fire Zones
 
The following fire zone is located in Fire Area CS-28:
Fire Zone  Description 0-24D U1 Div II Lower Relay Room SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-106 6.2.44.3  Combustible Loading
 
Fire Zone 0-24D is its own Fire Area CS-28. The principle combustibles in Fire Zone 0-24D are cables located in electrical panels and underfloor ducts and a limited amount of non-metallic PGCC floor paneling. There is no mechanical equipment (i.e. pumps, valves, etc.) in Fire Zone 0-24D. Fire Zone 0-24D is constructed in a manner that is similar to the PGCC design originally supplied by General Electric and described in the GE Fire Hazards Analysis in Licensing Topical Report NEDO 10466A dated February 1979. This NEDO Document describes the separation of Class 1E systems in the floor with 3/16" steel barriers, utilization of semi-permanent fire stop material, provision of heat detectors in the PGCC flooring and rooms and unitized halon system in the PGCC underfloor. Based on these characteristics the NEDO Document provides a reasonable basis for excluding the cable insulation in the PGCC underfloor area from the combustible loading for this fire zone. Due to a difference in the amount of non-metallic floor paneling used in Fire Zone 0-24D as compared to the NEDO Document, the cable insulation in the underfloor area has been included in the combustible loading analysis for Fire Zone 0-24D. Additional fire suppression beyond that discussed in the NEDO Document is provided in Fire Zone 0-24D. Fire Zone 0-24D includes a CO 2 automatic total room flooding system. This additional fire suppression is available to rapidly extinguish any fire that might originate in Fire
 
Zone 0-24D. 
 
The fire area boundaries are adequate to contain the effects of any fire originating in Fire Zone 0-24D. The level of combustible in Fire Zone 0-24D, including the contribution from the underfloor cable insulation in the PGCC floor and the non-metallic PGCC floor paneling, is maintained to assure that the total combustible loading does not exceed the fire resistance rating for the boundaries of Fire Area CS-28. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.44.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-28 is equipped with ionization detectors and heat detectors. The fire area has a halon extinguishing system located in the PGCC modules which protect the safety related cabinets with the exception of panels 1C636 and 1C699B. The room is also equipped with an automatic total flooding CO 2 system. In addition, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.44.5  Consequences of a Fire in Fire Area CS-28 In the event of a fire in Fire Area CS-28, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-28 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.44.5.1  Fire Zone 0-24D - U1 Div II Lower Relay Room
 
The following Category I components are located in Fire Zone 0-24D:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-107 - Unit 1 HPCI Division II Automatic Actuation Logic - This component is the automatic initiation logic for the HPCI System. Automatic initiation of safety systems in support of post-fire safe shutdown is not required. The automatic initiation logic is evaluated for the potential affects of a spurious initiation of the system. A fire induced spurious start of the HPCI System in conjunction with the loss of the HPCI high water level trip in Fire Area CS-28 can be mitigated by closing the HPCI Inboard Steam Supply Isolation Valve (HV-E41-1F002).
- Unit 1 RCIC Division II Automatic Actuation Logic - This component is the automatic initiation logic for the RCIC System. Automatic initiation of safety systems in support of post-fire safe shutdown is not required. The automatic initiation logic is evaluated for the potential affects of a spurious initiation of the system. A fire induced spurious start of the RCIC System in conjunction with the loss of the RCIC high water level trip in Fire Area CS-28 can be mitigated by closing the RCIC Outboard Steam Line Isolation Valve (HV-
 
E51-1F008).
6.2.44.6  Special Features The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-24D result in loss of Unit 1 reactor scram capability and/or scram discharge volume isolation capability from the Control Room, scram Unit 1 and isolate the scram discharge volume by manually venting the instrument air header in the
 
Unit 1 Reactor Building.
: 2. Should a fire in Fire Zone 0-24D result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B from the Control Room.
: 3. Should a fire in Fire Zone 0-24D result in spurious Unit 1 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 1 Division I ADS and to inject water into the reactor using Unit 1 Division I Core Spray remains available from the Control Room.
: 4. Should a fire in Fire Zone 0-24D spuriously open the Unit 1 RHR Injection Isolation Valve HV-151-F015A, close the RHR Injection Control Valve HV-151-F017A from the Control Room.
: 5. Should a fire in Fire Zone 0-24D result in Unit 1 HPCI spuriously starting while disabling the 54" high water level trip, manually take control of HPCI from the Control Room or close the HPCI Turbine Steam Supply Inboard Isolation Valve HV-155-F002.
: 6. Should a fire in Fire Zone 0-24D result in loss of the Unit 2 RHR Pump 2P202A start capability from the Control Room, initiate RHR Pump 2P202A operation from the Unit 2 Remote Shutdown Panel and open the RHR Loop A Return Valve to Suppression Pool HV-251-F024A.
 
6.2.44.7  Deviation Requests Affecting Fire Area CS-28
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-28.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-108 6.2.45  Fire Area CS-29
 
6.2.45.1  General Description Fire Area CS-29 is the Unit 2 Division II Lower Cable Spreading Room at Elevation 714'-0" of the control structure. Its location is shown on Drawing E-205989 in Section 8.0. Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area CS-29. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.45.2  Fire Zones
 
The following fire zone is located in Fire Area CS-29:
 
Fire Zone  Description 0-25A U2 Div II Lower Cable Spreading Room 6.2.45.3  Combustible Loading
 
The principle combustibles in Fire Area CS-29 are cables in cable tray. The combustible loading in this area is bounded by the construction of the fire area boundary. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.45.4  Fire Detection/Suppression in the Fire Area Fire Area CS-29 is equipped with ionization type smoke detectors and heat detectors. The entire area is covered by a pre-action sprinkler system. Manual hose reels and portable fire extinguishers are located nearby.
 
6.2.45.5  Consequences of a Fire in Fire Area CS-29 In the event of a fire in Fire Area CS-29, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-29 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.45.5.1  Fire Zone 0-25A - U2 Div II Lower Cable Spreading Room
 
There are no Category I components located in Fire Zone 0-25A.
 
6.2.45.6  Special Features The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-109 1. Should a fire in Fire Zone 0-25A result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator set supply breaker 2A10110 and/or 2A10210.
: 2. Should a fire in Fire Zone 0-25A result in spurious Unit 2 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 2 Division I ADS and to inject water into the reactor using Unit 2 Division I Core Spray remains available from the Control Room.
: 3. Should a fire in Fire Zone 0-25A result in Unit 2 HPCI spuriously starting while disabling the 54" high water level trip, manually take control of HPCI from the Control Room or close the HPCI Turbine Steam Supply Inboard Isolation Valve HV-255-F002.
 
6.2.45.7  Deviation Requests Affecting Fire Area CS-29
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-29.
6.2.46  Fire Area CS-30
 
6.2.46.1  General Description Fire Area CS-30 is the Unit 1 Division II Lower Cable Spreading Room at Elevation 714'-0" of the control structure. Its location is shown on Drawing E-205989 in Section 8.0. Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area CS-30. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.46.2  Fire Zones
 
The following fire zone is located in Fire Area CS-30:
 
Fire Zone  Description 0-25E U1 Div II Lower Cable Spreading Room 6.2.46.3  Combustible Loading
 
The principle combustibles in Fire Area CS-30 are cables in cable tray. The combustible loading in this area is bounded by the construction of the fire area boundary. There is no mechanical equipment (i.e., pumps, valves, etc.) in this fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.46.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-30 is equipped with ionization type smoke detectors and heat detectors. The combustibles in the area are covered by a pre-action sprinkler system. Manual hose reels and portable fire extinguishers are located nearby.
 
6.2.46.5  Consequences of a Fire in Fire Area CS-30
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-110 In the event of a fire in Fire Area CS-30, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-30 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.46.5.1  Fire Zone 0-25E - U1 Div II Lower Cable Spreading Room There are no Category I components located in Fire Zone 0-25E.
 
6.2.46.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-25E result in loss of Unit 1 reactor scram capability and/or scram discharge volume isolation capability from the Control Room, scram Unit 1 and isolate the scram discharge volume by manually venting the instrument air header in the
 
Unit 1 Reactor Building.
: 2. Should a fire in Fire Zone 0-25E result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping the Motor-Generator set output breakers.
: 3. Should a fire in Fire Zone 0-25E result in Unit 1 HPCI spuriously starting while disabling the 54" high water level trip, manually take control of HPCI from the Control Room or close the HPCI Turbine Steam Supply Inboard Isolation Valve HV-155-F002.
: 4. Should a fire in Fire Zone 0-25E spuriously open the Unit 1 RHR Injection Isolation Valve HV-151-F015A, close the RHR Injection Control Valve HV-151-F017A from the Control Room.
6.2.46.7  Deviation Requests Affecting Fire Area CS-30
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-30.
6.2.47  Fire Area CS-31
 
6.2.47.1  General Description
 
Fire Area CS-31 is the Unit 2 Upper Relay Room located on Elevation 754'-0" of the control structure. This fire area is a single room fire zone which primarily contains Division I equipment. The location of this fire area is shown on Drawing E-205992 in Section 8.0. Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-31. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.47.2  Fire Zones
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-111 The following fire zone is located in Fire Area CS-31:
Fire Zone  Description 0-27A U2 Div I Upper Relay Room 6.2.47.3  Combustible Loading Fire Zone 0-27A is its own Fire Area CS-31. The principle combustibles in Fire Zone 0-27A are cables located in electrical panels and underfloor ducts and a limited amount of non-metallic PGCC floor paneling. There is no mechanical equipment (i.e. pumps, valves, etc.) in Fire Zone 0-27A. Fire Zone 0-27A is constructed in a manner that is similar to the PGCC design originally supplied by General Electric and described in the GE Fire Hazards Analysis in Licensing Topical Report NEDO 10466A dated February 1979. This NEDO Document describes the separation of Class 1E systems in the floor with 3/16" steel barriers, utilization of semi-permanent fire stop material, provision of heat detectors in the PGCC flooring and rooms and unitized halon system in the PGCC underfloor. Based on these characteristics the NEDO Document provides a reasonable basis for excluding the cable insulation in the PGCC underfloor area from the combustible loading for this fire zone. Due to a difference in the amount of non-metallic floor paneling used in Fire Zone 0-27A as compared to the NEDO Document, the cable insulation in the underfloor area has been included in the combustible loading analysis for Fire Zone 0-27A.
Additional fire suppression beyond that discussed in the NEDO Document is provided in Fire Zone 0-27A. Fire Zone 0-27A includes a CO 2 automatic total room flooding system. This additional fire suppression is available to rapidly extinguish any fire that might originate in Fire
 
Zone 0-27A. 
 
The fire area boundaries are adequate to contain the effects of any fire originating in Fire Zone 0-27A. The level of combustible in Fire Zone 0-27A, including the contribution from the underfloor cable insulation in the PGCC floor and the non-metallic PGCC floor paneling, is maintained to assure that the total combustible loading does not exceed the fire resistance rating for the boundaries of Fire Area CS-31.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27A is affected by the fire hazards analysis referenced on the drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.47.4  Fire Detection/Suppression in the Fire Area Fire Area CS-31 is equipped with ionization detectors and heat detectors. The fire area has a halon extinguishing system located in the PGCC modules which protect the safety related cabinets with the exception of panels 2C635 and 2C699A. The room is also equipped with an automatic total flooding CO 2 system. In addition, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.47.5  Consequences of a Fire in Fire Area CS-31
 
In the event of a fire in Fire Area CS-31, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-31 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-112 its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.47.5.1  Fire Zone 0-27A - U2 Div I Upper Relay Room The following Category I components are located in Fire Zone 0-27A:
- Unit 2 HPCI Division I Automatic Actuation Logic - This component is the automatic initiation logic for the HPCI System. Automatic initiation of safety systems in support of post-fire safe shutdown is not required. The automatic initiation logic is evaluated for the potential affects of a spurious initiation of the system. A fire induced spurious start of the HPCI System in conjunction with the loss of the HPCI high water level trip in Fire Area CS-31 can be mitigated by manually tripping HPCI from the Control Room.
  - Unit 2 RCIC Division I Automatic Actuation Logic - This component is the automatic initiation logic for the RCIC System. Automatic initiation of safety systems in support of post-fire safe shutdown is not required. The automatic initiation logic is evaluated for the potential affects of a spurious initiation of the system. A fire induced spurious start of the RCIC System in conjunction with the loss of the RCIC high water level trip in Fire Area CS-31 can be mitigated by closing the RCIC Inboard Steam Supply Isolation Valve (HV-E51-2F007).
 
- Unit 2 RHR Automatic Actuation Logic (Cross Divisional) - This component is the cross divisional unit logic ties within the automatic initiation logic for the RHR System. It consists of the relays for the RHR preferred pump logic and the relays which control the Diesel Generator loading considerations between the same letter pumps on opposite units. Where fire induced damage can inhibit the starting of the required safe shutdown pump for a particular unit, the plant operator will take actions to trip pumps that are not required to be running and to start the required pumps.
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27A is affected by the fire hazards analysis identified
 
on Drawing E-205992 in Section 8.0.
 
6.2.47.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-27A result in loss of Unit 2 reactor scram capability and/or scram discharge volume isolation capability from the Control Room, scram Unit 2 and isolate the scram discharge volume by manually isolating and venting the instrument air header in the Unit 2 Reactor Building.
: 2. Should a fire in Fire Zone 0-27A result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B from the Control Room.
: 3. Should a fire in Fire Zone 0-27A result in spurious Unit 2 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-113 reactor using Unit 2 Division II ADS and to inject water into the reactor using Unit 2 Division II Core Spray remains available from the Control Room.
: 4. Should a fire in Fire Zone 0-27A spuriously open the Unit 2 RHR Injection Isolation Valve HV-251-F015B, close the RHR Injection Control Valve HV-251-F017B from the Control Room. 
: 5. Should a fire in Fire Zone 0-27A result in disabling the low condenser vacuum signal which prevents the Unit 2 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main Steam Line Drains.
 
6.2.47.7  Deviation Requests Affecting Fire Area CS-31
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-31.
 
6.2.48  Fire Area CS-32 6.2.48.1  General Description
 
Fire Area CS-32 is the Unit 2 Division I Upper Cable Spreading Room at Elevation 754'-0" of the control structure. Its location is shown on Drawing E-205992 in Section 8.0. Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-32. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.48.2  Fire Zones The following fire zone is located in Fire Area CS-32:
 
Fire Zone  Description 0-27B U2 Div I Upper Cable Spreading Room 6.2.48.3  Combustible Loading
 
The principle combustibles in Fire Area CS-32 are cables in cable tray. The combustible loading in this area is bounded by the construction of the fire area boundary. There is no mechanical equipment (i.e. pumps, valves, etc.) in this fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27B is affected by the fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
 
6.2.48.4  Fire Detection/Suppression in the Fire Area
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-114 Fire Area CS-32 is equipped with ionization type smoke detectors and heat detectors. The entire area is covered by a pre-action sprinkler system. Manual hose reels and portable fire extinguishers are located nearby.
 
6.2.48.5  Consequences of a Fire in Fire Area CS-32
 
In the event of a fire in Fire Area CS-32, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-32 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
 
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.48.5.1  Fire Zone 0-27B - U2 Div I Upper Cable Spreading Room There are no Category I components located in Fire Zone 0-27B.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27B is affected by the fire hazards analysis identified
 
on Drawing E-205992 in Section 8.0.
6.2.48.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-27B result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator set supply breaker 2A10110 and/or 2A10210.
: 2. Should a fire in Fire Zone 0-27B result in spurious Unit 2 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 2 Division II ADS and to inject water into the reactor using Unit 2 Division II Core Spray remains available from the Control Room.
: 3. Should a fire in Fire Zone 0-27B spuriously open the Unit 2 RHR Injection Isolation Valve HV-251-F015B, close the RHR Injection Control Valve HV-251-F017B from the Control Room. 
: 4. Should a fire in Fire Zone 0-27B result in disabling the low condenser vacuum signal which prevents the Unit 2 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main Steam Line Drains.
 
6.2.48.7  Deviation Requests Affecting Fire Area CS-32
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-32.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-115 6.2.49  Fire Area CS-33 6.2.49.1  General Description
 
Fire Area CS-33 is the Unit 1 Upper Relay Room located on Elevation 754'-0" of the control structure. This fire area is a single room fire zone which primarily contains Division I equipment. The location of this fire area is shown on Drawing E-205992 in Section 8.0. Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area CS-33. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.49.2  Fire Zones
 
The following fire zone is located in Fire Area CS-33:
 
Fire Zone  Description 0-27E U1 Div I Upper Relay Room 6.2.49.3  Combustible Loading
 
Fire Zone 0-27E is its own Fire Area CS-33. The principle combustibles in Fire Zone 0-27E are cables located in electrical panels and underfloor ducts and a limited amount of non-metallic PGCC floor paneling. There is no mechanical equipment (i.e. pumps, valves, etc.) in Fire Zone 0-27E. Fire Zone 0-27E is constructed in a manner that is similar to the PGCC design originally supplied by General Electric and described in the GE Fire Hazards Analysis in Licensing Topical Report NEDO 10466A dated February 1979. This NEDO Document describes the separation of Class 1E systems in the floor with 3/16" steel barriers, utilization of semi-permanent fire stop material, provision of heat detectors in the PGCC flooring and rooms and unitized halon system in the PGCC underfloor. Based on these characteristics the NEDO Document provides a reasonable basis for excluding the cable insulation in the PGCC underfloor area from the combustible loading for this fire zone. Due to a difference in the amount of non-metallic floor paneling used in Fire Zone 0-27E as compared to the NEDO Document, the cable insulation in the underfloor area has been included in the combustible loading analysis for Fire Zone 0-27E. Additional fire suppression beyond that discussed in the NEDO Document is provided in Fire Zone 0-27E. Fire Zone 0-27E includes a CO 2 automatic total room flooding system. This additional fire suppression is available to rapidly extinguish any fire that might originate in Fire
 
Zone 0-27E.
The fire area boundaries are adequate to contain the effects of any fire originating in Fire Zone 0-27E. The level of combustible in Fire Zone 0-27E, including the contribution from the underfloor cable insulation in the PGCC floor and the non-metallic PGCC floor paneling, is maintained to assure that the total combustible loading does not exceed the fire resistance rating for the boundaries of Fire Area CS-33.
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27E is affected by the fire hazards analysis for specific configurations. Any fire zones for which specific fire hazards analysis have been prepared are identified on the drawings contained in Section 8.0 of this document. Any restrictions applicable to a particular fire zone are described in the deviation requests or fire hazards analyses referenced for that fire zone.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-116 6.2.49.4  Fire Detection/Suppression in the Fire Area
 
Fire Area CS-33 is equipped with ionization detectors and heat detectors. The fire area has a halon extinguishing system located in the PGCC modules which protect the safety related cabinets with the exception of panels 2C635 and 2C699A. The room is also equipped with an automatic total flooding CO 2 system. In addition, a manual hose station and portable fire extinguishers are located nearby.
 
6.2.49.5  Consequences of a Fire in Fire Area CS-33
 
In the event of a fire in Fire Area CS-33, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area CS-33 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. This is accomplished using one of the methods outlined in Section 6.1.2.4.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.49.5.1  Fire Zone 0-27E - U1 Div I Upper Relay Room The following Category I components are located in Fire Zone 0-27E:
- Unit 1 HPCI Division I Automatic Actuation Logic - This component is the automatic initiation logic for the HPCI System. Automatic initiation of safety systems in support of post-fire safe shutdown is not required. The automatic initiation logic is evaluated for the potential affects of a spurious initiation of the system. A fire induced spurious start of the HPCI System in conjunction with the loss of the HPCI high water level trip in Fire Area CS-33 can be mitigated by manually tripping HPCI from the Control Room.
 
- Unit 1 RCIC Division I Automatic Actuation Logic - This component is the automatic initiation logic for the RCIC System. Automatic initiation of safety systems in support of post-fire safe shutdown is not required. The automatic initiation logic is evaluated for the potential affects of a spurious initiation of the system. A fire induced spurious start of the RCIC System in conjunction with the loss of the RCIC high water level trip in Fire Area CS-33 can be mitigated by closing the RCIC Inboard Steam Supply Isolation Valve (HV-
 
E51-1F007).
  - Unit 1 RHR Automatic Actuation Logic (Cross Divisional) - This component is the cross divisional unit logic ties within the automatic initiation logic for the RHR System. It consists of the relays for the RHR preferred pump logic and the relays which control the Diesel Generator loading considerations between the same letter pumps on opposite units. Where fire induced damage can inhibit the starting of the required safe shutdown pump for a particular unit, the plant operator will take actions to trip pumps that are not required to be running and to start the required pumps.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-27E is affected by the fire hazards analysis identified on Drawing E-205992 in Section 8.0.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-117 6.2.49.6  Special Features The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-27E result in loss of Unit 1 reactor scram capability and/or scram discharge volume isolation capability from the Control Room, scram Unit 1 and isolate the scram discharge volume by manually venting the instrument air header in the
 
Unit 1 Reactor Building.
: 2. Should a fire in Fire Zone 0-27E result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B from the Control Room.
: 3. Should a fire in Fire Zone 0-27E result in spurious Unit 1 ADS or SRV actuations as indicated by low RPV pressure and/or level, the capability to further depressurize the reactor using Unit 1 Division II ADS and to inject water into the reactor using Unit 1 Division II Core Spray remains available from the Control Room.
: 4. Should a fire in Fire Zone 0-27E spuriously open the Unit 1 RHR Injection Isolation Valve HV-151-F015B, close the RHR Injection Control Valve HV-151-F017B from the Control Room. 5. Should a fire in Fire Zone 0-27E result in disabling the low condenser vacuum signal which prevents the Unit 1 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main
 
Steam Line Drains.
6.2.49.7  Deviation Requests Affecting Fire Area CS-33
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area CS-33.
 
6.2.50  Fire Area D-1
 
6.2.50.1  General Description
 
Fire Area D-1 is Diesel Generator Bay A as shown on Drawings E-206000 through E-206002 in Section 8.0. This area is isolated from all adjacent safety related fire areas by 3-hour fire rated boundaries. Division I systems and equipment are located in Fire Area D-1. Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area D-1. Offsite power sources are credited for Safe Shutdown Path 3 in this fire area, because it has been demonstrated that the fire cannot cause a loss of offsite power and, as such, it will be available for fires in this fire area. As a conservative measure, circuits required for the operation of Diesel Generator D located in this fire area are also protected and assured to be available. In addition, HPCI would be available to provide a source of high pressure make up to the reactor in the event of a fire in this fire area. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.50.2  Fire Zones
 
The following fire zone is located in Fire Area D-1:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-118 Fire Zone  Description 0-41A Diesel Generator Bay A 6.2.50.3  Combustible Loading The principle contributor to combustible loading is lube oil contained in the A diesel generator and fuel oil in its day tank. With a fire area boundary rating of 3-hours, a fire initiated in Fire Area D-1 will remain within the fire area.
 
The fire rating of the fire area is established based on the lowest fire rating for any fire barrier in any fire zone forming a part of the boundary of the fire area. The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of fire
 
zones in Fire Area D-1 are addressed in Deviation Request 19. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.50.4  Fire Detection/Suppression in the Fire Area Automatic fire detection and suppression is provided in the basement (El. 660'-0") and on the ground floor (El. 677'-0") of this fire area. The top floor (El. 710'-9") of this fire area does not contain any required redundant safe shutdown components or cabling and is not provided with automatic suppression. The top floor (El. 710'-9") of this fire area is provided with fire detection. Manual suppression in the form of portable extinguishers is provided throughout the fire area and in the form of a fire hydrant outside of the building. Deviation Request No. 19 further addresses the lack of complete automatic suppression in this fire area.
 
6.2.50.5  Consequences of a Fire in Fire Area In the event of a fire in Fire Area D-1, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Offsite power sources are credited for Safe Shutdown Path 3 in this fire area, because it has been demonstrated that the fire cannot cause a loss of offsite power and, as such, it will be available for fires in this fire area. In addition, HPCI would be available to provide a source of high pressure make up to the reactor in the event of a fire in this fire area. Electrical cabling located in Fire Area D-1 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. Due to the availability of offsite power for fires in this fire area, circuits for the 'B' Diesel Generator located in this fire area are not protected. As a conservative measure, however, circuits required for the operation of Diesel Generator D located in this fire zone are protected and assured to be available. Automatic functions associated with the operation of the HPCI System can be impacted by a fire in this area. The ability to manually operate the HPCI System from the Control Room is assured for fires in this fire area.
 
Also, the Condensate Storage Tank (CST) low level switch circuits can be impacted. The CST low level signal initiates automatic transfer of the HPCI Pump suction from the CST to the Suppression Pool. The fire is assumed to defeat the automatic HPCI Pump transfer logic on low CST level. Sufficient inventory exists in the CST for HPCI operation and completion of its Appendix R function without the need to transfer to the Suppression Pool. CST level recorder LR00812 at panel 0C653 may be available to determine CST level and initiate manual HPCI Pump suction transfer. If CST level recorder LR00812 is not available HPCI Pump suction from SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-119 the CST to the Suppression Pool must be transferred within 8 hours. A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.50.5.1  Fire Zone 0-41A - Diesel Generator Bay A There are no Category I components located in Fire Zone 0-41A.
 
The minimum fire rating of the fire barriers and therefore the equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-41A is addressed in Deviation Request 19.
 
6.2.50.6  Special Features The following manual action may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-41A result in loss of Unit 1 automatic HPCI suction transfer on Condensate Storage Tank low level, manually transfer the Unit 1 HPCI pump suction from the CST to the Suppression Pool.
 
6.2.50.7  Deviation Requests Affecting Fire Area D-1 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area D-1.
 
6.2.51  Fire Area D-2
 
6.2.51.1  General Description
 
Fire Area D-2 is Diesel Generator Bay B as shown on Drawings E-206000 through E-206002 in Section 8.0. This area is isolated from all other fire areas by 3-hour fire rated boundaries.
Division II systems and equipment are located in Fire Area D-2. Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area D-2. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.51.2  Fire Zones
 
The following fire zone is located in Fire Area D-2:
Fire Zone  Description 0-41B Diesel Generator Bay B 6.2.51.3  Combustible Loading The principle contributor to combustible loading is lube oil contained in the B diesel generator and fuel oil in its day tank. With a fire area boundary rating of 3-hours, a fire initiated in Fire Area D-2 will remain within the fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-120 6.2.51.4  Fire Detection/Suppression in the Fire Area Automatic fire detection and suppression is provided in the basement (El. 660'-0") and on the ground floor (El. 677'-0") of this fire area. The top floor (El. 710'-9") of this fire area does not contain any required redundant safe shutdown components or cables and is not provided with automatic suppression. The top floor (El. 710'-9") of this fire area is provided with fire detection. Manual suppression in the form of portable extinguishers is provided throughout the fire area and in the form of a fire hydrant outside of the building.
 
6.2.51.5 Consequences of a Fire in Fire Area D-2
 
In the event of a fire in Fire Area D-2, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area D-2 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
6.2.51.5.1  Fire Zone 0-41B - Diesel Generator Bay B
 
There are no Category I components located in Fire Zone 0-41B.
 
6.2.51.6  Special Features There are no special features in Fire Area D-2. There are no manual actions required.
 
6.2.51.7  Deviation Requests Affecting Fire Area D-2
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area D-2.
 
6.2.52  Fire Area D-3
 
6.2.52.1  General Description
 
Fire Area D-3 is Diesel Generator Bay C as shown on Drawings E-206000 through E-206002 in Section 8.0. This area is isolated from all other fire areas by 3-hour fire rated boundaries.
Division I systems and equipment are located in Fire Area D-3. Safe Shutdown Path 3 would be available for use in the event of a fire in Fire Area D-3. Offsite power sources are credited for Safe Shutdown Path 3 in this Fire Area, because it has been demonstrated that the fire cannot cause a loss of offsite power and, as such, it will be available for fires in this fire area. In addition, HPCI would be available to provide a source of high pressure make up to the reactor in the event of a fire in this fire area. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.52.2  Fire Zones The following fire zone is located in Fire Area D-3:
 
Fire Zone  Description 0-41C Diesel Generator Bay C 6.2.52.3  Combustible Loading SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-121 The average in-situ combustible loading of Fire Area D-3 could exceed the fire area boundary limits. The combustible loading in this diesel bay is significantly higher than the other diesel bays since the lube oil drain tank and the dirty lube oil tank for the diesel generators is located in Fire Area D-3. This condition was described to the NRC in Revision 3 to the FPRR under Deviation Request No. 10. The NRC in an SER dated August 9, 1989 related to Revision 3 of the FPRR determined that this deviation was not required and asked that it be withdrawn.
Deviation Request No. 10 was withdrawn as a part of Revision 4 to the FPRR. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
6.2.52.4  Fire Detection/Suppression in the Fire Area
 
Automatic fire detection and suppression is provided in the basement (El. 660'-0") and on the ground floor (El. 677'-0") of this fire area. The top floor (El. 710'-9") of this fire area does not contain any required redundant safe shutdown components or cables and is not provided with automatic suppression. The top floor (El. 710'-9") of this fire area is provided with fire detection. Manual suppression in the form of portable extinguishers is provided throughout the fire area and in the form of a fire hydrant outside of the building. 
 
6.2.52.5  Consequences of a Fire in Fire Area D-3
 
In the event of a fire in Fire Area D-3, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Offsite power sources are credited for Safe Shutdown Path 3 in this Fire Area, because it has been demonstrated that the fire cannot cause a loss of offsite power and, as such, it will be available for fires in this fire area. In addition, HPCI would be available to provide a source of high pressure make up to the reactor in the event of a fire in this fire area. Electrical cabling located in Fire Area D-3 associated with Path 3 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. Due to the availability of offsite power for fires in this fire area, circuits for the 'B' Diesel Generator located in this fire area are not protected. A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.52.5.1  Fire Zone 0-41C - Diesel Generator Bay C
 
There are no Category I components located in Fire 0-41C.
6.2.52.6  Special Features
 
There are no special features in Fire Area D-3. There are no manual actions required.
 
6.2.52.7  Deviation Requests Affecting Fire Area D-3
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area D-3.
 
6.2.53  Fire Area D-4 6.2.53.1  General Description
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-122 Fire Area D-4 is Diesel Generator Bay D as shown on Drawings E-206000 through E-206002 in Section 8.0. This area is isolated from all other fire areas by 3-hour fire rated boundaries.
Division II systems and equipment are located in Fire Area D-4. Safe Shutdown Path 1 would be available for use in the event of a fire Fire Area D-4. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.53.2  Fire Zones
 
The following fire zone is located in Fire Area D-4:
Fire Zone  Description 0-41D Diesel Generator Bay D 6.2.53.3  Combustible Loading The principle contributor to combustible loading is lube oil contained in the D diesel generator and fuel oil in its day tank. With a fire area boundary rating of 3-hours, a fire initiated in Fire Area D-4 will remain within the fire area. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
6.2.53.4  Fire Detection/Suppression in the Fire Area
 
Automatic fire detection and suppression is provided in the basement (El. 660'-0") and on the ground floor (El. 677'-0") of this fire area. The top floor (El. 710'-9") of this fire area does not contain any required redundant safe shutdown components or cables and is not provided with automatic suppression. The top floor (El. 710'-9") of this fire area is provided with fire detection.
Manual suppression in the form of portable extinguishers is provided throughout the fire area and in the form of a fire hydrant outside of the building.
 
6.2.53.5  Consequences of a Fire in Fire Area D-4
 
In the event of a fire in Fire Area D-4, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area D-4 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.53.5.1  Fire Zone 0-41D - Diesel Generator Bay D
 
There are no Category I components located in Fire Zone 0-41D.
 
6.2.53.6  Special Features There are no special features in Fire Area D-4. There are no manual actions required.
 
6.2.53.7  Deviation Requests Affecting Fire Area D-4
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area D-4.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-123 6.2.54  Fire Area D-5 6.2.54.1  General Description
 
Fire Area D-5 is the Diesel Generator E Building. This structure is remote from the plant power block and stands at least 50 feet from the nearest structure. The general layout of this is shown on Drawings E-213410 through E-213413 in Section 8.0. Safe Shutdown Path 1 and 3 would be available for use in the event of a fire in Fire Area D-5. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.54.2  Fire Zones
 
The following fire zone is located in Fire Area D-5:
 
Fire Zone  Description 0-41E Diesel Generator "E" Building 6.2.54.3  Combustible Loading
 
This fire area is remote from any other structures containing safe shutdown equipment. The principle combustible materials in this fire area are the lube oil and diesel fuel associated with operation of Diesel Generator E. A fire in this area would not propagate to any other fire area at the plant. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
6.2.54.4  Fire Detection/Suppression in the Fire Area
 
Fire Area D-5 has fire detection and automatic suppression provided throughout the area.
Manual suppression in the form of portable extinguishers and hose reels are also available in the fire area.
6.2.54.5  Consequences of a Fire in Fire Area D-5
 
Fire Area D-5 is a separate building from the four original diesels built during plant construction.
This diesel generator is connected to the operating plant through a transfer switching system whenever this diesel is used to replace any one of the four original diesels. The transfer switching system assures that a fault in the cabling system caused by a fire in Fire Area D-5 will result in the isolation of this fire area from the remainder of the plant  Safe Shutdown Path 1 and 3 (depending on which existing diesel this diesel is being substituted for) would be used for safe
 
shutdown.
 
6.2.54.5.1  Fire Zone 0-41E - Diesel Generator "E" Building Diesel Generator "E" may be substituted for any one of the other diesel generators.
 
When not substituted for another diesel generator, the Diesel "E" components are not required for post-fire safe shutdown. Therefore, in this condition, there are no Category I components located in Fire Zone 0-41E.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-124 When Diesel Generator "E" is substituted for one of the other diesel generators, the Diesel Generator "E" components become required components on the safe shutdown path associated with the diesel generator for which Diesel Generator "E" is substituted . In this condition, all Diesel Generator "E" components become Category I components. The post-fire safe shutdown analysis, however, has concluded that a fire in Fire Zone O-41E will have no impact on safe shutdown since the impact for this condition is the same as if the fire were to occur in the diesel generator building for which Diesel Generator "E" is substituted.
 
6.2.54.6  Special Features Fire Area D-5 is the Diesel Generator E Building and is a separate, remote structure from the four original diesel generators. It is connected to the original plant through a transfer switching system whenever the Diesel Generator E is used to replace any of the four original diesel generators.
 
The transfer switching system involves operation of transfer switches on panels located in the Diesel Generator Building and in each of the existing diesel generator buildings. Several of the controls, indications, alarms and computer inputs will be transferred.
 
The transfer switches in the specific transfer panels in the Diesel Generator "E" Facility are used to select the path to the controls of the specific diesel generator to be replaced. The transfer switch at the individual transfer panel in each existing diesel generator building is used to transfer controls of the specific diesel generator to be replaced to Diesel Generator E. These two switches in series provide a double break in the circuits to preclude problems (i.e., a fire) in the Diesel Generator E building from being propagated into any of the other diesel generator
 
circuits.
This same double break principle also applies to the power circuits. There are always two breaks between Diesel Generator E and any of the other four diesel generators.
 
This double isolation provided by the two transfer switches in two different buildings precludes any cable faults from Diesel Generator E from affecting any of the other four diesel generators while Diesel Generator E is not substituted. 
 
Similarly, when Diesel Generator E is substituted for any one of the existing diesel generators, this double-break concept prevents any cable faults from affecting more than the Diesel Generator E. Thus, the other diesel generators are unaffected by faults involving any of these cables for all conditions involving Diesel Generator E (i.e., test mode, not substituted and not running; substituted for an existing diesel generator). There are no manual actions required.
 
6.2.54.7  Deviation Requests Affecting Fire Area D-5
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area D-5.
6.2.55 Fire Area E-1
 
6.2.55.1  General Description Fire Area E-1 is the east side of the Emergency Systems Service Water (ESSW) Pumphouse. This structure is located remotely from the power block at the spray pond. Its layout and fire area boundaries are shown on Drawing E-205998 in Section 8.0. Safe Shutdown Path 3 would SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-125 be available for use in the event of a fire in Fire Area E-1. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.55.2  Fire Zones
 
The following fire zone is located in Fire Area E-1:
 
Fire Zone  Description 0-51 East Side Of ESSW Pumphouse 6.2.55.3  Combustible Loading
 
There are minimal combustibles in this fire area. The principle contributor to the combustible loading in this area is the lube oil in the RHR service water and Emergency Service Water Pump motors. Cables inside electrical panels also contribute to the overall combustible loading. Any fire initiated within this fire area would be contained by the fire area barriers which would prevent propagation of the fire into Fire Area E-2. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.55.4  Fire Detection/Suppression in the Fire Area This fire area has ionization smoke detection but no automatic suppression system. Manual suppression in the form of portable fire extinguishers is provided throughout this fire area and in
 
the form of a fire hydrant outside of the building.
6.2.55.5  Consequences of a Fire in Fire Area E-1
 
In the event of a fire in Fire Area E-1, Safe Shutdown Path 3 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area E-1 associated with Path 3 safe shutdown systems and components has been evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition. A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
 
6.2.55.5.1  Fire Zone 0 East Side Of ESSW Pumphouse There are no Category I components located in Fire Zone 0-51.
 
6.2.55.6  Special Features
 
There are no special features in Fire Area E-1. There are no manual actions required.
 
6.2.55.7  Deviation Requests Affecting Fire Area E-1 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area E-1.
 
6.2.56  Fire Area E-2
 
6.2.56.1  General Description
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-126 Fire Area E-2 is the west side of the Emergency Systems Service Water (ESSW) Pumphouse. This structure is located remotely from the power block at the spray pond. Its layout and fire area boundaries are shown on Drawing E-205998 in Section 8.0. Safe Shutdown Path 1 would be available for use in the event of a fire in Fire Area E-2. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
6.2.56.2  Fire Zones
 
The following fire zone is located in Fire Area E-2:
Fire Zone  Description 0-52 West Side of ESSW Pumphouse 6.2.56.3  Combustible Loading There are minimal combustibles in this fire area. The principle contributor to the combustible loading in this area is the lube oil in the RHR service water and Emergency Service Water Pump motors. Cables inside electrical panels also contribute to the overall combustible loading.
Any fire initiated within this fire area would be contained by the fire area barriers which would prevent propagation of the fire into Fire Area E-1. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.56.4  Fire Detection/Suppression in the Fire Area This fire area has ionization smoke detection but no automatic suppression system. Manual suppression in the form of portable fire extinguishers are provided throughout this fire area and in the form of a fire hydrant outside of the building.
 
6.2.56.5  Consequences of a Fire in Fire Area E-2 In the event of a fire in Fire Area E-2, Safe Shutdown Path 1 systems and components will be available for safe shutdown. Electrical cabling located in Fire Area E-2 associated with Path 1 safe shutdown systems and components has been specifically evaluated to assure that its potential failure would not impact the ability of both reactors to reach a safe shutdown condition.
A description of the effect of a fire on safe shutdown systems by fire zone is detailed below.
6.2.56.5.1  Fire Zone 0 West Side of ESSW Pumphouse
 
There are no Category I components located in Fire Zone 0-52.
 
6.2.56.6  Special Features
 
There are no special features in Fire Area E-2. There are no manual actions required.
 
6.2.56.7  Deviation Requests Affecting Fire Area E-2 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area E-2.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-127 6.2.57  Fire Area T-1 6.2.57.1  General Description
 
Fire Area T-1 is the Unit 1 and Unit 2 Turbine Buildings. Its location is shown on Drawing E-105002 in Section 8.0. An analysis has been performed that considered the effects of a fire in the Turbine Building on the limited amount of Class 1E cable and on adjacent buildings. Safe shutdown Path 1, 2 and 3 would be available for use in the event of a fire in Fire Area T-1.
Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
6.2.57.2  Fire Zones
 
For the safe shutdown analysis, the Turbine Buildings were considered as one fire area.
Although there are various fire zones within the Turbine Buildings, Fire Zone 0-TB was assigned to both buildings for the purpose of the safe shutdown analysis. The analysis for the Turbine Buildings considered the possible effects of a fire on the safe shutdown.
 
The following fire zone is located in Fire Area T-1:
 
Fire Zone  Description 0-TB Unit 1 and 2 Turbine Building 6.2.57.3  Combustible Loading
 
The common walls, doors, and penetrations between the Turbine Building and the Reactor Buildings, the Control Structure and the Radwaste Building, have 3-hour fire rated barriers. The principle combustibles located within the turbine building are lube oil in the six reactor feed pump turbines and their lube oil reservoirs, the two main turbine-generators and their lube oil systems and the hydrogen seal oil systems. Each of these hazards are protected by a fire suppression system. A fire initiated within the turbine building would not propagate to any other fire area outside the turbine building. Any specific Fire Hazard Analyses applicable to the fire zone in this fire area are identified on the Drawings in Section 8.0 and referenced below along with any other combustible restrictions.
 
6.2.57.4  Fire Detection/Suppression in the Fire Area Fire detection and suppression systems are located in the Turbine Building where specific fire hazards warrant. The major combustibles listed above are all protected by automatic suppression systems. Each truck/railroad bay in the Turbine Building are also protected by suppression systems.
 
The Hydrogen Water Chemistry System injects hydrogen into the suction of the reactor feed water pumps. The system has, for protection, hydrogen detectors installed in accordance with NRC approved report EPRI NP-5283-SR-A, "Guidelines for Permanent BWR Hydrogen Water Chemistry Installation-1987 Revision". In addition to the detectors, there are excess flow control devices to protect against a large system leak. Therefore, the system will not affect the safe
 
shutdown capability of the plant.
Manual fire suppression in the form of hose reels and portable fire extinguishers are located throughout the turbine building.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-128 Manual deluge systems are provided for charcoal filters 1F258A, 1F258B, 2F258A, and 2F258B in Unit 1 and Unit 2 Turbine Buildings respectively.
 
6.2.57.5  Consequences of a Fire in Fire Area
 
A study has been performed and has shown that although some safe shutdown equipment is located in the turbine building, the redundancy of the instrumentation, the separation between the equipment of concern and the fire protection methods employed assure safe shutdown
 
capability.
6.2.57.5.1  Fire Zone 0-TB - Unit 1 and 2 Turbine Building
 
The following Category I components are located in Fire Zone 0-TB:
 
- Main Condenser Low Vacuum Switches (PSH-B21-1N056A, PSH-B21-1N056B, PSH-B21-1N056C, PSH-B21-1N056D, PSH-B21-2N056A, PSH-B21-2N056B, PSH-B21-2N056C, PSH-B21-2N056D) - Fire damage to this component can affect the automatic closure of the MSIVs in the event of a loss of condenser vacuum. The plant operator will manually close the MSIVs in the event of a loss of condenser vacuum.
- 13.8 KV Startup Bus 10 (0A103), Startup Bus 20 (0A104), Non-Segmented Bus (0A105, 0A106, 0A107) - This component is required for offsite power. Offsite power is not used for shutdown in Fire Area T-1.
- Appendix R Communication System Jackplate JP1208 - For Paths 1 and 3 JP1208 is not required for communications for a fire in this fire area. For a fire in fire zone 0-TB causing an inadvertent control room evacuation, manual actions 42 and 44 will require an alternative means of communication such as portable radios; plant page or cell phone.  [Note: This latter case is not a design basis fire.
- Appendix R Communication System Jackplate JP1502 - This component is a jackplate for Loop 5 of the Appendix R sound powered communications system. There are no operator actions resulting from a fire in Fire Area T-1 that require the use of this loop of the sound powered communications system. Therefore, this component is not required for post-fire safe shutdown in Fire Area T-1.
 
6.2.57.6  Special Features
 
The following manual actions may be required in the event of a fire in this fire area when the fire damage is in the specific fire zone listed below:
: 1. Should a fire in Fire Zone 0-TB result in loss of Reactor Recirculation Pump 1P401A and/or 1P401B trip capability, trip pump 1P401A and/or 1P401B by manually tripping the Motor-Generator set output breakers.
: 2. Should a fire in Fire Zone 0-TB result in loss of Reactor Recirculation Pump 2P401A and/or 2P401B trip capability, trip pump 2P401A and/or 2P401B by manually tripping the Motor-Generator set output breakers.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-129 3. Should a fire in Fire Zone 0-TB result in disabling the low condenser vacuum signal which prevents the Unit 1 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main
 
Steam Line Drains.
: 4. Should a fire in Fire Zone 0-TB result in disabling the low condenser vacuum signal which prevents the Unit 2 MSIVs from closing on low main condenser vacuum, initiate isolation of the Main Steam Lines from the Control Room and verify isolation of the Main
 
Steam Line Drains.
6.2.57.7  Deviation Requests Affecting Fire Area T-1 Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area T-1.
 
6.2.58  Fire Area W-1 6.2.58.1  General Description Fire Area W-1 is the Radwaste Building. The Radwaste Building is separated from the Turbine Building and Service and Administration Building by walls, doors, and penetrations that have a 3-hour fire rating and does not share any common walls with either the control structure or the reactor building. The general location of the Radwaste Building is shown on Drawing E-105002 in Section 8.0. A fire in the Radwaste Building would have no impact on any of the safe shutdown paths described in Section 3.0. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this
 
fire area.
6.2.58.2  Fire Zones
 
For the safe shutdown analysis, the Radwaste Building was considered as one fire area.
Although there are various fire zones within the Radwaste Building, there are no components or cables in the building that will affect safe shutdown of either reactor unit. The fire hazard analysis for the Radwaste Building considered the possible effects of a fire in the building with respect to potential radioactive releases.
 
6.2.58.3  Combustible Loading Fire Area W-1 is separated from the Turbine Building and the Service and Administration Building by 3-hour fire rated barriers. These fire barriers are sufficient to contain any fire originating in the Radwaste Building and would prevent the propagation of a fire to any other fire area in the plant.
 
6.2.58.4  Fire Detection/Suppression in the Fire Area
 
Fire detection and suppression systems are located in portions of the Radwaste Building.
Additionally, manual hose reels and portable fire extinguishers are provided throughout the fire
 
area.
Manual deluge systems are provided for the following filters listed by fire zone:
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-130 Fire Zone  Description 0-61H  Radwaste Building Vent Charcoal Filter 0F359 6.2.58.5  Consequences of a Fire in Fire Area W-1 Within the Radwaste Building, there is located solid, liquid and gaseous radioactive waste treatment systems. A fire could occur in the main charcoal adsorber beds of the offgas treatment system. The probability of such a fire is rather low, since several factors preclude fire.
The process stream is primarily air at a maximum pressure of 3 psig. Normal flow rate is 40 scfm with a maximum of 300 scfm during startup through over 15 tons of charcoal. No ignition sources are present other than the noble gas decay heat. This heat is removed by 100% redundant air conditioning which maintains the rooms below 65
~~F. Furthermore, the entire train of charcoal adsorber tanks can be isolated at both the inlet and outlet, thus if a fire were to start in a bed it would self-extinguish once the available oxygen was consumed. The charcoal adsorber tanks are constructed of 1-3/16 inch carbon steel and this would act as a barrier to prevent the spread of the fire. The minimum design pressure of the tank is 375 psig at 150 F.
A fire in these charcoal beds might result in the release of some radioactive gases. This accident is analyzed in Subsection 15.7.1.1 of the Final Safety Analysis Report (FSAR) and, as indicated therein, the radiological dose consequences are a small percentage of the guideline values of 10CFR100.
 
A fire could also cause the rupture of a liquid radwaste tank. The tank with the worst radiological consequences selected for this evaluation was the radwaste evaporator concentrate storage tank. The probability of a fire in the immediate area of this tank is rather low since the combustible loading is insignificant. Nonetheless, even if it is that a fire caused the rupture of this tank, the radiological dose consequences would be a small fraction of the guideline values of 10CFR100. An analysis of the radiological consequences for this tank is provided in FSAR
 
Subsection 15.7.3.
 
6.2.58.6  Special Features There are no special features in Fire Area W-1. There are no manual actions required.
 
6.2.58.7  Deviation Requests Affecting Fire Area W-1
 
Section 7.0 provides a complete listing of Deviation Requests that affect Fire Area W-1.
 
6.2.59  Fire Area A-1 6.2.59.1  General Description Fire Area A-1 is the general area outside of the power block. It includes site outside areas, the
 
Cooling Tower, S&A Building, Circulating Water Pumphouse and other miscellaneous site support buildings & facilities. The general arrangement of the plant outside areas is shown on Drawing E-105002 in Section 8.0. Safe Shutdown Path 1 or 3 would be available for use in the event of a fire in Fire Area A-1. Deviation Request 33 that justifies the use of ADS and Core Spray for achieving and maintaining post-fire safe shutdown generically applies to this fire area.
 
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-131 6.2.59.2  Fire Zones The following fire zone is located in Fire Area A-1:
 
Fire Zone  Description 0-00 Outside/Yard Areas 6.2.59.3  Combustible Loading
 
A fire hazard analysis was performed to examine specific combustible configurations in the outside areas. This analysis studied the effect of an outside area fire on Class 1 electrical manholes which contain safe shutdown cables. 
 
The study concluded that adequate safe shutdown path separation exists for the fire hazards identified and that safe shutdown could be achieved by using safe shutdown path 1 or 3 in the event of a fire anywhere in the outside areas.
The Hydrogen Water Chemistry storage facility is located southwest of the South Gatehouse, outside of the plant security Protected Area. This facility consists of cryogenic liquid storage tanks (one each for hydrogen, oxygen and nitrogen), ambient air vaporizers, automatic valves to isolate the tanks, liquid hydrogen pumps, hydrogen gas receivers and excess flow control devices to protect against a large system leak. This facility is designed and installed in accordance with NRC approved report EPRI NP-5283-SR-A, "Guidelines for Permanent BWR Hydrogen Water Chemistry Installation-1987 Revision". 
 
The cooling towers at Susquehanna SES are used as a source of water for the fire protection system.
The Unit 1 cooling tower is constructed of non-combustible structural components. The Unit 1 fill material is non-combustible, cement fiber boards. 
 
The Unit 2 cooling tower is constructed of non-combustible structural components. The Unit 2 fill material is primarily non-combustible, cement fiber boards. Approximately 1.5% of the fill has been replaced with PVC film fill material having a flame spread rating of less than or equal to
: 25.
 
A fire in the cooling towers would not adversely affect any safety-related structures, systems, or components. Therefore, no additional suppression systems or other fire protection features are required.
 
The equivalent fire duration (for in-situ and transient combustibles) of fire zones in Fire Area A-1
 
are addressed in Deviation Request 32.
 
6.2.59.4  Fire Detection/Suppression in the Fire Area Outside manual hose installations have been installed to protect safety related and non-safety related buildings. For the yard main loop surrounding the power block (i.e. Turbine, Reactor, and Radwaste Buildings), this is accomplished by installing hydrants at intervals of approximately 250 feet on average along the yard loop surrounding the power block. For other safety related buildings, hydrants have been installed within 250 feet of the building. Fire SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-132 fighting equipment, such as fire hose, nozzles, adaptors, etc., is provided for each hydrant using NFPA 24 as guidance.
 
The yard main laterals to the hydrants are controlled by a post indicator valve.
 
Fire detection and suppression equipment is provided in the site support structures for life safety. The in-service oil-filled transformers immediately adjacent to structures housing safe shutdown equipment are equipped with deluge systems and the transformers are provided with a pit to contain the oil and water released in the event of a fire.
 
6.2.59.5  Consequences of a Fire in Fire Area A1 Class I electrical manholes 16, 17, 18, 19, 22, 23, 27, 28, 31 and 32 are located at a sufficient distance from in-situ combustibles such as oil storage tanks and transformers to satisfy the separation criterion of 10CFR50, Appendix R, Section III.G. The analysis also postulated various outdoor worst case accidents (i.e., oil truck overturned, oil seepage into manholes, etc.) and concluded that adequate redundancy and separation exist to satisfy the safe shutdown criteria of Appendix R.
 
The Hydrogen Water Chemistry System storage facility is located away from safety related systems, structures and components, in accordance with NRC approved report EPRI NP-5283-SR-A, "Guidelines for Permanent BWR Hydrogen Water Chemistry Installation-1987 Revision", and will not affect the safe shutdown capability of the plant.
 
6.2.59.5.1  Fire Zone 0 Outside/Yard Areas The following Category I components are located in Fire Zone 0-00:
- Diesel Generator Fuel Oil Transfer Pumps (0P514A, 0P514B, 0P514C, 0P514D)-
Addressed in Deviation Request No. 32.
- 13.8 KV Startup Transformer 10 (0X103), Startup Transformer 20 (0X104), Non-Segmented Bus (0A108, 0A110), Motor Operated Air Breakers (1R105, 2R105), High Speed Ground Switch (1R106, 2R106) - These components are required for offsite power. Offsite power is not used for shutdown in Fire Area A-1.
- 4.16 KV ESS Transformer 101 (0X201), Transformer 201 (0X203), Transformer 111 (0X211), Transformer 211 (0X213) - These components are required for offsite power. Offsite power is not used for shutdown in Fire Area A-1.
- ESW Spray Pond Bypass Valves (HV-01222A, HV-01222B), Header Valves (HV-01224A1, HV-01224A2, HV-01224B1, HV-01224B2) - Addressed in Deviation
 
Request No. 32.
- Condensate Storage Tank Low Level Switch for Suction Transfer (LSLL-E41-2N002) - An analysis has demonstrated that fire induced damage to this level switch and LSLL-
 
E41-2N003 is not possible as a result of a single fire.
- Condensate Storage Tank Low Level Switch for Suction Transfer (LSLL-E41-2N003) - An analysis has demonstrated that fire induced damage to this level switch and LSLL-
 
E41-2N002 is not possible as a result of a single fire.
SSES-FPRR Text Rev. 23 FPRR Rev. 22 6.2-133
- Condensate Storage Tank Low Level Switch for Suction Transfer (LSL-E51-2N035A) - An analysis has demonstrated that fire induced damage to this level switch and LSL-E51-2N035E is not possible as a result of a single fire.
- Condensate Storage Tank Low Level Switch for Suction Transfer (LSL-E51-2N035E) - An analysis has demonstrated that fire induced damage to this level switch and LSL-E51-2N035A is not possible as a result of a single fire.
 
The equivalent fire duration (for in-situ and transient combustibles) of Fire Zone 0-00 is addressed in Deviation Request 32.
 
6.2.59.6  Special Features
 
There are no special features in Fire Area A-1. There are no manual actions required.
 
6.2.59.7  Deviation Requests Affecting Fire Area A-1 Section 7.0 provides a complete listing of Deviation Requests that affect the fire zones in Fire
 
Area A-1.
SSES-FPRR Text. Rev. 12 7.0 DEVlATION REQUESTS FPRR Rev. 13 7.0-1 SSES-FPRR Text Rev. 11
 
==7.1 INTRODUCTION==
 
The purpose of Section 7.0 is to provide a complete listing of the deviations which were taken with respect to 10CFR50, Appendix R. Sections 111.G. UI.J, 111.L and 111.0. Each deviation consists of the following sections:
Deviation from Requirements, Fire Areas/Zones Affected, Reason for Deviation Request, Existing Arrangement, and Justification.
Fire Hazards Analysis may be used as an alternate approach to or to supplement the use of deviation requests.
These Fire Hazard Analyses and changes to previously approved deviation requests can be made in accordance with the License Condition identified in the NRC Letter of 6-24-98t Amendment No. 177 to Unit 1 License No. NPF-14 paragraph 2.C.(6) and Amendment No. 150 to Unit 2 License No. NPF-22 paragraph 2.C.(3) applicable to the Susquehanna Fire Protection Program as described below: The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the abifity to achieve and maintain safe shutdown in the event of a fire. A deviation request reference matrix is provided as Table 7.1-1. FPRR Rev. 13 7.1-1 V:\NFM3\Work Areas\Pegues\FPRR TEXT 7 _ 1.00C SSES-FPRR Table Rev. 11 TABLE 7.1*1 APPENDIX R DEVrATION REQUEST REFERENCE MATRIX Unit 1 Reactor Buildina Fire Areas Deviation R*1A R-18 R-1C R-10 R-1E R-1F R-fG R-1H Request# 2 : ; 3 X X X 4 X X : ' 6 X X X 7 X X 8 X 11 X X X 12 X X I 13 X X 14 X X 15 : 19 20 X X X X X X X ! ; 23 : 24 25 X 26 27 X 28 29 X X 32 ; 33 X X X X X X X ! : 37 38 42 X X FPRR Rev. 11 Page 1 of 6 SSES-FPRR Table Rev. 11 TABLE7.1-1
' APPENDIX R DEVIATION REQUEST ' REFERENCE MATRIX : Unit 2 Reactor Building Fire Areas Deviation R-2A R-2B R*2C R-2D R-2E R*2F R-2G R*2H Request# 2 ' 3 X X X 4 X X 6 X X X 7 X X 8 i 11 X X X 12 X X : 13 X X 14 X X 15 19 20 X X X X X X X 23 24 X 25 26 X 27 28 X 29 X X 32 33 X X X X X X X : 37 38 X : ' 42 X X : FPRR Rev. 11 Page 2 of 6 I SSES-FPRR I . Table Rev. 11 TABLE 7.1-1 APPENDIX R DEVIATION REQUEST REFERENCE MATRIX Control Structure Fire Areas Deviation CS-01 CS-02 CS-03 CS-04 CS-05 CS-06 CS-07. CS-09 CS-10 CS-11 Request# 2 X 3 4 6 X X X ; X X 7 8 ** 11 12 13 14 15 I X 19 20 X X X X X X X ; X X X 23 X 24 25 26 27 28 29 32 33 X X X X X X X X X X 37 X X : X 38 : 42 FPRR Rev. 11 Page 3 of 6 I i. 
*SSES-FPRR Table Rev. 11 : TABLE7.M APPENDIX R DEVtATION REQUEST REFERENCE MATRIX Con1rot Structure Fire Areas Deviation CS-12 CS-13 CS-14 CS-15 CS-16 CS.17 CS-18 CS-19 CS-20 CS.21 CS.22 Request# 2 3 4 ; 6 X X X X X X X X X X X 7 8 X X 11 12 13 14 15 X ; 19 20 X X X X X X X X X X X 23 24 25 26 , 27 28 : 29 ; 32. 33 X X X X X X X X X X X 37 38 : 42 FPRR Rev.11 Page 4 of 6 I Table Rev. 11 TABLE7.1*1 1 APPENDIX R DEVIATION REQUEST REFERENCE MATRtX Control Structure Fire Areas Deviation CS.23 CS-24 CS.25 CS.26 CS.27 CS-28 CS-29 C~30 CS-31 CS-32 CS-33 ReQuest# 2 : 3 4 6* X X X X X 7 8 X ! 11 12 13 14 : 15 : 19 : 20 X X X X X X X X, X X X 23 I 24 25 26 27 28 29 ! : 32 33 X X X X X X X x* X X X : 37 38 42 FPRR Rev. 11 Page 5 of 6 1 SSES-FPRR
-. I Table Rev. 11 : TABLE 7.1-1 ! ; : APPENDIX R DEVIATION REQUEST : REFERENCE MATRIX ; Common Fire Areas Deviation D*1 0 .. 2 1)..3 D-4 D*S E*1 E*2 T*1 w.1 A-1 Request# 2 3 4 6 7 8 : 11 12 13 14 15 19 X X 20 X X X X X X X X : 23 I 24 ! 25 26 ' 27 28 29 : 32 X 33 X X X X X X X X X X 37 38 42 FPRR Rev. 11 Page 6 of 6 I
* SSES-FPRR Text Rev. 11 7.2 DEVIATION REQUEST INDEX : : Appendix R Deviation Requirement Request No .. Subject Deviated From 1 This Deviation Request has been withdrawn NIA 2 Suppression Pool Temperature Indication
; Section 111.G.311{1.L 3 Fire Doors -Non-Rated Section 111.G.2 4 Wraparound Area Section 111.G.2 5 This Deviation Request has been withdrawn NIA 6 Non Fireproofed Structural Steel Section 111.G.2 7 Fire Spread Limitations
! Section 111.G.2 8 One Hour Fire Barrier Wrap With Limited ! Section 111.G.2.a Suppression 9 This Deviation Request has been withdrawn N/A 10 This Deviation Request has been withdrawn N/A 11
* HVAC Penetrations Reactor Building Fire Walls Section 111.G.2 12 Fire Barriers Without Fire Dampers in Vertical : Section 111.G.2 Ventilation Duct Penetrations
: 13 Essential Redundant Raceway Protection Section IILG.2.a,b,c 14 Reactor Building Fire Zones Without Fire Section m.G.2 Detection 15 Frre Areas Control Structure Without Fire Section 111.G.2.c Suppression
* ; 16 This Deviation Request has been withdrawn
: N/A 17 This Deviation Request has been withdrawn
: NIA 18 This Deviation Request has been withdrawn
: NIA 19 Incomplete Automatic Suppression In Diesel Section 111.G.2.c Generator Fire Area 0-1 ; 20 Penetration Seals -Conduits Section 111.G.2 21 This Deviation Request has been withdrawn N/A 22 This Deviation Request has been withdrawn NIA 23 Control Structure Fire Area CS-9 Partial Fire : Section l!I.G.3 Suppression 24 Automatic Fire Suppression in Fire Zone 2-5D Section 111.G.2.b 25 Separation of Redundant Safe Shutdown Section llf.G.2.b Capability in Fire Zone 1-3A 26 Separation of Redundant Safe Shutdown Section 111.G.2.b Capability in Fire Zone 2-3B-N FPRR Rev.-11 7.2-1 
-SSES-FPRR Text Rev. 11 Appendix R Deviation Requirement Request No.
* Subject Deviated From 27 Nuclear Boiler Instrumentation in Fire Section 111.G.2.b Zone 1-SA-S 28 Nuclear Boiler Instrumentation in Fire ! Section 111.G.2.b Zone 2-SA-N ; 29 Category I Components and Safe Shutdown Section HI.G.2.b Raceway in Fire Zone 1-3C-W and 2-3C-W ; 30 This Deviation Request has been withdrawn NIA 31 This Deviation Request has been withdrawn N/A 32 Outside Areas -Lack of Separation of Safe Section IILG.2.b Shutdown Components and Electrical Cables 33 Reactor Coolant Makeup and Depressurization Section lll.G/111.L Systems (Guidance provided . in IN84-09, Para. V) 34 This Deviation Request has been withdrawn N/A 35 This Deviation Request has been withdrawn N/A 36 This Deviation Request has been withdrawn N/A 37 Control Room Raised Floor and Control Section HI.G.2 Structure Cable Chase Fire Protection 38 Protection of Redundant Safe Shutdown Section 111.G.2 Raceways in the Unit 2 Main Steam Pipeway (Fire Zone 2-4G) 39 This Deviation Request has been withdrawn N/A 40 This Deviation Request has been withdrawn N/A 41 This Deviation Request has been withdrawn N/A 42 Protection of Safe Shutdown Raceway in Fire Section ltl.G.2.b Zone 1-38-W and 2-38-W FPRR Rev. 11 7.2-2 SSES.*FPRR DEVIATION REQUEST NO. 1 HAS BEEN WITHDRAWN Rev. 10 DR1-1 G:\Lic Docs\FPRR ApprOYed\Deviations\fpc:1
_0700_01.doc SSES-FPRR Text Rev. 11 APPENDIX R DEVIATION REQUEST NO. 2 SUPPRESSION POOL TEMPERATURE INDICATION DEVIATION REQUEST: The existing Suppression Pool Temperature Monitoring System (SPOTMOS) configuration is considered acceptable.
The alternative indirect methods (described herein) to determine suppression pool temperature are acceptable in the event both divisions of SPOTMOS becomes unavailable due to a fire in Fire Area CS-9. FIRE AREAS/ZONES AFFECTED:
This condition would only occur due to a fire in Fire Area CS-9. The affected locations are the Unit 1 and 2 Remote Shutdown Panels. (Fire Zones 1-2D and 2-2A). REASON FOR DEVIATION REQUEST: Suppression pool temperature monitoring for the remote shutdown panels is provided by the SPOTMOS for each unit. While two redundant divisions of the system are provided for each unit and displayed at the units remote shutdown panel, there is a possibility that a failure induced by a control room fire could result in the loss of suppression pool temperature indication at the remote shutdown panels. EXISTING ARRANGEMENT
: Fire Area CS-9 Fire Area CS-9 has fire rated boundaries to all adjacent fire areas except at the boundary supporting floor elevator where structural steel at that elevation is addressed in Deviation Request No. 6. Fixed manual CO 2 protection is provided for under the floor space containing cables. Automatic detection is provided throughout the fire area. The control room fire zone is constantly staffed. Each division of the Unit's SPOTMOS provides a temperature averaging signal to the remote shutdown panel. Each division is contained in a separate control panel, located side by side and separated by steel plates totaling 3/8" in thickness.
FPRR Rev. 11 DR2-1 SSES-FPRR Text Rev. 11 JUSTIFICATION:
The primary function of the SPOTMOS is to monitor the suppression pool temperature to ensure that suppression pool temperatures will remain below defined limits and, thereby, containment integrity will be maintained.
The system also functions as an indirect indication that the reactor is shutdown.
In the event of a fire resulting in a control room evacuation, the operators will scram the reactor before leaving the control room to go to the remote shutdown panel. When the remote shutdown panel is used, SPOTMOS serves solely to provide helpful confirmatory information on the condition of the reactor. The operator monitors and controls reactor pressure and water level from the remote shutdown panel. Procedures also direct operators to verify reactor pressure and level indication from local instrument racks. During operation from the remote shutdown panel. explicit procedures allow operators to provide makeup water to the reactor using the Reactor Core Isolation Cooling (RCIC) system and depressurize the reactor pressure vessel with safety relief valves. In the event that both divisions of suppression pool temperature indication at the remote shutdown panel fail: Loss of temperature indication would be detected by operators by off-scale readings.
Operators would be aware of heat transferred to the pool through observation of the reactor pressure vessel level and pressure and emergency core cooling system discharge valve alignment indication.
* Emergency remote shutdown procedures direct and instruct operators to start Suppression Pool Cooling. Emergency primary containment control procedures direct operators to start suppression pool cooling upon increasing temperature in the pool. Verification of suppression pool cooling system function is accomplished by observing valve line-ups and primary (RHR) and secondary (RHRSW) flow indication.
Suppression pool temperature can be inferred from suppression chamber air temperature and air pressure indication which are available at the remote shutdown panel. Because the chamber remains a relatively constant volume, the pool heat-up or cooldown rate will be related to these two air parameters.
Control and indication for one loop of suppression pool cooling valves is available at the remote shutdown panel. This includes primary (RHR) and secondary (RHRSW} system valves and pumps presented in "mimic" board fashion for easy alignment verification.
FPRR Rev. 11 DR2-2 SSES-FPRR Text Rev. 11 In addition an existing analysis demonstrates that suppression pool temperature during a shutdown will not exceed 200&deg;F. This calculation conservatively assumes: 1. Lowest pool level and highest initial temperature
: 2. Full reactor vessel depressurization to the pool 3. HPCI or RCIC systems rejecting heat into pool 4. Minimum coolant level in the RPV (maximum heat to pool) 5. Absence of Suppression Pool cooling for approximately 30 minutes. The required NPSH for the RHR pumps at their required 10,000 gpm rating is 7.3 feet. Susquehanna SES FSAR calculations (Subsection 6.3.2.2.4.1}
in accordance with Regulatory Guide 1.1 demonstrate that the RHR pumps have an NPSH of 20.25 feet at atmospheric pressure and 200&deg;F suppression pool water temperature.
Therefore the ECCS functions are not affected by a pool temperature of 200&deg;F. Primary containment integrity in this operating region is not in jeopardy until a static pressure of about 53 psig is reached, which cannot be achieved without a minimum temperature of 300&deg;F (saturation).
Again, both of these parameters are indicated at the remote shutdown panel and are more important for primary containment control than pool temperature.
FPRR Rev. 11 DR2-3 e *
* APPENDIX R DEVIATION REQUEST NO. 3 FIRE DOORS -NON-RATED DEVIATION REQUEST: Existing unlabeled, untested, doors are acceptable for use as fire doors based on confirmation by Factory Mutual that the doors are of sufficient construction to provide equal or better fire resistance to that of a _rated fire door._ Existing watertight doors which have not been fire tested are acceptable as 1-1/2 hour fire doors based on Factory Mutuars evaluation of these doors. FIRE AREAS/ZONES AFFECTED:
For the effected fire zones see Table DR 3-1. REASON FOR DEVIATION REQUEST: Various fire barriers within the Unit 1 and 2 Reactor Buildings have been identified as requiring 3 hour fire rating to meet the requirements of Appendix R. Existing doors within these barriers are not fire rated (see Table DR 3-1 for a listing of these doors). JUSTIFICATION:
There are three types of doors within the Reactor Buildings.
Factory Mutual has reviewed each door type, and door within that type, and compared them to either known data or an existing fire rated door at Susquehanna.
* Water Tight Doors IType n Factory Mutual in their January 1985 and August 1987 Reports conclude~
that these special purpose (flood) doors would be expected to provide at least 1-1/2 hours of fire resistance (see Attachments
*1 and 5). Pressure Resistance Doors CType m Factory Mutual in their August 1985 and Ju_ne 1986 Reports compared va"rious non*labeled pressure resistant doors. with press.ure resistant door number 279 which is an Underwriter's Laboratories labeled 3 hour fire door. Factory Mutual concluded that the doors would be expected to provide at least 1-1/2 hours of fire resistance (see _Attachments 2 and 3) . Rev. 10 DR3-1 G:\Lic: Oocs\FPRR Approved\Oeviations\tpd_0700_03.doc SSES-FSAR In their March 1994 Technical Report (Supplement 5), Factory Mutual compared door number 505 with the requirements for fire resistance ratings of fire doors. Factory Mutual concluded that door number 505 may be considered to be equivalent to a 1-1/2 hour rated assembly. (See Attachment 6). Hollow Steel Doors Qype Ill) Factory Mutual in their August 1985 and June 1986 Reports compared various non-. labeled hollow metal doors with hollow metal door number 421 which is an Underwriters Laboratories labeled 3 hour fire door. Factory Mutual concluded that the doors should be expected to provi~e at least 1 .. 1/2 hours of fire resistance.
In their May 1987 Report (see Attachment 4), Factory Mutual compared various labeled hollow metal doors with hollow metal door number 115-R which is an Underwriter's Laboratories labeled 1-1/2 hour fire door. Factory Mutual concluded that these doors should be expected to provide at least 1-1/2 hours of fire resistance.*
The combustible loadings in the Reactor Buildings have been conservatively calcu1ated and the average combustible loading in each Reactor Building Fire Zone is less than 1-1/2 hours. Changes in these combustible loadings are programmatically controlled.
This Deviation Request is valid so long as: The calculated maximum average combustible loading in the fire zones adjacent
* to these fire barriers is below the minimum rating of the door. The concentrated combustible loading adjacent to these fire barriers is calculated to be below the minimum fire rating of the door. All the recommendations proposed by Factory Mutual for the fire doors listed in Table DR 3-1 have to be completed to meet the requested rates as specified in this deviation request.
* Rev. 10 DR3-2 G:\Uc Docs\FPRA Approved\Oeviations\tpcl_
0700_03.doc 
* *
* Rev. 10 SSES-FSAR APPENDIX A DEVIATION REQUEST NO. 3 FIRE PROTECTION PROGRAM -CONCERN #1 ATTACHMENT 1
* DR3A1-1 G:\Uc Docs\f PRR Approved\Oevlations\fpcC 0700_03.doc 
......... l . * ' ... ] 1 ) ] l ]*-] e i ) ] ] J ) ) , * ] 1 TECHNICAL
'REPORT !VAl.UATlON ar SELECTED_
Flll tx>OR AND DOOa FRA1* ASSEMBLttS
!nparN fort Peamyl*ani*_
Pow* and Li.pt Ccapany "Susquehanna Stem !lec~ric Statton" Rouu 11 Saln Tov~hip, Pen.m1hania 15635 FM lndes No. 384l2.,s NS January 1985 Approvad by i fH 1 e -f .Lv'..ll.
,. 1. D0b10D . Factory Mutual "esearcll ns, 8oMaft. ""-** T..,.,....
tits a*. 020l2 s eni OT I nai nHI' nae * * 
*.a .... ].* -~ ] ] ] ] l ] 1 .1 ] 1 1 ] 1 I 1 I ) \ ;* fACTCft MU'NAl IIIIAICM COll'OIA1ION PUIPOS!
* An *~*luatice of ,elected fir. door* prat1ctia1
**f*tr-related area, va, coDClucc1d far Pau7lvania Po.rn and Lishe. Coapaay (PP&l,) &t Su1qu*banna Steam tlectTic Station Unit* 1 and 2.
* The purpoae o~ the evaluation vaa to esa~ine 1elected Hre door* to determine llhethar field aodificati.on., 11ad1 to* -labeled fire dOOTI (door, which ha'V9 be1111 t**ted *1'14 accaptad 'by a natio11&ll1 reco111iaed laboratory) ,inc* their iftatallatlon voided th* ~ire re1i1tance Tacina of the doo~*; and to eKa*ine ochar nonlabeled dDot' a1,emblie1 and r*ndar an opinion cm their fire rc1i1tanc*
ratina. i * ** 
., .. * *
* t . * , SUMKAllY AHD COMCLOStOHS
: 1. TM labeled fire door aaS fnm* UNUl.iH aad the la~ehd accu1 panel an expecte-d to provid* th* level of fire 'fHi1tanc*
*~at*d ol\ the label. 2. The special purpoae (vater tigh~) doOT and fram.* ***embly eaamined ahould provide* minimum cf 1*1/% hr fire r*tiac.ne,.
: 3. To aHt FM ncoamendatiou ventilacin l_ouver1 iD th1 door, to the four ch**** coot*ioin,a electrical panel.I and cab1** at elevation 171 of th* Conerol luildi!ll 1.hould be relocated to the face of th* cable chaH near t~* u_i.ling to aehi.ev* fut rHpollH * 
.. ~-Ll . l *1 *1 ] .l .. ] ].*. ] 1 1 ] ] ] ] ) I I ] TABLE OF CONTENTS Section. PtJIPOSE SUM!WlY AND CONCUJSIOHS I INTIODUCI'ION II. nu DOOR EVALUAIION 2.1 fir* Doa~ and Door rr-AaHllbliH and AcceH Panell 2~2 Spacial' Purpose Door 2.3 Electrical
!quipma:DC aia. .. IECOMMENDATICllS I'll! DCX>a OIS!I.VAnOHS
* Page 1 11 l 2 2 4 5 7 9 -t * *** 
.1* * *~ J* ] ] ] ] '] ] *1
* i 1 ] ] ] ] ) ' * ] l I IJ1r1l0DUCT10ll Tlll pl111c waa v~ait*d duriaa ~anuary 7 and I, 1915. The writer va, .aceaapanied b)' Ke11r1. t. laile71, rP,L fir. Protection
!n1in*~, and *. J. Mattern, FMEA, aea~de~t Loe* Pr1veotioa Speciali1t.
~izi,-,ix door* and door fram**, one labeled ace*** panel, and ona milab*~**
1pecial*pu:rpote door vere euaiud duriq thi.* v.hit. The** UHablia wen located i11 th* Control luildin1 arul Unit i and Unit 2 leactor luildia1**
Tbl vd.ur .ii a Pro.;ect Eqia.ear with 20 7ean npericu:e a; Pactory Mutual IHearcb. Carporatica (FMIC). Bil. pdaar1 re1ponlibUit:, iu l) tHtina and datenaiution of fir* ncha foe Ure -SOor1J ** 2) eumiutin of i natalled unlabeled doon to detel'lliaa their fire rHiaCDce nd.q for buiUina autboriti*.
Thi writer baa aenad oa tba ladou1 Pire Procectioa
~H~iat:ic,a "Pin Door ad Vi.lUlow" COllricu. (llP'PA. IO) far 11 pan. -t 1 
.. : .,. tt FIi! DOOi !VALUATION e Labeled fire door, and door f~****,**
labeled ace*** P*nel, *nd *~. unla~*l*d 1pecial purpo** door and frame v,re exaained durift& thi, viiit to Su1quahanna Steam Elactric Station at t~* reque1t of Penn*ylvinia Pover and Liahc Company (PP&L). 1.1 r::t:: ?!OO!t! AND 1)001 FUME ASS!MIU!S ARb ACCESS PAJm.S Siaty-*i*
doo~* and door fraae1 and Ofte acce11 panel veTe eaamined det*r11in1 whether 1) label, v*r* in-place and properl7 attached, 2) modification*
had been *aada to the door or p*n*l, and 3) *odificatio~*
made vould void. the fin reahtance ndna of the door or pand. . Of the 66 doo~, examined, 62 daor9 were labeled, 4 doora v*r* not lab*lr OT had label* loo1el7 attached.
foTc,-tvo of cha labeled fire doo~, had . mO.Si.fiecl.
 
====2.1.1 Labeled====
Door* with lo Modiflcacioa1
-L&bel .. d~on ven *itualt7 euaiud tolletamine th*cithffl va* no ,~y*i~al daaaa* to the door aftd that hardware 1uppli*d ** pare oft~ auembly functioned prop.-rly to cloaa and latch the door*_v'hea the doo~. r*l****d fraaa tbe open po.itian.
Fire doo~ asaembli**
vhich haYe noi: been eodifiad 1hould ,.. .. the fire nli.1tance ratina indicated on the l*bel.* 2.1.2 L*b*led Fire Door, aftd Panel vi~h Modification, Flr1 door &ad door frame a,1emblie1 which h*va bean tatted
* nationally reco1ni~*d laboratory, such ***Factory Mutual lete&rch Cotporu:ion (FKRC) or Underffitn*
1 L&bol"atoTiet (U'L), have
* label atta<:h to both the door and the fr**** The fire re1iat1nee r1tin1 i1 noted on t~ label. A aenarally accepted pr*c*pt of FKIC and UL i* that any alt*~*tion of *** .. bly froa*the aucce,1full7 fi~* ce,t~d con*truction void* th* fir* tc1iatance ratina indicated on th* label. However, th1Te *~* rea,on* ia' nuclear indu1tr1 for *od.ifyiaa.
fi~* door ***eably;
** .. jor rea,on.i*
aeeu~ity.
CaTe muat be u1ed vhen addiftl **curity hardvare to the 4oof an* fr ..
* to aa1ure th&C thi* hardvar* vill have *iniaua impact oa fl~ r*~i* ratiaa of th~ aa,eably.
* 2 1 * ] ] ] ] ] ]* * .. 1* *1 1 .. 1 ] 1 ] ** l .. I . '] -**-**. -------------------------
1ACTOIY .WN~ BIIAICN coa,cu TION .. In tba naaiuticm, fire door aunbli* with aodific.atiou had ou or eOC"* of tha followi.11.1 additioa11 or aluratiou&
: 1. Swi.tcha1 or ellctraaaaneu.
attached co tba header of tbe door fr*** Vlria1 b in l'i&icl **tal coaduit frca the cad readar to t~ face of the door fraaa. 2. StHl or aluminua ~11* sti-ip1 2 h. to 4 in. vida, 1/8 i.n. thick," and 4 in. to 6 in. lona attached to che top of. tba door by aachiu 1c:rev1. TM an1le 1trip1 aet in coneert with. the 1vitdl or electrm*pet.
: 3. V*ather atrippina u1*d to aiei*i11 ai, leak.as* around door, where a prHeure difhrential n:itu betv** **Joiain1 anu. WHtbu 1trippiaa vH attach** to tM door or door tr ... by uana at ..chi.* ,crew. Tbl labeled fire doan emina4* ara i.dntiH.a4 I.a _,,-,,a:tz A.. ilia lnclad:a4 i.11 ~hil Appen4it ue c:011Hata cm. ad4itiw/...tlH c.a~o* to doaa ;n. fram*
* A. 1-1/2 hr*l&baled accen pnel ao. 7006 ii located 111-tbl Concrol luilding at d.H*acicm 754. Tha
* p&n1:l la 3 h bJ 3 ft la *11Uippecl rit.b a llli.croavitc:b on tbe fr....
* Modi.fication, made to labeled fire ~l'I ** fna* mcl tbll accH1 paael ara not *z,ected to affect the fire r**i*tance Tatin1 of th*** a,1 .. bli ... Z.1.3
* Fire Door, Roe L*beled Door No. 111 (elevatioa 610, ***c~or Ilda. Unit 1) and Door Ro. 201 (elevation 613, a.actor llcll* Unit 1) bad no labell. ThaH doora vere cmpared vith Door Ro. 110 (*h*ad.oa 670, I.HCC.OT ilq, U11it 2) vm.cb* had a 1-1/2 hr label vi.th th1 folla11ina re1ult1t 1. All thrff had the , ... diaen,iona ( hei pt, vi.dtll and thic.knH1) aad tM 11me* identification ta11 Cn:cept fM" the openiq number) riftted to the latch edp .of the door. 2.
* The 1pac:iq of inuraal borhontal
*Uff*n*r*
va, tletel"ahed to be apprasiaately I to 12 i1:i.
* ceat* aa all tb:r* cloon.
* 1hu Val done by mean, of a stetho1czopa.
3 
: l. TIie aa* type of i11111lat~0D
.,., u*d ~a Cite con of. ~11 three * (11&11 fiber b*tu). Thu vat utabb*h* bJ raaoviaa ecrew fr, door hinges oa all door, and extractiaa door filler ~*terial.
: 4. Tha_Cbickn***
of th* aeta~ face aheet oo all door*"-' the**~* (0.04S i.ft. 18 p). Thia va, determined by maaurin1 1Mt&l thicknu1 by meaGI of a aped.ally adapted ai.c:rometer.
Door No. 115 (elevatiom 670 of a.actor llcta.*UDit
: 1) al,o had N>> label. Thia door VU app&Hfttl)'
dHi.Sn*tl II & t pl'OOf do~ Vitb hingee welded place. It could noc be internally
~xaaioed ia the m.a1u:1er d11cribed above. the dao~ vaa manufactul'ed bJ the Olicqo Bullet Pl'oof Door. Company. Other door*_ made by th* ,aae coapany ware locatad ia the Control luildin& (Door 4 at elevetioc 729) ** in the a.actor lui.lcliq (Don 511 at ehvatica 811). loth the abw* doou hava l*l/2 br labd1. AU cbr** doon han 1) the ... di.aenaiau1, 2) the **n taadvan, 3) a eolid con. iaa..t OD tba wd.tar'* esperieace auclitina fir* door aa:Dl&bccurba plau it--u belin** tba~ Doc, Ko. 115 1ta1114 al.to bffl a l*l/2 hr fin rad.QI* &Olfe'WU, aia.ce the dear c, .
* t 11ot be i_o.terully euained, the aam.afactunl" VCN14 baTe to be coo.tactecl aa. **keel to *coapare the c:ou~tioa of Cbia d.oor with tbe 1-1/2 bf' fin r.~, door, to COil fin tb* ab ewe. Door 587 bad a loo** b ate.ached 11).t. fti.a door IIOald norul17 be . tr*ned &1 .if it had aa labal. The cloor _. aoc pb)'*ical11 euai.nM u ab, becauae it VH l~ated in ahon corridoT vitb a lab*l*d fir* door oc eit' side (Door 586 and a *tairva, do1n). 2.% SPEC-IAL PUaPOS! i,)OR AA evaluad.OII 11118 a.ad& of an unlabaled
*pecial-purpoae (flood) d( to detenuu vhetbar ic voulcl pl'ovia a 1-1/2 hr fin naiatanc*
i-uicg. doot' eHmined vH at devatioa 64S ia Che COr* Spray Pua, looa of Unit 1. Thia area i* imlicac.cl u Ana 1-11 ia the "lire Protecti.oa lwi.., leportci '1111 door vaa 3: ft b1 7* ft and c.onaiated of 1/4 ill. flat* ateel vith 1 ia. z 2 in.* 3/16 io. ,t .. 1 channal for peripheral fraains and bori&oQ1 *tiffening 10 in. on cencer. Tb* d~r vaa latched by cvelve 1 in. 1quar,. *t*l bar latcbH ens*icic tbe 5/1 in. daic:k n*l fnaa oa tba cop, 1'otc. ancl 1idea. Culteciq i.1. eaplo,ed to .. It* a vacarproof
**d vith tbe 5/9 thick *teel frame. Steel door, of chi.I type bave not been teated for fir* re1i1taace ir couatry. The con1tructioo of Chia do<< VH capered eo* tba Rul .. of 'I Office** COlllllittee (FCC), Seccioo 1, Specification 1, froa Gr.at ITit* 4 
-*. J * . , ~l _] _] ~] :1 :].: **1 * .. *1 * ~] :1 ~] ~] , Ll l,
* PACTOl'I Mlll'UM *IIAICN C~1ION vhi.ch* ~,tatH that doon fabricated io accodanc~
_with choH rule, uy be expect*d to pnwif!:e 6 hr-1' fin reli1tanc1 vhn there i, o~ door oa each aide of th* ope11i111.
Tbia i1 ba1ed OD rai .. rou1 1u:cce11ful fire te1t1 ~f th*** doo~* iD that c011ff.pration.
Fire te1t1 on 1ingle door* of thia de1i1n, conducted to requir1111nt1*of B~iti1h Standard 476, Part 8, have 1ati1fied rwquiram1nt1 of that 1taudard for 2 hour,. Tbil test method i1 equival*nt to the t11c procedure uaed ia the u.s., ASnt 1-152, in determiaina
* door'* fire re1i1tance ratia.a, vitb one ez~eptioni
* ho** 1tream t11t i1 not Tequi~ed in 15476. Thia ezceptica i* not conllidu*ed CTitical for 1t*l doon line* the ho** 1trua ia applied to th* *h ina* dde o_ the _door vh ich dri YH-th* door qain, t the fr** , top. lul** of the roe raquire tvo point latch** ol no 1*** th1111 3/1 iG. dia*ter atHl in ncb doon. The vatarpnof d.oar i11 41ueaci.oa baa tvalft 1 in. aquare *t*l latch bar1 llhidl **-t'be !n11e.J bellca,.t'ba dadnd 1-1/2 hr fin ruiatant perlonanc:e can J"9UODU1J be ezpacce.d i.e a fin *ituticm.
%.3 EL!C'mICAL
!QUIPM!MT CBASiS i A.a evducioe vaa cad* .of door, to chue1 cntaiaina electrical equipment-
*t elevatiois 771 in tha ConC~l J11ildiq.
ThHe dovn Wfe tambend 594, 595, 598, Cid one unmallbend.
Tb* doora
* an fitted vitb a fuaible ec~uated louver (11 in.. a l1 ill.) located in the top tbi'C'Cl of tba docw. The docin and lmffn bore 1-1/2 hr V1.i labeb. FM doe* not approve labeled fin dooii1 vitb louvera. Boveve~, 111., tettl and li1t1 louven fo*r iDltall.aticaa
* ia labeled fire door,. Th* Natio1ial Fi.re Proteccion A11ociation (NPPA) allow. the u** of louver* in labeled fire door, vhere the opening ia 11ot ia an *zit or located when product* of coabu1tioo flawina through the louvu openiq prior co it1 operatioa could jeopardise thia u* c:,f ezit1. Th* vall conatnaetion of the cable ch**** coaai*~* of tvo l iu. thick lay*n of Type % IYP*u* vallboari oa 1teel 1tud1. Th* wallboard ii aa the corridor lid* on17 vitb no ahuthia& pi-ovidacl oa ell* chaae *id.a of ~* atucla.
* Thi* b not a tHted fin rated conatract:l.n.
to _meet FK rec01111euoatio119 1ou~*r* 1bould be ralocatad to th* face o~ the
* cable cha** near th~ ceiliaa to achieve fa1t re1poc1e.
Louv~-opmda,1 ic t~ door 1b~ ld be e 101ed vith 16 &&II 1heec .. ta l with a lliniaua 2 ia. overlap arouDd tu opmiq. the aheet aetal covariq 1bauH N attached with aachioe* 1crev1 5 in. OD center. 5 
-* -the coo1cruction of the 1l1ctrical e4u~paent cba11 ii 1ucb that al~\ fin l'Hi1taac*
can be eJlpected if fire expo11ire ii = tM conidal' aide. Hoi,nH, i.f th* fire expo1ura ~--froa vithia the chua, fir* reai,uace Htina would be minimal..
tx,auion of the *s,oied *t*l 1tud1 due
* to * .fin inaida vould re,ult in 111DVI .. GC of fa1tener1 holdina the 17paua vallboard ia place vicb po11ible lo** of atructural iate1Tity of the "1.ll. *
* 6 
~..._ Al ~1 *** r ~] J ~] ~] ] , ]** ]
* j 1 J 1 ] ] ] ,,
* 1 1 III R!COMMENDATtONS Eight dooT a111*blie1 in Control &nd Reactor luildina1, t1qu~r1 the foUovin,:
: l. Doo~ No. 115 (Elevation 670, Reactor Buildin&, Unit 1): The manuiactur1~
1nould be contacted to deter,aine the fire ratin1 of thi1 door. 2. Door No. 5S9, Elevation 771, Control luildic&1 the latch **chani1m on thia fir* *~it device n1ed1 ~p*ir. L1tdlin1 i1 not ~*liabl* aftd bolt retraction i* erratic. 3. Door Ro. ,a6, !l*vation 713, Contnal luildia11
?hi.a docw prepared for a dead bolt which ha.a nae beea pTO&#xa5;ided.
Thi I in. diaaetu hol* it1 the face ahu~ ahol&l4 be cowu.4 11Ct11 16 l*I* ahHt 4. To aNt FM recome1ulati.ou wntllatloe lonen la tha cloan to the fatd' ~~**** concalnl111
*lectrical pan*l* and cable* at 11 .. atioa 771, CoatTGl luildin& (Doara .Ko. 594, 595, 591, atld one ullflUllabered.)
11'1ould* be relc,c:ated to the face of the cable ch*** near the ceilin& to
* achieve fut n1pDUe. Louvn openiq1 i.a the door ~hould 'be clo1ed vi.th 16 1*1* 1heat .. cal vich a mini.111111 2 in. overlap around the openina. The 1hHt **tal 1hou\d b* attached vi.th aacbiM *cnvs 5 in. G11 center. 5. Doo~ No. 601, !levacion 779 a.aecoT lutldiaa:
One bolt attachin, the fr*~e to the vall i1 *i11in& and 1hould be* replaced.
Al10, the ) cloaer attach11ent to the fr*** head*~ i1 1001* and 1hould be ti&htened.
'
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--* . ... . -~ 1 **C101Y MUNA&. *MAIOI coa,ou110N I 1 of l
* APP!HDil A 1 rm DOOi OISDYAtlCIIS*
DOOi !LEV* DOOi. ] BUILDING ll'.)
* AtlOM LAl!LED K>DIFtCATlORS aJMK!NTS 1* ---* .. Q.. C 1 ... j .. ... ., ., .,, OS
* IJ .. ._, 1 IC C .J: .. u "" Ill a "' * ,I: 0
* 8 ...
* u >> 0 1 COlltlOL 263 698 Ya* X BLDG 317 698 , .. I 457 129 tea I 1 462 719 tu J. X 463 -729 !H X 46S nt , .. X ..
* 1 466 729 te1 _ . *x 468 n, , .. X 538.
* 75/t , ..
* S4Z 7S4 tu X 1 544 754 , .. I 553 771 , .. I 554 771 , .. X
* 1 5S5 771 , .. I 556 771 ,* .. X 557 771 Yu X 1 5SI 771 , .. X 559 771 , .. X SH Secti.011 III 560 771 Ya* I ] 561 771 , .. I 562 771 TH J. 563 771 , .. l 564 771 . tu I ] 567 771 Ye1 X 561 771 t .. I 569 771 Yet I ] 570 771 YH X 571 771 YH I 572 711 -Yea J. 573 771 Yu I ] 580 783 Yea I 585 783 Yea X 586 783 Y** X Se* 1ec ci.oo Ill .J ] ,
_,,..,. -~ PACIOIY MUNAI .IIAIOt CQIPOIA 1ION
* APP!MDtl 2 of 3 A rm DOC8 OIS!KVAnClfs DOC& EL.ff* 0001 BU1LD1RG 11). Ano, LUtLED K)D1FICAT1DNS COMK!RTS .,, -u
* a. ... Q. C ... J .. .. .. w Cit
* ti .. ..,. u -= ... u ., * = ... * .I! 0
* V ..
* u :s 0 CONTIOL (SN ILIJG S87 783 Note l) l 594 771 1 .. 1 S* Seed.OIi 111 595 771 Yu Ii See Sacti.Dll 111 591 771 , .. (S* S* Sectin. III Iota 1) 730 106 * , .. l 731 106 , .. *:I I. t 7006 754 , .. X Microni.Cdl oa tr-,(sea'Bote
* UACTOI. BLDG tnn:T 1 70 . 670 Yu X 109 670 ,. .. X I !stra 'bea., dlat7 bins** 111 670 No z
* Appa*r* , ... ** Door Ro. 110 (elw. 670 l.ectcrr llq. UDi.C : 115 670 Ro l A.ppun ,aa u Door llo. 4H (*lev. 729 Cootrol Ilda.) and Door No. 571 (el.v 818 leactor Ilda.> 201 683 Ro l Appaar1 ,ama aa Door Ho. 110 (elev. 670 Reactor lld&* Unit* 415 719 Yea l 419 719 Ye1 X 421 719 , .. X 42S 719 tu I 517 149 "fH X 519 749. Yes X 52' 749 YH I ns 749 YH X 571 818 YH X l 601 779 Yea x* s.. Secti.011 III
* 617 779 , .. I I 803 818 Yes I I 806 818 YH l 807 818 Yai X l
* 10 
] ' J ] ] ] J 1 1 J 1 :1 ]* ] ] ] , ] ] fACTOIT MUNA& *IIAICN CC9DIAflaN
., APPEIIDI1 A. ,m DOCll OISDVAnCKS IUILD1RG DOOi !LEV* IX>OI fl). ATIOR t.AB!LED M:>DlFICA.TIORS """' 1ill
* t ... C -u ... .. I w ... "IS en
* u ., w .., Ill w .i= w u "' . ., " g .. * * * .. s u :a 0 UACTOI ' 1 . ! IU,C URtT 2 72 670 Yu X l 110 112 113 114 116 511 2. 3. 670 Ye, 670 Ye* X 779 Yea X I Air lock *itch 779 Yu l z Air lock awi~dl -670 tu I I . -f . ,.., dnar *nislfarc,-nc oa. fac* 749 , .. I of cloor na label on ttlia doo, ha* aiuor daaaa* allll u loo*l1 anachd. Thi.a cuu a *quaati.cna
_.. to i.u 1 .. iti.macy.
tu Chi.I iaatanca, the quenion ia .oot, aa thu locacicm la io
* tborc caTi'idor vitb ma acceptable fire door oo eitber 1ida of it. (Door No. 586 aad a 1cairva, doer.) The.re ia a fmr.cb dool' ad .t*~*nt to thi.1 door vitb ao openiq idutifieation.
Thia i1 a 3 fc s 3 tc, l*l/2 br rated ace*** *puael. 11 * 
* *
* Rev. 10 SSES-FSAR APPENDIX A DEVIATION REQUEST NO. 3 A TI ACHM_ENT 2 DA3A2-1 G:\Uc Docs\FPRR Approved'\Deviations\fpd_0700_03.doc 
;**., . .,. ** *
* EVALUATION OF SELECTED FIR! DOOl AHl> DOOi FUME ASSEMBLIES ( St1PPL!K!HT
: 1) BJ Suual M. Jt.u11bt Prepared for: Penuyballia towr &ml L1pt CoapallJ *s1aaqueha1mA Stu.a llecas.c*Stutn*
l.ou~* 11 Salaa TC111Ubi.J1~
Pau1lft111&
1.5635 Aupat 1985 Factarr Mutual Researcll "51 ao.tDft. Prvw
* a T"'&deg;"9 Ncrwaod. 02082 ApproTed ly P. ll. Oobao~ Senior !q111Hr nae .. t w, .*. **CTOIY MU1UAL HSIAIOt COIPOHtlON
* 'I.UL! or CONTENTS Section Title Page -PUUOSE 11 StJMMAl.t AND CONCLUSIONS 111 I llffltODUCTIOH 1 II Fill DOOi. ARD 11.&ME EVAUIA%10H 2 Ill ~OBS 4 t *
* 1 
....... '~ * *
* PACTCIY MUTUAL MIIAI04 COIIOIA 1ION PtrlPOSE AA evaluation of ,elected fir* door* protectinl
.. fety related are** vaa conducted for the Pem:11ylvarua Pove~ and Liaht Co. CPP&L) at Su1quehalln&
Steam Electric Station. Ullitl 1 & 2. Th* pur,oH of the evaluatS.011 va1 to U&Alne cer~aic *unlabeled door* and compare th~ VS.th labeled doer cell1tru.c.tiosu to render &11 optuioD on their especte4 fire r~11at&Dce.
Tb11 evaluation va* reque1t*d by !l&L aa a 1upple .. Gt to th.a orisinal evaluation 1n a Pactor, Mutual rapo~t dated J&Aa&rf 1985 * * -* 11 
,_ .... **CTOIY MUTUAl USIAICH COUCIA TION SUHKART AND CONCLUSIONS
: 1. Door Ho. 279 o~ Level 676, had* *3 hour labal atucbed. The door may be espected to provide that level of protect10D.
: 2. Door Ho. ~%1 TAvel 719, bad a 3 hour label atucbad. The door uy be espected to provide that level of prot*~t10ll.
: 3. Door No,. ll1 and 201~ **re coapared to Door Ho_. 279 aud found to be of the HM ccn*truct1on
&Del of tb* *-uterS.&11, Rd were jud1ed to be cqu.1v&len.t, hence. uy be erpected to proYide up to 3 hou.ra of f1-re raai1tuc:e.
* 4. Door Ho *. U.5 on Level 749, VH coapared to Door Ho. 421 ad fouad co be cf the HM coutruc:tian
&Cd of the -utarl.ala ud na. jadJed to M equ1valesit 11 hellce, uy be apectecl co prcwtde "P co 3 boua of fire s. to **t 1M reeommndatiou, the lc,aqr ill~~ Ho. 606 os !laTaeiOll nt, 1boul.4 be -re::aoftd au tba o_pesdn1 protactad.
The door ... cospared to
* Door No. 421., _aul 1f pro~ected u m,t*d ill para,raph 2.3, uy be n,,ecce to pron.de up to 1-112 hour'* fira raaialuce
* .
* 6. Shau.14 it be ucH8H'7 to have addidoul.
door~ at dli* aite aulyzed aa to their expected fire reai1tance ratiug. th11 aay be acco11pli1hed by ~e of th.a follovin.g proced~r**r
: a. For door* 11NCU.q up to a 1-1/ 2 hour equi valea.cy; COG tact ~he aanufacturer and obta.1~ written c01Lfirmat1oo tb&t the door* iu q~eation aild at leaat one sla1lar door prevtoualy exam1Ded by the writer ad qu.alif1ed for 1-1/2 hour ratiq vere fabricated to the appropd~t*
PP&L apecif1c:at1on..
rua ehould.be corroborated by detera1Dillg that 111**, faca aheet thick~e**
an4 h1os* reiDforceae~t thickuH are the ..... I11atallat1011 aball confor. to the raquiruenta
~t Hl'P~ Stu.cl.&rcl 80, "fir* Door* and VJ.don.* b. Por doora uediq up to a 3 hour eqaJ.Y~eacy; requeat a ad.clitioul T111t bJ the vrit~r to dauraiu that partpharal chamlal fQa1q ad . latch re1D.forceaeot*
ar* tba eaae asi.d tbat 1Dt*~*tiffanar quantity and loc.at1ou*
are the aaae. ** 111 
.; ...... * *
* PACTOIY la'UNAL IIIIAICM COIPOIAT10N I INTIODDCUON tb* plant va1 viaited _011 May 7, 1985. Tba writer** accomp.anied by Mr. D. 'l.o'tm of PP&L *. Four doore ad fraae* "r* eu*tned duriq th11 Yidt. Tb.a aaaeabl1e*
war* located 1~ U1lit 1 and 2 a.actor 1"1ld1D.SI*
The wruar 1a a Projec.t tna111eer Yitb 20 year*' ezper1nc*
at the Pactory Mutuai lHaarcb Corporation
{nt&C). The writer baa Hrted oa tb.e Natioul Ptr* Protectiat1 Aaaoci~tioi1
*11re Door* and W1DdOlf1*
Colalitt** (HPPA JO) for 18 years.* !111 prtaary rHpou1b1lit1H are: 1) THt1111 and d.etera1ut101l of fire ractna* for fire door,; u4 2) PH*1utioa.
of ioat&Uacl* aiabehcl doon ~o d*t*raS.Ae their f1re*r**1*tance TatiD.a fOT bedld1DI au~t:lea
* 1 
,ACTOIT MUTUAi. IUIAICM COIPOI.A TlCN II FIR! DOOi. AND.PP.AM! !VAltJA!IOM Two labeled fir* door* and fr ... ,, ~d aro uu.labeled fire door, and . . fraua. wen eum;ud duriq thi~ vidt to.the Suqu.elwma Stea Elec~ric sut1c,11 at the requeat of the Pe1m1ylvania Ponr ud Uaht Coapqy (PP&l.). 2.1 Door Frame A91eablie1 All fr ... * .var* fo\llld to 'be fabricated in accord.&l:u:a with th.a Aaerlcau ** NatioD&l St&Ddard, ID.lt1tute, St&11dard Al.55.1, and a&J be aspecte4 to provide up to 3 boura fire re1i*t&AC**
* z. 2 P1ra Doar1 U1U.&kl*d fire doora ware ese*tned b1 c-,uiq tbaU cautnc.uon fu~ with labeled fire doore. 2.2.1 Door Noa. 111 and 201 ' Door Koa. W ad. 201 .. n* ra
* aT&l.aatecl d.11!'1Da th.11 '1.dt. Tbay nre preTiou.alJ c:OTered 1c the PMIC report dated Jaaal'11985.
l.t that taa, thoa door* w~* cosp&red apJ.ut a 1-1/2 hour l&laeled door (Ko. llO &t taftl 670) 9 ad our opiuioc na that tbaH door* could bf ezi,ected to pron.4a at laaat a 1-1/2 hour fire redatance.
Door Mo. %79 oa Level 676 bur* a labial. 1u41cat1Da a 3 hour fire realatanca.
The con1tructicni detail* o! Door Ho .. 179 wre c.oapar.d to Door Ho. 110 vit.h the folloriq renltai l) All doora had ~ba -cU.aeuiou (be1gbt, wS.dtb ad thicbleaa).
: 2) Iutemal..sts.ffu.en wen 4ateru.ned to *1,e apprarl .. tely 6 in.. to 8 iA. on center. Thia wa1 done by mean, of a 1tetheacope.
: 3) Face 1haet 1 hiua* reia.torceaeDt and peripheral cb&D.nel fraaiua were foa.d to N elHDt1allJ the aame. _Tbil va* d01le by ae&Di cf & apaciallJ adapted aicro .. tar. ** 2 
* *
* f ACTCIY MUTUAL IISIAICN COffl)IA TION 2.2.2 Door !fo. 515 Door Ho. ll.5, c= Level..749, ~* aoi labeled ud waa eua.1.ned to com.para it* couatruction detail* again.It Door No. 421 ua1D1 the criteria outlined in Paragraph 2.2.1. Door 421. ha* al hour 1-bel. lath door* have eaaaotially the .... cO'llllt?UCtion detail,. 2.2.3 Door Mo 606 Door No. 606, on Level 779, *** e:1eaa1:ne4 to coapara itl c~tt'Uet1cn,.
aaain.at Door No. 421. Door No. 606 contaiuad a louver (6 1D. s 8 111.) vhicb preclude*
tba door fraae bavilLI AAJ fire re1la~c*, U.111*** aodif1ed.
All other detail***
outlined iu Paraarapb 2.2.l ... r* ****nt1&l.17 the .... betw**~ the** tWD dcora. Door Ho. 42111 a 3 bour rate4 fire doo~. U Door Ho. 606 11 aodil1ed.
it co provide at leaat 1-1/2 hear'* fin re*~ta.ca.
The m.od.:lficat1.0II ahould COlldlt of attach1q OU 11 pp *tN.l place to ucll door face. the pJ.te *bould be arp eaoqb co. onwp the lolmtr 2 a. oa all . dd.al
* Putaan 1haulcl be 1lutet aul Kr-, apaced ao .on tha. 6 ill. Oil cn'ter
* 3 j *1 I i f i J 
........ fACTOIY MUTUAL IISIAIOI COlf'OIA TION III ucoMKEHt>ATIOHS
: 1. If a fire reaiatauce rating of up t~ 1-1/2 hour* for Door Ho. 606, oa Level 779,* 11 dedred. the louver ahoul.4 be covered Cll botb face, by 18 1*1* atael plate1, overlappia.&
all aide1 by 2 in., faateued by ahaet utal 1cre1r1 apaced iio acre tb&D 6 i"A. 01a center. 4 e * * 
* *
* Rev. 10 APPENDIX A DEVIATION REQUEST NO. 3 ATTACHMENT 3 DR3A3-1 G:\Uc Docs\FPRR Approved\OeviationsVpd_0700_03.doc 
** *
* TECHNICAL REPOlT ?VALUATION OP SELECTED Flll DOOR. AND*DOOJ.
FRAME ASSEMBLIES (SUPPLEKEH'.t
: 2) By Samud M. bight Prepar~d for: Pennsylvania Pover & Light Company *suequebanna Stea* !lectTic Statlou* loute 11 Sal~m fo11Z11hip, Pezma7lvania 15635 June 1986 Factory Mutual Research n51 Boston-~ T~ NarWOOCI.
Mess.ac..,_n, 02062 Approved bys P.a. bobeoD Sellior tnaiaeer
* nmc 
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* *
* Section SOMMAJlY AND CONCLUSIONS I II III FACTOIV MUTU~L lESlAICH coaPOIA TION TAIL! or CONTEHTS IHTB.ODUCTION rm DOOP. AND FllAME EVALUATION UCOMKENDATIOHS . . 1 11 l 2 6 
...........
fACTOIY MUTUAl *U&#xa3;,UC"4 CORPOIAflON SUHHAR.Y AND CONCLUSIONS An evaluation of aelected fire doore protecting safety related area, vas conducted for the Pennsylvania Power&. Light Co*pany (PP&L) at Susquehauna Steam Electric Station, Units l & 2. The purpose of the evaluation vaa to ezamine certain utll.abeled doo~a and compare them with labeled door construction, and render-au opinion ou their ezpected fire reeiatance.
Tb.is evaluation vaa requested by PP&L aa a supplement ta the original evaluatiou in a Factory Mutual report dated January 1985, and Suppleme~t 1, da~ed August 1985. The following concluaioaa vere reached: l. Door 112 on Level 670 may be ezpected to provide 3 hours of fire reaiataace.
: 2. Door 202 on Level 683 may be ezpected to provide 3 houri of fire reaiitance.
: 3. Door 407 on Level 719 may be espected to provide 3 hours of fire res1atance when the four 1/8 in*. diameter boles iD the face aheet are a~aled vith sheet aetal acrewa. 4. Door 514 .ou Level 749 may be expected to provide l-/2 boure of fire reaiatauce.
If. the esietiug latch b~lt ii replaced with a latch having a 3/4 in. throw, thia door may be expected to provide 3 hours fire resistance
.. S. Door S30 on Level 761 aay be expected to provide 1-1/2 hours of fire resistance.
lf tbe eziatina latch bolt 11 repla~ed &#xa5;1th a latch having a 3/4 in. throw, thia door a&J be erpected to provide 3 hours fire reaiatance.
: 6. Do~r 711 on Le~el 799 aay be erpected to provide 1-1/2 hours of fire re11stance.
lf the ~i*ting latch bolt 1a replaced vi.th* latch having a 3/4 in~ throv. thia door aay be ezpected to provide 3 boura fire resistance.
11 * * 
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* fACTOIY MUTUAL HSlARCH COIPOIA T&ON I INTRODUCTION The Suaquebanua Steaa*Electric Station vaa vi11~ed oo April 4, 1986 and Kay 16, 1986. The writer va1 accompanied by Mr. S. 1. Davia of PP&L; Kr. L. J. Mattern of PKEA va1 present durin.g the ~pr11 v1a1t. Three unlabeled doora an4 fraaea were esaained during each visit. '1'he door ***emblie1 are located iu On1t l & 2 keactor Buildings.
The writer 11 a Project !q1neer vitb 20 years' upedence at the lactory Mutual Research Corporation (PMllC). The writer has aerved on tbe Natiooal Fire Protection Association
*11re Door* and Windova* Coamittee (NFPA 80) for 18 years, ,Bia primary re1pousibilitiea a~e: 1) Testing and determination of fire rating* for fire ~oor,; and 2) E.zaainat1on of 1natalled unlabeled doors . to determine their fire rea11tance rating for building authorities
* l 
-... FACTORY MUTUAt RESEARCH
* COIPOIA TION II PIRE DOOR AND.FRAME EVALUATION Sis unlabeled fire doors and frame* were ezaaiued during tvo viaits to the Suaquehauua Stea.a Electric Station at the request of the Pennsylvania Pover 6 Light Company (PP&L). Espected fire reaistance rating* for each door ve~e determined through compariaon with labeled doa~a * . 2.l FilE DOOl PllAKES All frames are fabricated in accordance vitb the Aller1cau National Standards Institute, Standard Al55.l, and may be ezpected ~o provide 3 hours of fire resistance.
2.2 PIR.E DOORS I'he following uulabeled fire door* were esaained by comparing the1r -conatruct1on features vith labeled fire doors. 2.2.1 Door 112 Door 112 on Level 670 vaa compared to Door 421, a 3-hour labeled door on Level 719; it is concluded that Door 112 ha1 an e%J)ected 3-bour rating baaed ou the folloving-reaulta: l. Both doora are the aame aize. 2. luteroal stiffener*
in both door* ere 6 to 8 iu. on ceuter, This vas determined by mean, of a *tetboacope.
: 3. Pace sheets, hinge reinforcement*
and peripheral cbauael framing are ea~eutially the eame. Meaeureaent1 vere aade u1iu1 a apecially adapted micrometer.
In addition latch tbrove in Door 670 are equal to or greater than the 3-hour labeled door. 4. !>oor 421 haa a lov-deusity glaee fiber iuaulatioa 1D the do~r caVity vhile J>oor 112 doe* not. Tbii low density 1naulat1ou baa no a1gn1ficant
~earing en the performance of a door in a fire aituatlon.
2 * * 
* *
* fACTOIY MU1UA.L lfSfAICH COIPOIATION 2.2.2 Door 202 Do~r 202 011 Level 683 va1 e~aained and 1t1 con1truct1on deta1li vere coapared vitb thoae of Door 110 a l-l/2-houT (aubaeq*uentlJ upgraded to 3 boura) labeled door on Level 670; it 1* con.clud~d that Door 202 ha1 an ezpected 3-hour rating baaed oD the following obae~atiOD*J
: l. Both door* are the same si&e. . . 2. luternal atiffener*, 1D both doon are 6 to 8 111. on ceiiter. 3. Pace eheet** hinae reinforceaent1 and peripheral chamiel framiug hav~ the same meaaureaeot1.
The 3-hr rated door haa a 3/4 1D. latch throw, whereas 1>oor 202 ha1 a 1/2 *in. throw; bovever, because Door 202 employs a three point latch aecbanisa, (i.e. tbree points of engagement betve~n door and fraae) it 1* concluded that thia aechaui**
offaet1 the aborter throw and juetifi**
extending the expected*
fire resieta~ce rating to 3 boura. 2.2.3 Door 407 Door 407 on Level 719 va1 esamined to compare it* con*truct1_o:n details asainst Door 42lt a 3-bour labeled fire door on Level 719; it 11 coucluded that Door 407 baa all ezpected 3-hour rating 'baaed OD the following observations:
: l. ~e labeled door 1* 2 in. higber than Door 407. Teat, have ahovn that door, smaller th.au te*ted will provide equival~pt perfo~nce if all other couatruction feature* are the aaae. 2. Internal 1tiffener1 iD both" door* _are 6 to 8 in. ou ceuter. 3. Facea abeeta, hiqe re11lforceaentl and peripheral chaunel framing are the eame.*escept tbere are four hole* of appro:Eiaatelf 1/8 in. 41aaeter io oce face *beet of Door 407. lD*add1t1on, latch tbrcnra in Door 407 are equal to or greater than Door 421. 2.2.4. Door 514. Door 514 oa Level 749 VH ezaained to coapare 1u cou,truct1cna detail* against Door 421, a 3-hour_ labeled fire door. oo Level 719; it 11 cou~luded that Door S14 baa an expected 3-hour ratiq baaed OD tbe folloriq obaervat1ona:
3 
-:-*r ., f ACTOl't MUTUAl IUfAICM CORPORA T10N Both doors are the aame siie. 1,. 2. Internal 1tiffener1 in both doors are 8 to 12 in~ OD center. 3. Pace 1beet1, h1uge reinforceaeuti, and perip~eral channel framing are eaeentially the aaae. 4. Tbe labeled door 1a fitted vitb a aingle po~nt latch baviD.g a 3/4 in. throw, vhile Door 514 has a 5/8 in. throw. Although the conatruct1ou of Door S14 1* comparable vitb tbe 3-hour rated door, thia aborter latch throw dictates a aborter expected fire re111tance of 1-1/2 houra. Since greater forces are senerated 1G the aaaembly dur1111 a 3-bour erposure, there ii incr.eaeed poaaibility that the ahorter latch bolt will be pulled out of the strike during ezi,aneion and dtatortiou cf the door and frame, resulting in failuire.
h):,er1.ence haa abovn that 1f the construction of the door 1a adequate, a 1/2-in. latch throw ia adequate to achieve a 1-1/2-hour expected fire reaistance.
If the S/8-1n. bolt 1, replaced with a 3/4-in. bolt, the door aay be expected to provide up to 3 hours fire resistance.
2.2.5 Door 530 Door S30 on Level 761 vaa ezamined to compare !ta construction detail* against Door 421, a 3-hour labeled fire *door on Level 719; it 11 concluded tba~ .Door 530 baa an eZJ\eCted 3-hour rating baaed on the folloving evidence:
* 1. Both doors are of the ilame 11&e. 2. Internal atiffenera in both door* are 8 to 12 in. an center. 3. Face sheets, hinge re1nforceaeota and peripheral channel framing are eaaentially the same. 4. The labeled door 1a fitted with a 1ingle poiot latch haV1ng a 3/4 1u. throv, while Door S30 baa a 5/8 in. throw. Although the cou*tructiou of Door 530 1a comparable with the 3-hour rated door, t~* aborter latch throw dictate* a aborter erpected fire reai1tance of 1-1/2 houra. Since greater force* are generated 1D the aeaembly during a 3-bour erpo1ure, there 11 1ncreaaed poaaibilitJ that tbe*aborter latch bol~ Will be pulled out of the strike during e~anaioo and d11tort10D of the door and fraaet resulting in failuire.
!sperience haa 1hovn that 1f the couetruction of 4 *I I I I l I I I I ' I I I
* 1 .* I 
** * * . fAClOIY MU1UAl IHlAICH COIPOIA'flON the door 11 adequate.
a l/2-in. latch throw 11 adequate to achieve a 1-1/2-bour e.zpected fire rea11tance.
If the 5f8~1n. bolt 11 replaced with a 3/4-in. bolt. the door aay*be ezpected to provide up to 3 hours fire reai~tam:e.
2.2.6_ Door 711 Door 711 on Level 799 vas ezamined to compare it* construction detail* a1aiu1t l>oor 421. a 3-bour labeled fire door* OD Level 719; it 11 concluded that Door 711 baa an erpected 3-bour ratina baaed on the follovina evidence:
: 1. Door 711 va1 6 in. narrower than Door 799. Teat* have ah01n1 that doors aaaller than teated will provide equivalent perforaance if all other con1truction detail* are the aaae. 2. Internal atlffeoer1 are 8 to 12 in. on center. 3. Face sbeeta, hinge reill.forceaent1 and peripheral channel fraaing are eaaentially the eame. 4. The labeled door ia fitted "1th a 11ngle*point latch having a 3/4 iD. throw, while Door 711 has
* 5/8 in_. throw. Although the con*tructioD of Door 7111* comparable vi.th the 3 hr. rated door. thie aborter latch throw dict~te*
* a aborter erpected fire realltauce of 1-1/.2 boura. Since greater force* are generated in tbe aaeeably during a 3-bour ezpoaure, there ia increaaed poaa1b111tJ that the *horter latch bolt vill be pulled
* out of the 1trite during ezpaua1on ac.cl dletortioii of the door and fr .. e, re1ult1ng in fa1lu1re.
EzperieDce ha~ ahovn that if the conatruct1on of the door ia adequate, a 1/2-iu. latch tb~o* ie adequate to achieve a 1-1/2-bour ezpected fire re1i1ta11ee.
If tbe 5/8-in.*bolt 11 replaced with a 3/4-in. bolt, the door aay he espected to provide up to 3 haura fire reaiatance
* 
,.cron MUTUAL IISfAICH CORPOt* TION III !!COHK!NDATIOHS
: 1. To obtain a 3-hour fire reei1tance ratiug the f~ur 1/8-in. di,&#xb5;aeter boles* 10 the face sheet of Doer 407 OD Level 719 should be filled ua~ug sheet aetal acrevs.
* 2. To increase the 1-1/2-hour fire resi*tance ratios to 3 hours. the 5/$ in. thTov latch bolts on Door 514 on Level 749; Door 530 on Level 761; aGd l>oor 7ll on Level 799 should be replaced with latch bolts havtng a 3/4 in. throw. . 6 * * * 
* **
* Rev. 10 SSES-FSAR APPENDIX A DEVIATION REQUEST NO. 3 ATTACHMENT 4 DR3A4-1 G:\Uc Docs\FPRR Approved\Oeviations\tpd_0700_
03.doc 
*-.v ..... I * *
* I I I
* 1 I I I* I
* I I I I t TECHNICAL REPORT EVALUATION OF SEL.ECTEI>
FIR&#xa3;-DOOR AND DOOR FRAM! ASSEMBLIES (SUPPLEMENT 3} by Chris~opner A. Spencer Prepared ror
* Pennsy l van1a Power .and Light Campany Susquehanna Steam Electric Station Route 11 Salem Townsnip, Pennaylvania 15635 Hay 1987 Factory Mutual Researcll "51 8omlrt* PR,.. .-a T""&deg;"'9 Narwood. ManactuNftl 02062 Revlewed by: w. f. Shield t Ass 1.9tan, ttana,er Materials Section (Codes/Ratings)
FMRC Approved by: P.H. Dobson Senior Engineer FMRC 
._.,. : A I
* I I I I I I I ** I I I I I I I * **CTOIY MUTUAL .IISIAICM COIPOIAflON TABLE OF CONTEPn"S Section Ill!! TABL.E OF CONTENTS S~ARY*AND CONCLUSIONS . I INTRODUCTION Il FIRE DOOR AND FRAME EVALUATION III REC~NDATIONS 1 Page 1 111 , 2 5 
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* I I I I I *1 I
* fACTOIY MUfUAl IISIA.IOt COIPOIATION
 
==SUMMARY==
AND CONCLUSIONS An evaluation or.selected tlre doors and tram~ protecting safety related areas was conducted for the Pennsylvania Power and Light ~o. (PP&L) at . SusquehaMa Steam Electric Station. Units* 1 I 2. nie purpose or the evaluation was to ~xamine certain unlabeled or IIOd1t1ed doors and frame5, compare them with labeled units and render an opinion.on their expected fire resistance.
Thia evaluation waa requested by PP&L as a supplement to the original evaluation contained in a Factory Mutual report dated January 1985~ Supplement 1 dated August 1985 and Supplenent 2 dated Jw,e 1986. -. The tallowing conclusions were reached: 1. All fraines eaamined '1/aY be eapected to provide 3 hours tire resi~tance subJect_to the completion ot Recomendatlona 1 and 2 2
* 3. 4. noted in th1s report.,, A ... ,.. .. -.... -Door 115'on Level 779 had a 1-1/2.hour label attached.
The door may be.expected to provide that level ot protection.
Door 175 on Level 676 had a t-T/2 hour label attaehed.
The door . may be expected to provide that level or protection.
Door*4o8 en Level 719 may be expected to provide 1-112 hcnrs tire resistance. . . s. Door 531 on Level 7ij9 may be eapected to provide 1-1/2 houra tire resistance subject to replacement or the missing sllencera and tn.stallatlon or a-16 ga. cover plate over the hole which waa -. . provided to receive an electromagnetic switch. mechanism.
: 6. The active leat or Door 712 on Level 199 has been sprung at the top and should be replaced.
111 
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* I I I I I I I * ' . I ' I . l I . * ,ACTOIT MUTUAL USIAICH COIPOIATION I INTRODUCTION The plant wu visited on April 9, 1987 by V .. *F .. Shield ancs C. A. Spencer or FKRC. Ve were accompanied by Mr. S. Davis*or PP&L.' Five doors and rrames were examined during thi., vbit. The usembliu were located 1n Unit 1 and 2 Reactor Buildings and the Control Building.
Mr. C. A. Spencer is a Registered Prore*~a 1onal Engineer in tlre protection w1th 11 years' ezper1ence at Factory tilltual.
Mr. Spencer has been involved in t1eld.~d plan review ev~uat1on or tire walls and r1re rated assemblies and is now involved in testJn1 and evaluation or tire ~eslstanee ot bulldins mater1ala and tire rated aaaembliea.
1 
... . .. * * ** fACTOIY MUTUAl IISIAICM CC)IJOIATION II FIRE DOOR AND FRAM&#xa3; &#xa3;VALUATION Two labeled tire doors and frames, and three unlabeled tire doors and frames, were examined durlng this v1ait to the Susquehanna Steam Electric Station at the request er the Pennsylvania Pow~r and Light Company (PP&L). 2.1 FIRE DOOR FRA~ All tramea examined were round to be fabricated in accordance with the Alller1can National Standards Institute, Standard A155,1, and may be expected to
* provide 3 hours r1re resistance subJect*to cam.pletlon ot Recomaendat1ona t and 2. 2.2 FIRE DOORS Two_ labeled doors with mocUt1cat1ons were eum1n,d and three unlabeled doors were compared to labeled fire door1 to obtain an est1mat~ t1re resistance rating_._ 2.2.1 Labeied Fire Doors wlth Modifications . . Labeled doors with mod1t1cat1ona were elalit1ned to determine whether the doer would ,till be ezpected to provide the level or fire resistance indicated on the label. Door 115-A 1,..-c,,..,,.,...., Door 11S'f'tlevat1on r19, Reactor Building, Unit 2) had a 1-1/2 hOur label attached.
This door had been modlt1ecl by addition or an electromagnetic card . . reading device. E:iaalnation 1nd1catea this door may be e*pected to provide , ... 1/2 hours tire resistance. (Note: the* report or the original tire door evaluation dated January 1985 referenced a Door No. 11S on Elevation 670 or Reactor Buildilll, Unit 1. This 1s not the SUie ~oor.) Door* 175 Door" 175 (Elevation 676, Control Structure, Lunch Room C. t09) had a 1-1/2 hour label attached.
This door had been mod1r1ed by addition or a 10 1n 1 10 ln wired 11ass li1ht (Hodel T!iG manufactured by Le1lie Locke Inc.~ Atlanta, Georgia).
E1aminat1on indicates that since thi~ is within the 2 
"'--.. I * -I I I I I I
* I I I ' I I I I I
* I I" F.&ClOIY MUTUAL IHIAICH COIPO&ATION maximum exposed glass area allowed by National Fire Protection
*A3sociation, NFPA 80, Standard for Fire Doors and Windows, th.b door may be expected to provide 1-1/2 ho&#xb5;rs fire resistance.
 
====2.2.2 Unlabeled====
 
Fire Doors Unlabeled tire doors were examined by comparing their construction features with labeled doors. Door 408 Door ijQ8 (El~vation 719,*Reactor Building, Unit 2) had no label. This . * ~'lt-C.. ., .... -~ door was compared to Door 115 'U1 th the.. following results: a. Bath doors are the same size. b. Both doors have vertical internal stittenera at approzlmately 6 in. on center. c. Face sheet thickness ( 18 p.) and hinge reintorcement ( 16 ga.) weN-the. sa.me on both doors
* d. Both *doors have mineral wool lnsulat1on in the cavity. e. Door 1108 has a latch throw ot 1/2 in. compared to 5/8 1n. for ll "t,...,., , ***ft'? . Door 115!'" However, -this satisfies the minimum latch threw requirement speclt'1ed in NFPA 80 tor a 1-1/2 hour door. Based on the above observattons, 1t is concluded that Door ~08 would have *an expected rating or 1-1/2 hours. Door 531 Door 531 (Elevation 7l9, Reactor Building, Unit 1) had no label. This . A ~,r,-' .., .,,. .. ,,, door wa..s compared with Door 115 1"1 th the following results: a.. Both doors had the ame dimensions.
: b. Both doors have vertical internal .st1trener*
at appro~lmately 6 in. on center a:i determined using a stethoscope
*. c. Face sheet .th:lcli:nesa ( 18 1a.) and hinge reinforcement* ( 16. ga.) were the same on both doors as determined using a specially adapted micrometer.
: d. Both doors have lateh throwa ot S/8 in. e. Both doors have mineral wool insulation in the cavity
* 3 
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* I I ,.1.ctOIY MUTUAL II IIAICM COIPOIA noN It is concluded that Door No. 531 *would have an expected rating or 1-1/2 hours subJect to completion of the recomended 1.mprovementa 1n Se~tlon III er this report. Door 712 An examination or Door 712 (Elevation 799, Reactor Building, Unit 1) showed that the active lu.t of' this pair or doors had been sprung at the top edge and should be replaced.
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* I I" J I I fACTOIT MUTUAL IUIAICM (oa,QIATION III RECOMMENDATIONS
: 1. The silencers missing froa the tra:ae ot Door 531 should be replaced.
: 2. The opening in the frame ot Door 531 Which ~s intended to receive an electromagnetic switch mechanism tor a card reader, should be covered with a 16 ga. cover plate. 3. The active leat or Door 712*, which has been sprung at the ~op, should be replaced v1th a labeled t-1/2 hc~r rated tire door. s 
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* Rev. 10 SSES-FSAR APPENDIX A DEVIATION REQUEST NO. 3 ATTACHMENT 5 OR3A5-1 G:\Lic Docs\FPRA Approved\Oeviations\tpd_0700_03.doc 
**-.... It I l I I I I I I ._ 1 I I 1 I . J. I I t .. I 1 TECHNICAL IEPOlT EVALUATION OP SELECTED PW DOOi AND DOOi PllAHE ASSEHILI!S (SUPn.EMEN'I
: 4) bJ JeffreJ !. Gould Prepare~ for Penneylvaaia Power aud Llaht Coapaaf Suaquehanna Steaa Electric Stai1D1l lout, ll Sal** ToW11all1p,-Pezm171T&D1&
15635 Auguat 1987 l.edeved b71 w. r. Shield, 4aaiatant Kanaa*r Material*
Sectioa (Code1/l.at1n1*>
nae l. H. Dobaoa '-Snlor !qlaeer *nm.c Factory Mutual Research 1151 Boellan-Ptai.dlila T""l*t Nm woac1. * *-'IIICh*lnl 02oe2 -
..... ~. * *
* I I I J* I I I 1 I J ] 1 ] I I-,ACTOH' MUTUAL IISIAICH COIPOIA TION TAIL! or CONTENTS Sectioa . TAIL! OP CONTIH'tS SUMKAILY AMI> CONCLUSIONS 1* INTI.ODUCTION II FDZ DOOi. ASS!KILT !V.&.LUA?I011 Title -.. 1 Ui l 2 ... 
...... * *
* PACTOIY MUTUAL IUIAIOt COIPOIAnON StJMMAlY ANl> CONCLUSIONS An evaluation of ,elected fire door* and fraae1 protectin1
**fety related area* vH conducted f~r_ th* Penn17lval11a Power and ~_1ht Co. (PP&L.>. at Su1quehatma St ... !lectric Station, UD.1t11
* 2. The purpo1e of the evaluation vaa to esaaine_ certaia unlabeled doar aaaeablie1 aud render au opinion Oil their fire re1l1t&a.ce ratilll* Thia evalut1on n1 requHted bJ PP&.L u
* 1upplunt to the or111nal eYalu.tion contained 1n a Factory Mutual report dated JanuarJ 1985t . . Suppleaeut 1 dated Au1uat 1985,_ ~uppleaent 2 dated June 1986 a_nd Suppleaeut 3 daud May 1987. *It*** concluded that the *pecial.purpoae (water tiaht) 4oor aaaeablie* . identified**
Door* 14, 13 and 24 abouldprOT1**
a lliniaua of 1~112 houri fire re111iuce
* 111 
-*--* *
* I* [ PACTOIY MUTUAL llSIAICH COl,OIATION I IHTRODUCTION The plant waa v1i1ted 1D July 1987 by L. J. -Mattern., !'KEA, Loa* ,reventioa Spec1al1at.
'l'bree door* aud fraae1-vere ez&llined dur1n1 tb11'v111t. lbe information gathered duri=a tbil 0&11.iution
*** tbea forwarded to---tbe Appro*ala D1v11l0D for evaluatiOD*
'Iha a1aeablie1 are located in Unit 1 and 2 leactor Buildinga.
The wr1tar 11 a11 bgiDeer in tbe Approval*
Din.don of factory Mutual and baa 7 year* of espedence.
*prtur11J 1D the auc:lear iduatry. IU.1 priury re*pon*ib111tJ 11 te,t1aa and deter.iuatio1i of fire reat,tanca of bu1ld1na aaterial*
and fire rated ***eab11***
.. --.... 1 *'I' 
.... .. ** ** 1
* I , ACTOIY MUTUAL IUIAICM COl,OIA noN II Fill DOOi ASSOOLY EVA.UUTIONS Three unlabeled apec1al purpo** (water ti&ht) fire door ***e*bl1ea
*ere e.zaala*d duri111 th1* T11it to the Suaquehaana Steaa Electric Station at the requaat of the Pena*JlTania Power and L11ht CoapaaJ (PPIL) 2.1 FID DOOi. ASSEKBLDS
 
====2.1.1 Locat10D====
th* door* esaaioed **r* located at !.levaticna 645 and **r* identified**
*r :Door, 14, 23 and 24. J)ocno 14 H;&ratH Ude 2, A ad 1, Core Spra7 Puap l.oou; Door 23 Hparatea UD1t 1, A and I, ID Puap Roou ad Door 24 HparatH lhl!t 2. A ac.d I, Ul Puap loou. 2.1.2 Couatructioa
** * -*The thr** door* *ar* iz:aapectad and toWld to he idaa.tical to 01Se a11othar.
They au*ur* l ft wide z 7 ft h11h ad CODalat of a 1/4 1th at*el. plate witb 1ta.s2111.
s 3/16 ia. *t*el chaael *. Tbere are 2 b.1111** waltled 1:0 tb* clon * . . . 1-and fr-proride4 with 5/8 ia.. dl ... ter pi~** 1.acll door la eqaipped With twelTe ateel bar latcbe* oparated ,,*a ceater aouated wheel type operator.
Tile latch thrDWa are l~l/4 111. loq u.d enaaa* th* _5/8 ta. thick ateel fr* .. on tbe top, _bottoa acd 11dH. the doon are rub'ber aaakatecl to wake a waterproof H&l with tbe 5/8 ia. thick 1t*al fr ..... Door* 23 u4 24 are
* aounted ill 36 in. thick ra1D.f orced cncrete wall*. Door 14 11 aountad. 1a a 30 111. thick re1Dforced coccr*t* wall. 2.1.3 !Yaluat101l Tbeae 3 door* were fomul co be 1cl*t1cal to a door wbicb bad bea . prerioualJ evaluated ltJ Suual 11. Km.pt of factor, Nu~ual ReHudl Corporat10D witb conclu1toa cODtaila_.
la a report entitled *!Yaluat1oa of Selected r1ra Door ud Door lraM '-**l>>11H*
dated Jnuar, 1985. the door praviouaiy e*alaated 1* 1de11tifted
** Door 13 aa.4 referenced 1a Sectioa 2.2, Special Pu.rpoaa Door, 111 the aboH note4 report. the cncluain ill that repon 11 that Door 13 -.oul.4 P':~ida a a1i11m of 1-1/Z hour* of fire r*1i1tace.
2.1.4 Ccn:,.clu1ioa .Door, 14, 13 and 24 ~ould pro'Yide a ailliaua of 1-1/2 hour* fire re1lataac:a.
2 
* *
* Rev. 10 SSES-FSAR APPENDIX A DEVIATION REQUEST NO. 3 ATTACHMENT 6 DR3A6-1 . G:\Lic Docs\FPRR Approvec11Deviations\fpd_0700_03.doc 
* *
* TECHNICAL REPORT -EVALUATION OF SELECTED FIRE DOOR -AND DOOR FRAME ASSEMBLIES (SUPPLEMENT
~) . Susquehanna Steam Electric Station Units 1 & 2 By Jeffrey E. Gould Prepared for: Pennsylvania Power and Light Company "Susquehanna Steam Electric Station" Route 11 Salem Township, Pennsylvania 15635 J.I. 3XOQ2.AM (Class File 4104) March 1994 . -Factory Mutual Research DR3A6-2 . 
* *
* NOT to be distributed outside the FACTORY MUTUAL SYSTEM, ex.cept by CLIENT. TECHNICAL REPORT EVALUATION OF SELECTED FIRE DOOR ANO DOOR FRAME ASSEMBUES (SUPPLEMENT
: 5) Prepared for Pennsylvania Power and Light Company*' Susquehanna Steam Electric Station Route 11 Salem Township, Pennsylvania 15635 -I I. March 1994 Factory Mutual Research 1151 Boston-Providence Turnpike P.O. Box 9102 Norwood, Massachusetts 02062 DR3A6-3 Report Prepared.
By: *Ut E.~ JeM}6oukt, P.E.
* Assistant Section Manager Report Appr~ved By: *$" /George A. Smith~ P.E. Manager, Building Materials Section I I i I FACTORY MUTUAL RESEARCH COllPORATION TABLE OF CONTENTS *
 
==SUMMARY==
ANO CONCLUSIONS Page 1 INTRODUCTION Page2 FIRE DOOR ASSEMBLY EVALUATION Pages 3-6 .,
* DR3A6-4 
------* ---..... * *
* FACT ORV MUTUAL Rf5&#xa3;ARCH CORPORATION
 
==SUMMARY==
AND CONCLUSIONS An evaluation of selected fire doors* and frames was conduded for the Pennsylvania Power and Light Co. (PP&L) at Susquehanna Steam Erectric Station, Units 1 & 2. The purpose of the evalL:Jation was to examine certain openings in an attempt to determine an anticipated fire resrstance rating or to make recommendations regarding modifications that could be made in order to achieve* anticipated fire resistance ratings. This evaluation was requested by PP&L as a supplement to the original evaluation contained in a *Factory Mutuaf Research Corporation (FMRC) report dated Janua,y 1985, Supplement
: 1. dated August 19B5; Supptement
: 2. dated June 1986; Supplem~mt 3 1 dated May 1987; and Supplement 4, dated August 1987. It was concluded that the openings met anticipated fire resistance ratings or could be modified to meet anticipated fire resi~tance ratings . DR3A6-5 FACTORY MUTUAL RESEARCH CORPORA TlON INTRODUCTION The facifity was visited on March 7, 1994 by Jeffrey E. Gould, Assistant Section Manager/Project Engineer of the Building Materials Section in the Approvals Division of FMRC. The writer has 14 years of experience.
hatf in the nuclear industry and the other half in fire endurance testing of building materials.
including fire doors and frames. DR3A6-6 * * * 
* *
* 1ACTORY MUTUAL RESEARCH CORPORATlON FIRE DOOR ASSEMBLY EVALUATION An examination was conducted of 11 openings.
Each opening 'Contained an existing fire door frame and a door (or pair of doors). The assembUes were examined for_overan general condition, size of opening, type and condition of the wall, type of frame, number and location of hingesland clearances between doors and frames. The results were then compared to documented industry standards and requirements and , engineering judgment acqulred from past experience.
e*as~ on this, an assessment was made as to the anticipated fire endurance capabirdies of the assembUes.
Many of the openings contained labeled doors and framest but had either been modified or contained excessive clearances.
An* assessment was made as to the impact, ii any, of the modifications or corrective action necessary to reduce the clearances to acceptable levels. The following information applies to all openings unless noted otherwise:
: a. All frames were standard profile steel frames incorporating 518 in. (16 mm) mini.mum stops. Several had been modified to include additional
~erfal for air leakage resistance.
This will not adversely effect the anticipated ratings. b. f'II frames were installed in sofid, reinforced concrete waifs. As such, it was not possible to examine the system used to anchor the frames to the wall without destroying the integrity of the assembty.
It is assumed that all frames wer~ property anchored when instaned.
: c. AH doors were constructed of steel, were of fire rated construction, were 1-3/4 in*. (44 mm) nominal thickness, sized for a nominal opening of 36 ln. x 86 in. (.9 m x 2.2 m). and* contained three steel hfnges property located. d. Latch throws on all doors were adequate.
: e. Anticipated hourly ratings shown below assume that all recommended corrective actionsj if requiredt have been completed . DR3A6--7 Door ID 505 415 70 543 469R S187 S190 1491 1496 1495 i4n 1} 2) 3) Rating {Hrs) 1*1/2 3 3 3 1.112* 1-1/2 3 1-1/2 1-1/2 1-1/2 1/2 fAC10RY MUTUAL IE$EARCH CORPORATION OveNiew of Findings Deficiency Corrective Action Reg'd. No label No Clearances Yes Clearances Yes Clearances Yes Clearances Yes Cracks Yes Clearances Yes Clearances Yes Crack Yes Hardware Yes Clearances Yes Findings/Recommendations
* Comments Pair of doors Pair of doors Pair of doors Pair of doors Door 505 was examined and found to be missing labels denoting fire resistance ratings. No other deficiencies were noted. No corrective action ts required and the assembly may be considered to be equivalentto a 1-1/2 hour rated assembly.
poor 415 was examined and found to contafn excessive clearances(>
1/4 in.) between the top . of the door and frame (on both sides). An excessive clearance was also noted along the latch edge near the top of the door. SmatJ holes were also noted at the latch location on both sides of the door due to a change in hardware tom that originally installed.
Recommendation:
This door should be replaced with a 3 hour fire rated (and labeled) door. While modifications can be made to correct the gap at the top. I am hesitant to modify the side of the door or patch the holes at the latch location since this is a 3 hour rated assembly.
If the door could be rehung such that the clearance of the side was 1/4 in. or less and the hardware was replaced with hardware Ulat completely covered the holes at the latch location, then the top of the door could be modified in accordance with Ill. 1 and the door not replaced.
Short of this. the door should be replaced.
poor 70 was examined and found to have excessive clearance at the bottom of the door, holes in the head and sill for top and bottom bolts, and two (2) screws in the upper right comer of the door to fill in small holes. 4-DR3A6-8 * * ** 
* *
* 4) 5} 6) 7) FACTORY MUTUAL RESEARCH CORPORATION Recommendation:
A sloping sill made from noncombustible material (concrete, mortar, etc.) should be provided at the base of the door such that the maximum clearance under the door is no greater than 3/4 in. The siD should extend through the opening. The presence of the screws in the area where they are located, while not desirable, wiTI not adversety affed the rating in my opinion. The holes in the top and bottom of the door should be repaired in accordance with Ill. 2. Door 543 was examined and found to have excessive clearance along the top edge of the door. Recommendation:
Repair the top of the door in accordance with HI. 1. Door 469R was examined and found to have excesstve clearance along the top edge of the door. Recommendation:
Repair the top of the door in accordance with Ill. 1 or 3. Door S*187 was examined and found to have a significant crack in the metal near the hinge. do not feel that this can be adequately repaired.
Recommendation:
Repta~e the door with a 1*1/2 hour fire rated and labeled fire door . Door S-190 was examined and found to be a paJr of doors. The only c;leficiency noted was the absence of an astragal.
Recommendation:
Add an astragal as shown in ID. 4. A door coordinator should also be provided.
: 8) . Door 1491 was examined and found to be similar to door S*190 mentioned above. ' Recommendation:
Add an astragal as shown in Ill. 4. Since one door is inactive, a coordinator is not needed. 9) Coor 1496 was examined and found to be a pair of doors. The inactive door was splitting and cracking due to unexpected contacUfriction with the active door at their meeting edge. The active door did not appear to be hung property.
: 10) Recommendation:
Replace the inactive door with a *1-112 hour rated and labeled fire door. Sf the active door cannot be satisfactorily rehung,_ it should also be replaced with a 1-1/2 hour rated and labeled fire door. Door 1495 was examined and found to be a pair of doors. The only deficiency noted was a missing bottom bolt in the inactive door. DR3A6-9 FACTORY MUTUAl HSEARCH COiPORATtON Recommendation:
Replace the bottom bolt in the inactive door leaf. 11) Door 1477 was examined and found to have excessive clearance between the top of the door and the frame. Recommendation:
Repair the top of the door In accordance with lll. 1. CONCLUSfONS The above referenced fire door and frame assembUes will provide the anticipated fire -resistance, as noted, upon completion of all recommended corrective actions, if any, or when replaced by rated and labeled fire doors when noted. Attachments:
rn. 1e4 -6. DR3A6-10 * *
* FMRO COMPUTATION SHEET J.L 3XCQ2, Am APPENDIX -.._ IUUSTIATION 3( 4 wiJ:===========;:==~,tw'E~===il~ISIE.ET~HO
====;::::, ====== 1'ioT To 4jcAI.! &deg;";~ o. M1 A I NUJ d'On~\ ~~fC \ (1",iQ .. r ,a~ .. mt.I\ \. r,::::::===-i TQc.k t>~e1J --{ FS) .f' cM:.. * -* _J A ILL. l !ELEV) :tLL. 2 ( PL/\N) I . I ' ---' A-A DR3A6-l1 
--***---*
*----------------
FMR.C JJ. J)(oQ2.Al'l APPENDIX -L~:===~=========:::::::;:;:,~=::::U=S11RA==noN==;:11~<=2.::=:=:======.::1
====*= ..... SHEEf No. REPORT NQ. 1'lo-r TD Scale. COMPUTATION SHEET **
* Toc-.k l,J~\J (NS t S:S, 4 "o::.) A I _J A A-A s~ N\e.~ sc.rews ... 2"f'I'\~ t('T't'\ '12>f ibo,.lO,<<'
""O(. *ci\cT'\~
\tl\d Th L &#xa5;4** . Ju..., cwa~\ ( 1, zo* *hw:.tM~, k,T~ ooJ w~ '1o 5'iit) (s"\\ ltnr-b'tJe.or'i
* :rt.L + (PLA~) DR3A6-l2 SSES-FPRR TABLE DR3*1 FIRE DOORS -NON-RATED Wall Between Fire Zones Unit Number Door Number DoorType FM Report 1-1A/1-1B 1 13 I 1/85 1-1 E/1-1 F 1 23 I 8/87 .. 1-2A/1-2B 1 111 II 8/85 1-3A/1-3B-N 1 201 II 8/85 1-4A-S/1-4G 1 407 II 6/86 1-5A-W/1-5E 1 515 Ill 8/85 1-58/1-SA-N 1 531 Ill 5/87 2-1A*/2-1B 2 14 I 8/87
* 2*1 E/2-1F 2 24 I 8/87 2-11/2-6A 2 115-R Ill 5187 2-2A/2*2B 2 112 II 6/86 2-3A/2-3B-N 2 202 n 6/86 2-4A-S/2-4G 2 408 Ill 5/87 2-SE/2-SA-W 2 514 lfJ 6/86 2-5A-S/2-5B 2 530 Ill . 6/86 2-4G/2~A 2 711 II 6/86 2*5A-S/2-4G 2 505 u 3/94 ** Rev. 10 Page 1 of 1 G:\Uc Docs\FPRR Approved\
Tables\Devtables\OevtablasVpdt_
0700_3_ 1.doc 
----------------------------------
--~------*-*
____ ., __ _ * * ** SSES-FPRR APPENDIX R DEVIATION REQUEST NO. 4 WRAPAROUND AREA DEVIATION REQUEST: On the east side of each reactor building at elevations 683'-0'\ 719'-1 fl' and 749*.1 n, there is no physical fire rated barrier separating the north and south fire areas. To meet the intent of 10CFR50 Appendix A Section 111.G, an area 66 .. feet wide (Le., 50 foot wide with a plus 8 f cot tolerance on either side) has been provided as a spatial separation distance between the north and south fire areas. This area is called the Wraparound Area and it is intended to function in a manner equivalent to a fire barrier having a 3-hour fire rating as required by Appendix R Section 111.G.2.a.
* The Wraparound Area has a physical volume associated with it and the potential exists for having components and/or cables from both redundant safe shutdown paths contained within it. To provide a level of protection equivalent to that required by Appendix A Section 111.G, any one of the following*methods may be used to protect the redundant
~af e shutdown systems within the Wraparound Area: 1. Providing raceway wrap as protection for cables on both redundant paths for a distance of 50 feet, unless damage to the circuits can be justified based on other criteria acceptable under the requirements of Appendix R. 2. Providing a deviation request which specifically justifies the existing conditions.
FIRE ZONES AFFECTED Unit~ Unit 2 Elevation 683'-0a 1-38-N 2-38-N 1-38-W 2-3B-W 1-3B*S 2*38-S 1-3C .. N 2 .. 3c-N 1-3C-W 2-3C-W 1-3C-S 2*3C-S Elevation 719'-1" 1-4A-N 2*4A-N 1-4A-W 2 .. 4A-W 1-4A-S 2-4A*S Elevation 749'-1 11 1-5A-N 2-SA*N 1-SA-W 2-SA-W 1-5A-S 2-5A*S Rev. 10 DA4-1 G :\Uc Ooes\FPRR Approved\Deviations\fpd_0700_04.doc SSES-FPRR REASON FOR DEVIATION REQUEST: The north and south sides of the reactor building, each of which use different redundant shutdown paths in achieving safe shutdown, are not separated by a continuous rated fire barrier on the east side of the building.
In order to prevent a single fire from damaging both shutdown paths, the Wraparound Area was created to provide spatiar separation between the north and south sides of the reactor buildings.
Within the Wraparound Area, both shutdown paths are protected.
EXISTING ARRANGEMENT:
The 1able below provides a description of each Wraparound Area which includes, the fire zones comprising each Wraparound Area, the fire protection features provided in each Wraparound Area and the presently calculated average combustible loading within each Wraparound Area. Zones ln*Sltu Average Comprising Combustible Wraparound Wraparound DetecUon Automatic Loading In Each Zone Area Elevatlon Area Provided SUPR* Provided (See Note Below) Unit 1: 683'-0" 1*38--W YES YES 6MIN 1-3C-W YES NO 22MIN 719*.1* 1-4A*W YES YES 14MlN 749*.1* 1*5A-W YES YES 3MIN Unit 2: 683'-0'" 2*3B-W YES YES 6MIN 2-SC.W YES NO 2BMIN 719*.1* 2-4A*W YES YES 21 MIN 749*.1* 25A-W YES YES 5MIN Actual in-situ combustible reading durations are provided to document existing arrangement and justify the deviation request. These values are based on the initial combustible toading analysis.
Modifications subsequent to this analysis have revised these values with the possibility ot future modifications revising them again. The governing criteria for the combustible loading anatysis is that the fire resistance rating of the fire area boundaries exceed the combustible loading duration.
The combustible loading durations specified in the deviation request will. not be updated in the future since program commitments require that all modifications be evaluated to assure that additional combustibles are controlled to remain below the fire area fire resistance rating. Rev. 10 DR4-2 G:\Lic Oocs\FPRR Approved\Deviatlons\fpd_
0700_04.doc
* * *
* SSES-FPAR JUSTIFtCATION:
In order for a fire originating in either the north or south sides of the reactor buildings to damage equipment focated in the opposite fire area, the fire must spread across the Wraparound Area. The Wraparound Area is a 66 foot wide physical area of the plant. The intent of the area is to provide a minimum 50 foot spatial separation between redundant shutdown paths in adjacent fire areas. To _accomplish this, an additional 16 feet was added to the separation distance to conservatively compensate for drawing tolerance of +/-8 feet for conduit locations within the Wraparound Area. It is not consid~red feasible for a fire to propagate across any of the Wraparound Areas. This conclusion is based on consideration of the following for the two configurations associated with the areas designated as Wraparound Areas: Configuration
#1: Fire Zones 1-38-W, 2-38-W, 1-4A*W, 1-SA-W, 2-4A-W. and 2-SA-W are all provided with automatic sprinkler protection.
Additionally.
the present calculated average combustible loading (in-situ and transient) in each fire zone is less than 45 minu1es. The combination of low combustible load with sprinkler protection precludes a single fire
* involving both the north and south fire areas.
* Configuration
#2: Fire Zones 1-3C-W and 2-3C-W are not provided with automatic sprinkler protection; however, the physical features of these fire zones preclude the need for such protection.
These fire zones would not be expected to have transient combustibles present during normal operation as they are high radiation areas and access is limited. Additionally, the physical arrangement of valves, piping, platforms, etc. inhibits the introduction and movement of transie,:it combu~tibles.
Each fire zone also contains a space approximately 25 feet wide which divides the zone and contains no cable trays. Therefore, there is minimal in-situ combustibles and no available path for a fire to spread between the North and South areas. Finally, combustible loadings values, which are expected to change throughout the life of the plant, are being programmatically controUed.
The original calculated average combustible loading values have been provided above. This Deviation Request remains valid so long as: The calculated average combustible loading remains below 1-1/2 hours in the Wraparound Areas . Rev. 10
* DR4*3 G:\Uc Docs\FPAA Approved\Oeviations\fpd_0700_04.doc SSES-FPRR The potential for transient combustibles in Fire Zones 1-3c .. w and 2-3C-W remains as described.
* The potential for fire spread via in-situ combustibles in Fire Zones 1 *3C*W and 2-3C*W remains as described.
The increase in the average combustible loading is not a result of the addition of a concentration of combustibles which could result in a single fire that could damage redundant equipment and cables in the north, south and wraparound areas. * *
* Rev. 10 DR4-4
* G:\Uc Oocs\FPRR Approved\Deviations\fpd_07C>p_04.doc
*
* SSES-FPRR
* DEVIATION REQUEST NO. 5 HAS BEEN WITHDRAWN
*
* Rev. 10 DRS-1 G:\Uc Oocs\FPRR Approved\Deviations\fpd_0700_05
.doc SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-1 APPENDIX R DEVIATION REQUEST NO. 6 NON FIREPROOFED STRUCTURAL STEEL
 
DEVIATION REQUEST
:
Exposed structural steel supporting the fire area barriers identified below are acceptable and do
 
not require fireproofing.
FIRE AREA/ZONES AFFECTED
:
Tables DR 6-1 and 6-2 provide a list of the affected fire zones. These tables also refer to a series of drawings associated with each fire rated floor slab with non fireproofed structural steel showing the extent of the required fire protection.
 
REASON FOR DEVIATION REQUEST
:
Within the Unit 1 and 2 Reactor Buildings and Control Structure, certain floor/ceiling assemblies are to be upgraded to a 3 hour fire rating, to separate redundant safe shutdown equipment. The structural steel supporting these floors is not protected.
 
JUSTIFICATION
:
UNIT #1 AND #2 REACTOR BUILDINGS
:  Structural steel associated with each of the Unit #1 and #2 Reactor Building fire barriers required to be upgraded was examined and the evaluation criteria applied to demonstrate that fireproofing of this structural steel is not required was developed in the "Summary Report for Structural Steel Evaluation". To clearly demonstrate the applicability of this criteria to the fire area barriers in question, a drawing of each area, corresponding to the Fire Zones listed in Table DR 6-1, is attached to this deviation request along with an area unique justification for each drawing. These drawings show the barrier area in question, the structural steel members supporting the barrier and the primary combustibles relevant to each area. Each drawing's corresponding unique justification references the section of the Summary Report for Structural Steel Evaluation that provides the basis for that justification.
CONTROL STRUCTURE
:
There are several floor fire barriers in the Control Structure whose structural steel beams are not fireproofed. The extent of each of these barriers vary throughout the building; they are clearly defined in the drawings referenced in Table DR 6-2 of this exemption request.
 
The following sections provide justification for each upgraded floor barrier where steel beams are not fireproofed.
 
STEEL BELOW SLABS ELEVATION 676'-0, 686'-0, 698'-0 AND 714'-0 An analysis of the floor fire barriers for these elevations demonstrate that the structural steel beams are adequate for the combustible loading present in Fire Zones 0-21A, 0-22A and 0-24E.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-2 NOTE: Only the steel above Fire Zone 0-24E (below elevation 714' 0) is not fireproofed. The remaining main floor steel below elevation 714'-0 is fireproofed.
The analysis for each of these fire barrier has been done utilizing the criteria developed in the "Summary Report for Structural Steel Evaluation". In particular, Section 3.2 - Energy Balance Method and Section 3.3 - Two Horizontal Cable Tray Criteria were utilized to demonstrate the adequacy of the structural steel beams.
 
Based on the results of the analysis, steel beams above Fire Zones 0-21A, 0-22A and 0-24E will not be adversely affected as a result of a postulated fire in any of these fire zones.
 
STEEL BELOW SLAB ELEVATION 754'-0
 
Automatic detection and protection is provided below the exposed structural steel. The majority of the combustibles in the area below the exposed structural steel are cables. The majority of the cables are located either below the raised (computer type) floor or along the south walls of the Control Structure where only one structural member is effected. There is approximately 20 feet between the raised computer floor and the exposed structural steel supporting elevation 754'-0. Finally, the Control Room comprises the majority of the area beneath this steel and it is continuously staffed.
 
STEEL INSIDE HVAC CHASES
 
Structural steel beams inside the HVAC chases do not require fire proofing.
 
The analysis which considers Fire Zones 0-24I, 0-24K and 0-28S indicate that these fire zones contain minimal amounts of combustibles; therefore, damage to the steel is highly unlikely.
 
STEEL BELOW SLAB ELEVATION 783'-0 Only the steel above Fire Zones 0-28A-I, 0-28A-II, 0-28B-I, 0-28B-II and 0-28H need justification. This steel (below elevation 783'-0) is considered adequate for the combustible loading present.
: 1. Fire Zone 0-28H is the Cold Instrument Repair Shop containing minimal combustibles; therefore, damage to steel due to a fire is highly unlikely.
: 2. The primary in-situ combustibles in Fire Zones 0-28A-I, 0-28A-II, 0-28B-I and 0-28B-II are due to various electrical panels and electrical raceway firewrap (Thermo-Lag).
The reasons for the justification are as follows:
a) All of the panels are separated by either a block wall, or by distance. If a fire was to occur in one of the panels, it will be delayed or contained within the panel.
b) All of these fire zones have ionization detection. This will give early indication for site personnel to respond.
c) Various electrical raceways are wrapped with fire barrier material in these fire zones. Even though firewrapping (Thermo-Lag) on these electrical raceways is considered a combustible material, it has a high ignition temperature (1000
&deg;F) and requires a large amount of heat (from an external source) before it will ignite or SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-3 spread a flame laterally. Other combustible loads in the fire zones discussed above will not be sufficient to ignite or propagate a Thermo-Lag fire based on inspection.
Because of the nature and arrangement of the combustibles in these fire zones, it is rather unlikely to ever have a raging fire where all of the panels will be on fire at the same time. This in fact eliminates the possibility of generating sufficient heat to produce structural damage to the
 
steel.
Based on the above justification, steel beams above fire zones 0-28A-I, 0-28A-II, 0-28B-I, 0-28B-II and 0-28H will not be adversely affected as a result of a postulated fire in any of these
 
fire zones.
 
The structural steel beams above the 125V and 250V Battery Rooms (Fire Zones 0-28C, 0-28D, 0-28E, 0-28F, 0-28G, 0-28I, 0-28J, 0-28K, 0-28L, 0-28M, 0-28N and 0-28T) do not require fireproofing due to the minimal amount of combustibles contained within each battery room. A specific fire hazards analysis was performed to evaluate the impact of the combustible configuration of each fire zone on the overhead structural steel beams. The analysis conservatively evaluated the ideal burning rates of the batteries in each room and calculated the time required to heat the structural steel beams in each room to the assumed failure temperature. Based on this analysis, fireproofing of the overhead structural steel beams is not
 
required.
 
STEEL BELOW SLAB ELEVATION 806'-0 Steel beams below slab elevation 806'-0 are adequate because there are minimal combustibles in Fire Zones 0-22B and 0-29A. These fire zones are part of the north and south Control Structure stairwells.
 
Therefore, steel beams above Fire Zones 0-22B and 0-29A, below elevation 806'-0, cannot be adversely affected by a fire because of the lack of combustibles.
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-4 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-1F
 
Reference Drawing C-206006, Sheet 1
 
DESCRIPTION
:
The fire rated floor slab in question is 2'-9" thick and the top of slab is at elevation 683'-0". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The source of combustibles in this area is two horizontal cable trays located approximately 12' beneath the bottom of the structural steel
 
beams.
EVALUATION
:
Section 3.3 of the Summary Report for Structural Steel Evaluation provides justification for the adequacy of structural steel for a combustible configuration of two horizontally stacked cable trays. The two cable trays in this fire zone are located approximately 12' beneath the bottom of the structural steel beams whereas the cable trays discussed in Section 3.3 of the report are only one foot below the steel beams. This increased distance adds to the margin of safety already contained in the Section 3.3 analysis.
 
CONCLUSION
:  The fire rated floor slab above Fire Zone 1-1F as shown on Drawing C-206006, Sheet 1, will not be adversely affected by a fire in Fire Zone 1-1F since a postulated fire in Fire Zone 1-1F would not generate sufficient heat to weaken the structural steel beams supporting the fire rated floor
 
slab.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-5 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-1E
 
Reference Drawing C-206006, Sheet 2
 
DESCRIPTION
:  The fire rated floor slab in question is 2'-9" thick and the top.of slab is at elevation 683'-0". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. There are no cable trays in Fire Zone 1-1E located beneath this fire rated floor slab.
 
EVALUATION
:
With no cable trays located beneath this fire rated floor slab, sufficient heat to adversely affect the fire rated floor slab would not be generated. Section 3.3 of the Summary Report for Structural Steel Evaluation provides justification for the adequacy of structural steel for a combustible configuration of two horizontally stacked cable trays. This area has no cable trays.
 
CONCLUSION
:
The fire rated floor slab above Fire Zone 1-1E as shown on Drawing C-206006, Sheet 2, will not be adversely affected by a fire in Fire Zone 1-1E since a postulated fire in Fire Zone 1-1E would not generate sufficient heat to weaken the structural steel beams supporting the fire rated floor slab.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-6 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-3A
 
Reference Drawing C-206007, Sheets 1 & 2
 
DESCRIPTION
:  The fire rated floor slab in question varies in thickness from 2'-9" to 4'-9" as shown on the reference drawing, Sheet 2. The top of the entire slab is at elevation 719'-1". The source of combustibles beneath this fire rated floor slab is a series of horizontal and vertical cable trays as depicted on the reference drawing. It should be noted that the top two trays are fire wrapped with Thermo-Lag 330-1.
EVALUATION
:
A structural analysis was performed on the 4'-9" thick portion of the reinforced concrete slab above the fire zone in question. The analysis demonstrated that this reinforced concrete slab is capable of supporting itself without the W21x127 beams which underlie it. The only required structural steel beams beneath the 4'-9" thick slab are the W21X127 steel beams (with a 2" thick steel plate on the bottom flange) which lie directly under the 4'-6" thick walls.
 
The required steel beam south of column line 25 is protected from the effects of a fire by the NFPA 13 sprinkler system. Section 3.4 of the Summary Report for Structural Steel Evaluation provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though the top two cable trays are wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section 3.4 which is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material. Therefore, the combustible configuration beneath this required steel beam is bounded by the analysis in Section 3.4.
 
The required W21X127 steel beam north of column line 25 was analyzed by the Energy Balance Method as developed in Section 3.2 of the Summary Report. Even though this area is now protected by a NFPA 13 sprinkler system, this analysis method is still valid. This analysis calculated the ratio of the critical energy needed to heat this structural steel beam to the critical
 
temperature (E Ct) to the predicted heat release for this combustible configuration (H') to be 1.17 which is greater than the required minimum value of 1.0.
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-7 Even though the top two cable trays are wrapped with Thermo-Lag which is considered to be a combustible material, the heat release of the Thermo-Lag is bounded by the cable tray heat release analysis. The cables within the cable tray will not contribute to the fire, since the Thermo-Lag firewrap will protect them from burning. This analysis verifies the structural integrity of the required W21X127 steel beam.
 
A structural analysis was also performed on the 2'-9" thick portion of the reinforced concrete slab above the fire zone in question. This analysis demonstrated that this reinforced concrete slab is capable of supporting itself without the two W24X55 steel beams which underlie it. This slab is supported on the south end by the W21X127 (acceptability as discussed above) and on the north end by the 2'-0" thick concrete wall beneath the slab. Therefore, the heat effect on the W24X55 steel beams is inconsequential since the 2'-9" concrete slab is structurally acceptable without these 2 steel beams.
 
CONCLUSION
:
Based on the above evaluation, the fire rated floor slab above Fire Zone 1-3A will not be adversely affected as the result of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-8 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-3B-W
 
Reference Drawing C-206021, Sheet 1
 
DESCRIPTION
:  The fire rated floor slab in question is 2'-3" thick with the top of slab at elevation 719'-1". This reinforced concrete slab acts compositely with the structural steel beams which support this floor elevation. The primary source of combustibles in this area is cable trays.
 
EVALUATION
:  The portion of Fire Zone 1-3B-W located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zone 1-3B-W, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting the fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. The combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-9 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-3B-W
 
Reference Drawing C-206021, Sheet 2
 
DESCRIPTION
:  The fire rated floor slab in question is 2'-3" thick with the top of slab at elevation 719'-1". This reinforced concrete slab acts compositely with the structural steel beams which support this floor elevation. The primary source of combustibles in this area is cable trays.
 
EVALUATION
:  The portion of Fire Zone 1-3B-W located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zone 1-3B-W, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting the fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. The combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-10 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-4A-W Reference Drawing C-206008, Sheets 1 & 3
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9" thick south of column line 26.5 and 3'-3" thick north of column line 26.5 as depicted on the reference drawing. The top of the entire slab is at elevation 749'-1". This reinforced concrete slab acts compositely with a series of structural steel beams which support this floor elevation. The source of combustibles in Fire Zone 1-4A-W consist of a number of cable trays located throughout the fire zone. Some of these cable trays are wrapped with Thermo-Lag which has been determined to be a combustible material.
EVALUATION
:
The portion of Fire Zone 1-4A-W located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zone 1-4A-W, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting the fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though some of the cable trays in the vicinity of the structural steel are wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section 3.4 which is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material. Therefore, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:  Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-11 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONES 1-4A-W AND 1-4A-N
 
Reference Drawing C-206008, Sheet 2
 
DESCRIPTION
:  The fire rated floor slab in question is 1'-9" thick and the top of the slab is at elevation 749'-1". This reinforced concrete slab acts compositely with a series of structural steel beams to support this floor elevation as shown on the reference drawing. The primary source of combustibles in this area is two cable trays spaced approximately 12' from each other. Some of these cable trays are wrapped with Thermo-Lag which has been determined to be a combustible material.
EVALUATION
:
The portion of Fire Zones 1-4A-W and 1-4A-N located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zones 1-4A-W and 1-4A-N, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting the fire rated floor slab system. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation.
This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though some of the cable trays in the vicinity of the structural steel are wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section 3.4 which is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material. Therefore, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:  Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-12 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONES 1-4A-W AND 1-4A-S Reference Drawing C-206008, Sheet 4
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9" thick with the top of slab at elevation 749'-1". This reinforced concrete floor slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The source of combustibles beneath this fire rated floor slab is two vertical cable trays which are separated from each other by approximately 20'.
These cable trays are wrapped with Thermo-Lag which has been determined to be a combustible material.
EVALUATION
:
The portions of Fire Zones 1-4A-W and 1-4A-S located beneath the fire rated floor slab in question are protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in these portions of Fire Zones 1-4A-W and 1-4A-S, actuation of the automatic fire suppression sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting the fire rated floor slab system. The basis for this evaluation is presented in Section 3.4 of the Summary Report for structural steel evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though the cable trays in the vicinity of the structural steel are wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section 3.4 which is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material. Therefore, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:  Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-13 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONES 1-4A-W AND 1-4A-N Reference Drawing C-206008, Sheet 5
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9" thick with the top of slab at elevation 749'-1". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The source of combustibles beneath this fire rated floor slab is cable trays. Some of these cable trays are wrapped with Thermo-Lag which has been determined to be a combustible material.
 
EVALUATION
:
The portions of Fire Zones 1-4A-W and 1-4A-N located beneath the fire rated floor slab in question are protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in these portions of Fire Zones 1-4A-W and 1-4A-N, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting the fire rated floor slab system. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though some of the cable trays in the vicinity of the structural steel are wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section 3.4 which is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material. Therefore, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-14 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-4G Reference Drawing C-206009, Sheets 1 & 2
 
DESCRIPTION
:
The fire rated slab in question is 1'-2-1/2" thick with the top of slab at elevation 761'-10". This slab acts compositely with a series of structural steel beams as shown on the reference drawing. The source of combustibles beneath the fire rated slab consist of two cable trays which vary in elevation but are no closer than 18' from the bottom of the floor slab.
 
EVALUATION
:  Section 3.3 of the Summary Report for Structural Steel Evaluation provides justification that two horizontally stacked cable trays will not adversely affect the integrity of the structural steel beams. The two cable trays in this fire zone are located approximately 16' below the overhead structural steel beams whereas the cable trays discussed in Section 3.3 of the report are only one foot below the steel beams. This increased distance adds to the margin of safety already contained in the Section 3.3 analysis. Furthermore, an analysis using the Energy Balance Method as developed in Section 3.2 of the Summary Report showed the ratio of the critical energy needed to heat the minimum required structural steel members to the critical temperature (Ec t) to the predicted heat release for this combustible configuration (H') to be 6.4 which is much greater than the required minimum value of 1.0. This analysis substantiates the integrity of the structural steel beams above this combustible configuration.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the structural steel beams supporting elevation 761'-10" above Fire Zone 1-4G will not be adversely affected as the result of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-15 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-5A-S Reference Drawing C-206010, Sheets 1 & 2
 
DESCRIPTION
:
The fire rated slab in question is 3'-0" thick approximately 5-1/2' south of column line 27.5 and 1'-9" thick north of this point. The top of the entire slab is at elevation 779'-1". This slab acts compositely with a series of structural steel beams as shown on the reference drawing. The combustibles in Fire Zone 1-5A-S consist of a number of horizontal and vertical cable trays located throughout the fire zone.
 
EVALUATION
:
The portion of Fire Zone 1-5A-S located beneath the fire rated slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zone 1-5A-S, actuation of the automatic suppression system would mitigate the effects of the fire on the structural steel beams supporting this fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. The combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-16 UNIT 1 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 1-5B Reference Drawing C-206010 Sheets 3 & 4
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9" thick and the top of the entire slab is at elevation 779'-1". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The primary source of combustibles in these fire zones located beneath the fire rated floor slab are cable trays of varying elevation and location as shown on the reference drawing.
 
EVALUATION
:
The fire rated floor slab in question is exposed by only two horizontal cable trays. Section 3.3 of the Summary Report for Structural Steel Evaluation provides a discussion of this configuration and justifies the structural steel for a combustible configuration of two horizontally stacked cable trays not less than one foot beneath the bottom of the steel beam. Although these trays are not stacked, one tray is less than one foot from the bottom of the steel beam.
 
The W24X68 beams in this area as well as the G309-5 girder were analyzed by the Energy Balance Method as developed in Section 3.2 of the Summary Report for Structural Steel Evaluation. This analysis determined the ratio of the critical energy needed to heat each required structural steel member to the critical temperature (Ec t) to the predicted heat release for the combustible configuration surrounding each beam (H'). In the bounding case, this ratio (Ec t/H') was determined to be greater than the minimum value of 1.0. This analysis verifies the integrity of all of the structural steel beams in this area in the event of a postulated fire.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, a postulated fire in Fire Zone 1-5B would not generate sufficient heat to adversely impact the required structural steel beams supporting the fire rated floor slab.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-17 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONES 2-1A, 1C, 1D Reference Drawing C-213472, Sheets 1 & 2
 
DESCRIPTION
:
The fire rated floor slab in question is 2'-2" thick west of Column Line R and is 3'-11" thick east of Column Line R. The top of slab is at elevation 670'-2". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawings. The primary source of combustibles in this area is two stacked horizontal cable trays (minimum 2'-4" beneath the bottom of the structural steel beams) and a single horizontal tray which is located approximately 7' horizontally from the stacked trays (minimum 1'-0" beneath the bottom of the structural steel beams).
 
EVALUATION
:
Section 3.3 of the Summary Report for Structural Steel Evaluation provides justification for the adequacy of structural steel for a combustible configuration comprised of no more than two horizontal cable trays with no other cable trays within a four foot distance and not less than one foot below the structural steel. The combustible configuration beneath the fire rated floor slab being reviewed here is bounded by the analysis in Section
 
==3.3
 
CONCLUSION==
:  The fire rated floor slab above Fire Zones 2-1A, 1C, 1D as shown on Drawings C-213472, Sheets 1 & 2, will not be adversely affected by a fire in Fire Zones 2-1A, 1C, 1D since a postulated fire would not generate sufficient heat to weaken the structural steel beams supporting the fire rated floor slab.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-18 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-1F Reference Drawing C-206011, Sheet 1
 
DESCRIPTION
:
The fire rated floor slab in question is 2'-9" thick and the top of slab is at elevation 683'-0". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The source of combustibles in this area is two horizontal cable trays located approximately 11' beneath the bottom of the structural steel
 
beams.
EVALUATION
:
Section 3.3 of the Summary Report for Structural Steel Evaluation provides justification for the adequacy of structural steel for a combustible configuration of two horizontally stacked cable trays. The two horizontally stacked cable trays in this fire zone are located approximately 11' beneath the bottom of the structural steel beams whereas the cable trays discussed in Section 3.3 of the report are only one foot below the steel beams. This increased distance adds to the margin of safety already contained in the Section 3.3 analysis.
 
CONCLUSION
:  The fire rated floor slab above Fire Zone 2-IF as shown on Drawing C-206011, Sheet 1, will not be adversely affected by a fire in Fire Zone 2-1F since a postulated fire in Fire Zone 2-1F would not generate sufficient heat to weaken the structural steel beams supporting the fire rated floor
 
slab.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-19 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-1E Reference Drawing C-206011, Sheet 2
 
DESCRIPTION
:
The fire rated floor slab in question is 2'-9" thick and the top of slab is at elevation 683'-0". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. There are no cable trays in Fire Zone 2-1E located beneath this fire rated floor slab.
 
EVALUATION
:  With no cable trays located beneath this fire rated floor slab, sufficient heat to adversely affect the fire rated floor slab would not be generated. Section 3.3 of the Summary Report for Structural Steel Evaluation provides justification for the adequacy of structural steel for a combustible configuration of two horizontally stacked cable trays. This area has no cable trays.
CONCLUSION
:
The fire rated floor slab above Fire Zone 2-1E as shown on Drawing C-206011, Sheet 2, will not be adversely affected by a fire in Fire Zone 2-1E since a postulated fire in Fire Zone 2-1E would not generate sufficient heat to weaken the structural steel beams supporting the fire rated floor slab.
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-20 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-3B-N Reference Drawing C-206012, Sheets 1 & 2
 
DESCRIPTION
:
The fire rated floor slab in question is 4'-9" thick and the top of slab is at elevation 719'-1". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The primary source of combustibles in Fire Zone 2-3B-N located beneath the fire rated floor slab consist of a number of horizontal and vertical cable trays. The location of these cable trays are shown on the reference drawing. One of these cable trays is wrapped with Thermo-Lag which has been determined to be a combustible material.
 
EVALUATION
:
The entire section of Fire Zone 2-3B-N located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zone 2-3B-N, actuation of-the automatic fire suppression sprinkler system would mitigate the heat effects of the fire on the structural steel beams supporting the fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though a cable tray in the vicinity of the structural steel is wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics, which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section 3.4 which is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material.
Therefore, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:  Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-21 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-3B-W Reference Drawing C-206022, Sheet 1
 
DESCRIPTION
:
The fire rated floor slab in question is 2'-3" thick with the top of slab at elevation 719'-1". This reinforced concrete slab acts compositely with the structural steel beams which support this floor elevation. The primary source of combustibles in this area is cable trays. Portions of one of these cable trays may be wrapped with abandoned-in-place Thermo-Lag  (These cable trays are no longer required to be protected for Appendix R Safe Shutdown).
 
EVALUATION
:
The portion of Fire Zone 2-3B-W located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zone 2-3B-W, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting the fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for structural steel evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though portions of the cable trays in the vicinity of the structural steel may be wrapped with Thermo-Lag, the fire hazards analysis documented in Deviation Request No. 42 has determined that the level of combustibles in this fire zone will not be capable of sustaining a large fire. Therefore, the temperatures required to ignite the Thermo-Lag material will not be reached prior to actuation of the automatic suppression system. In conclusion, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-22 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-3B-W Reference Drawing C-206022, Sheet 2
 
DESCRIPTION
:
The fire rated floor slab in question is 2'-3" thick with the top of slab at elevation 719'-1". This reinforced concrete slab acts compositely with the structural steel beams which support this floor elevation. The primary source of combustibles in this area is cable trays. Portions of these cable trays may be wrapped with abandoned-in-place Thermo-Lag  (These cable trays are no longer required to be protected for Appendix R, Safe Shutdown).
 
EVALUATION
:
The portion of Fire Zone 2-3B-W located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zone 2-3B-W, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting the fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for structural steel evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with regards to cable tray fires. Even though portions of the cable trays in the vicinity of the structural steel may be wrapped with Thermo-Lag, the fire hazards analysis documented in Deviation Request No. 42 has determined that the level of combustibles in this fire zone will not be capable of sustaining a large fire. Therefore, the temperatures required to ignite the Thermo-Lag material will not be reached prior to actuation of the automatic suppression system. In conclusion, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-23 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONES 2-4A-S AND 2-4A-W Reference Drawing C-206013, Sheet 1
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9" thick and the top of slab is at elevation 749'-1". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The primary source of combustibles in Fire Zone 2-4A-S and 2-4A-W located beneath this fire rated floor slab consist of two horizontal cable trays stacked on top of each other as shown on the reference drawing.
 
EVALUATION
:
The entire section of Fire Zones 2-4A-S and 2-4A-W located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in these portions of Fire Zones 2-4A-W and 2-4A-S, actuation of the automatic fire suppression sprinkler system would mitigate the heat effect of the fire on the structural steel beams supporting this fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation.
This section of the report provides justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. The combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-24 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-4A-W Reference Drawing C-206013, Sheets 2 & 3
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9" thick east of column line T and 3'-3" thick west of column line T. The top of slab elevation for the entire slab is at elevation 749'-1". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The primary source of combustibles in Fire Zone 2-4A-W located beneath this fire rated floor slab consist of three horizontal cable trays as depicted on the reference drawing.
EVALUATION
:
The entire section of Fire Zone 2-4A-W located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in this portion of Fire Zone 2-4A-W, actuation of the automatic fire suppression sprinkler system would mitigate the heat effects on the structural steel beams supporting the fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. The combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-25 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONES 2-4A-W AND 2-4A-S Reference Drawing C-206013, Sheet 4
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9", thick and the top of the slab is at elevation 749'-1". This reinforced concrete slab acts compositely with a series of structural steel beams to support this floor elevation as shown on the reference drawing. The primary source of combustibles in this area is two horizontal cable trays. Portions of these cable trays are wrapped with upgraded Thermo-Lag.
 
EVALUATION
:
The portions of Fire Zones 2-4A-W and 2-4A-S located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in these portions of Fire Zones 2-4A-W and 2-4A-S, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting this fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation.
This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though portions of the cable trays in the vicinity of the structural steel are wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section
 
===3.4 which===
is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material. Therefore, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-26 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONES 2-4A-W AND 2-4A-N Reference Drawing C-206013, Sheet 5
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9" thick and the top of the slab is at elevation 749'-1".
This reinforced concrete slab acts compositely with a series of structural steel beams to support this floor elevation as shown on the reference drawing. The primary source of combustibles in this area is cable trays located throughout the fire zones. One cable tray is wrapped with upgraded Thermo-Lag.
 
EVALUATION
:
The portions of Fire Zones 2-4A-W and 2-4A-N located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in these portions of Fire Zones 2-4A-W and 2-4A-N, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting this fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though a cable tray in the vicinity of the structural steel is wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section 3.4 which is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material. Therefore, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section 3.4.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-27 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-4G Reference Drawing C-206014, Sheets 1 & 2
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-2-1/2" thick with the top of slab at elevation 761'-10". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The source of combustibles in this fire zone is two cable trays located greater than 16' below the structural steel supporting this elevation.
 
EVALUATION
:
Section 3.3 of the Summary Report for Structural Steel Evaluation provides justification that two horizontally stacked cable trays will not adversely affect the integrity of the structural steel beams. The two cable trays in this fire zone are located approximately 14' below the overhead structural steel beams whereas the cable trays discussed in Section 3.3 of the report are only one foot below the steel beams. This increased distance adds to the margin of safety already contained in the Section 3.3 analysis. Furthermore, an analysis using the Energy Balance Method as developed in Section 3.2 of the Summary Report showed the ratio of the critical energy needed to heat the structural steel to the critical temperature (Ec t) to the predicted heat release for this combustible configuration (H') to be approximately 6.4 which is much greater than the required minimum value of 1.0. This analysis substantiates the integrity of the structural steel beams above this combustible configuration.
 
CONCLUSION
:  Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the structural steel beams supporting elevation 761'-10" above Fire Zone 2-4G will not be adversely affected as the result of a postulated fire in this area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-28 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-5A-N Reference Drawing C-213469, Sheets 1 & 2
 
DESCRIPTION
:
The fire rated floor slab is 1'-9" thick in the area being rated that is west of column line Q (reference Drawing C-213469, Sheet 1). The top of slab elevation for this portion is 779'-1". East of column line Q (Reference Drawing C-213469, Sheet 2) the slab is 6'-3" thick in the area being rated below the surge tanks vault floor (top of slab elevation is 779'-4") and is 6'-4" thick in the area being rated below the fuel shipping cask storage pool floor (top of slab elevation is 777'-5"). The primary source of combustibles in these areas is cable trays located throughout the fire zone. Some of these cable trays are wrapped with Thermo-Lag which has been determined to be a combustible material. 
 
EVALUATION
:  The portions of Fire Zones 2-5A-N located beneath the fire rated floor slab in question is protected by an automatic fire suppression sprinkler system which has been installed in accordance with NFPA 13. In the event of a fire in these portions of Fire Zone 2-5A-N, actuation of the automatic sprinkler system would mitigate the heat effect the fire would have on the structural steel beams supporting this fire rated floor slab. The basis for this evaluation is presented in Section 3.4 of the Summary Report for Structural Steel Evaluation. This section of the report provides the justification for the NFPA 13 sprinkler system's heat absorption capability with respect to cable tray fires. Even though cable trays in the vicinity of the structural steel are wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. Since the Thermo-Lag material has combustibility characteristics which are enveloped by the cable jacketing and insulation characteristics, the analysis in the Section 3.4 which is performed for cable jacketing and insulation effects will bound those effects from the Thermo-Lag material.
Therefore, the combustible configuration beneath this fire rated floor slab is bounded by the analysis in Section
 
==3.4
 
CONCLUSION==
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, the existing automatic fire suppression sprinkler system can be expected to protect the structural steel beams with a wide margin of safety in the event of a postulated fire in this area.
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-29 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONES 2-5C, 2-5A-S, 2-5B Reference Drawing C-206015, Sheets 1, 2 & 3
 
DESCRIPTION
:
The fire rated floor slab in question varies in thickness from 1'-9" to 2'-3" as shown on the reference drawing. The top of the entire slab is at elevation 779'-1". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The combustibles in these fire zones located beneath the fire rated floor slab are primarily cable trays of varying elevation and location as shown on the reference drawing. A cable tray in Fire Zone 2-5B is wrapped with upgraded Thermo-Lag.
EVALUATION
:
The portion of the fire rated floor slab located north of column line 34.5 has only two horizontal cable trays. Section 3.3 of the Summary Report for Structural Steel Evaluation provides the justification for the adequacy of structural steel for a combustible configuration of two horizontally stacked cable trays. Even though a cable tray is wrapped with Thermo-Lag which is considered to be a combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. The heat release of the Thermo-Lag is bounded by the cable tray heat release analysis in Section 3.3. Therefore, the condition analyzed in the summary report bounds this combustible configuration of two side-by-side horizontal cable trays.
 
The portion of the fire rated floor slab in question located south of column line 34.5 has been structurally evaluated to determine which steel beams are the minimum required to support this entire floor slab area. The results of this analysis concluded that five structural steel beams are necessary to support the floor slab. These steel beams are noted on Sht. 1 of the reference drawing. The other beams are not required since the 2'-9" thick reinforced concrete slab is capable of spanning between these five required members.
 
These five required steel beams were then analyzed by the Energy Balance Method as developed in Section 3.2 of the Summary Report for Structural Steel Evaluation. This analysis determined the ratio of the critical energy needed to heat each required structural steel beam to the critical temperature (Ec t) to the predicted heat release for the combustible configuration surrounding each beam (H'). In all five instances this ratio "(Ec t/H')" was determined to be greater than the required minimum value of 1.0. Even though a cable tray is wrapped with Thermo-Lag which is considered to be a SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-30 combustible material, the combustibility effects of the Thermo-Lag are enveloped by the cable tray combustibility analysis. The cables within the protected raceway are protected so they do not contribute to the fire. The heat release of the Thermo-Lag is bounded by the cable tray heat release analysis in Section 3.2. Therefore, this analysis verifies the integrity of the required structural steel beams in the area in the event of a postulated fire.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath the fire rated floor slab in question, a postulated fire in Fire Zones 2-5C, 2-5A-S and 2-5B would not generate sufficient heat to adversely impact the required structural steel beams supporting the fire rated
 
floor slab.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6-31 UNIT 2 FIRE RATED FLOOR SLAB ABOVE FIRE ZONE 2-6A Reference Drawing C-206016, Sheet 1
 
DESCRIPTION
:
The fire rated floor slab in question is 1'-9" thick and the top of slab is at elevation 779'-1". This reinforced concrete slab acts compositely with the structural steel beams to support this elevation as shown on the reference drawing. The primary source of combustibles in this area is 3 horizontal cable trays stacked on top of each other.
 
EVALUATION
:  The area directly beneath the portion of the floor slab which is fire rated has no cable trays, however, 3 horizontally stacked cable trays are located beneath the W3OX19O structural steel beams which support the area floor slab at elevation 799'-1". These structural steel beams were evaluated by the Energy Balance Method described in Section 3.2 of the Summary Report for Structural Steel Evaluation. This analysis demonstrated that the ratio of the critical energy needed to heat each W3OX19O structural steel beam to the critical temperature (Ec t) to the predicted heat release for the combustible configuration surrounding each beam (H') to be greater than the required minimum value of 1.0. This analysis verifies the integrity of the required structural steel beams supporting the fire rated floor slab in question.
 
CONCLUSION
:
Based on the above evaluation and the specific combustible configuration beneath this fire rated floor slab as shown on the reference drawing, a postulated fire in Fire Zone 2-6A would not generate sufficient heat to weaken the structural steel beams supporting the fire rated floor slab.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-1
 
SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 & 2
 
FIRE PROTECTION PROGRAM APPENDIX R DEVIATION REQUEST NO. 6 NON FIREPROOFED STRUCTURAL STEEL
 
==SUMMARY==
REPORT FOR STRUCTURAL STEEL EVALUATION
 
REVISION 2 10/87 
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-2
 
==SUMMARY==
REPORT FOR STRUCTURAL STEEL EVALUATION
 
==1.0 INTRODUCTION==
 
===2.0 METHODOLOGY===
3.0 CRITERIA AND JUSTIFICATION
 
===3.1 General===
Criteria
 
===3.2 Technical===
Basis 3.3 Two Horizontal Cable Tray Criteria 3.4 NFPA 13 Sprinkler Criteria 3.5 Case-by-case Fire Protection Evaluation
 
===4.0 RESULTS===
 
===5.0 MODIFICATIONS===
 
===6.0 SCHEDULE===
 
===7.0 COMPENSATORY===
MEASURES
 
==8.0 CONCLUSION==
 
APPENDIX A - Figures
 
APPENDIX B - References
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-3
 
==SUMMARY==
REPORT FOR STRUCTURAL STEEL EVALUATION UNIT 1 & 2 REACTOR BUILDINGS APPENDIX R DEVIATION REQUEST NO. 6
 
==1.0  INTRODUCTION==
 
Deviation Request No. 6 was submitted to the NRC in September 1985 (PLA-2529) requesting approval of exposed (non-fireproofed) structural steel which supports fire area barriers in the Unit 1 and 2 Reactor Buildings and the Control Structure.
After reviewing the Deviation Request, the NRC requested additional justification. In response to the NRC request, PP&L submitted the Structural Steel Action Plan to the NRC for their concurrence on February 10, 1986 (PLA-2592).
 
The initial submittal, outlined in Revision 0 to this report, was submitted to the NRC on May 19, 1986.
 
Subsequent to the initial submittal, a meeting was held in the NRC Office in Bethesda, MD on July 30, 1986 to discuss the submittal. During this meeting the NRC requested that PP&L revise their submittal and provide the following:
Consideration of the effects of slab openings and the use of a 100% live load criteria.
Specific details of the areas required to be fire rated.
Our summary report has been revised to respond to the NRC requests. Methodology changes different than those proposed in our action plan submitted with PLA-2592, have occurred as a result of NRC comments. These changes are explained in the report.
This report specifically addresses the fire-rated barriers in the Unit 1 and 2 Reactor Buildings and some barriers in the Control Structure. Fire-rated barriers covered by Deviation Request 06 are located in the Unit 1 and 2 Reactor Buildings and in the Control Structure. The write-up within the body of Deviation Request No. 6 is considered to have adequately addressed the combustible configuration so the subject is not specifically addressed in the report.
 
Finally, in response to concerns expressed verbally by the NRC staff, we have taken the initiative to review all of the structural steel in the Unit 1 and 2 Reactor Buildings regardless of whether or not the structural steel was part of a fire-rated barrier.
 
==2.0 METHODOLOGY==
 
The methodology outlined below, which differs from the methodology outlined in PLA-2592, was used in performing our updated analysis.
 
All structural steel in both the Unit 1 and Unit 2 Reactor Buildings was reviewed. The structural steel framing plan for each floor elevation on each Reactor Building was reviewed and the minimum set of structural steel framing members required to insure structural integrity was selected. This minimum set of structural steel framing members was selected on the premise SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-4 that the thick reinforced concrete slabs used in the construction of the Reactor Buildings are able to span significantly longer distances than the normal beam to beam span required by other design basis accident scenarios. Since these other design basis accident scenarios need not be considered in conjunction with a fire, much of the structural steel installed in the Reactor Building is not necessary to maintain structural integrity for the fire scenario. In selecting the minimum set of required structural framing members, the following restrictions were applied:
 
The reinforced concrete slab must be able to support 100% of the allowable live load shown on the existing structural framing plan drawings. The loss of structural continuity as a result of hatch openings and penetrations must be considered.
The selected structural steel framing beams must be capable of carrying any increased loadings caused by the elimination of adjacent members to the building girders and/or columns. Similarly, the building girders and/or columns must be capable of supporting
 
any increased loading.
 
Each specific concrete slab section was evaluated to assure that the first criteria outlined above was met. Each required structural steel framing member was reviewed for the effects of any additional load imposed on the member and for the effects of the combustible configuration near each member.
 
Any required structural steel framing member with a maximum of two horizontal cable trays in its vicinity was evaluated to be acceptable. (See Section 3.3 - Two Horizontal Cable Tray Criteria for an explanation of and justification of this criteria.)
 
Any required structural steel framing member located in areas protected by an NFPA 13 sprinkler systems was evaluated to be acceptable. (See Section 3.4 - NFPA 13 Sprinkler Criteria, for an explanation of and justification for this criteria.)
All remaining required structural steel framing members were evaluated with respect to fire protection on a case-by-case basis. By reviewing each member and the combustible configuration in the vicinity of the member, the fire protection evaluation determined that structural steel temperatures could not be raised above 1000
&deg;F. The case-by-case fire protection evaluation is explained in Section 3.5.
 
===3.0 CRITERIA===
AND JUSTIFICATION
 
===3.1 General===
Criteria In the past it has been common to calculate the average combustible loading by distributing all calculated combustibles uniformly over the entire floor area and comparing the results with the fire rating of the structure. While this method provides a room-to-room comparison, it fails to consider such parameters as combustible concentration, fuel arrangement, and burning rates. These average combustible loadings have traditionally been compared to fire-rated components tested to the Standard Time Temperature Curve (Ref. 2). More recently, this approach has come under attack as being unconservative in certain applications because it fails to address the condition where the majority of the combustibles in an area are concentrated in a small portion of the area.
PP&L based the structural steel evaluation on a comparison of combustible configuration in each area using actual cable tray fire test data. Cable trays are the predominant fire hazard in SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-5 the Reactor Buildings. The cable tray fire tests referenced take into account the actual fuel arrangement within the cable tray, combustible configuration, and burning rates.
 
The critical steel failure temperature used in the evaluation criteria was based on the 1000
&deg;F average temperature acceptance criteria found in the National Fire Protection Association's standard used for testing fireproofing for structural steel (NFPA-251). Since fireproofing materials are designed to maintain structural steel temperatures below this level, we can conclude that fires which do not heat the structural steel to this critical temperature will not result in loss of structural integrity.
 
This conclusion is further substantiated by information provided by the American Institute of Steel Construction. The American Institute of Steel Construction Manual (Ref. 8) states that steel maintains approximately 63% of its yield strength at 1000
&deg;F and approximately 37% of its yield strength at 1200
&deg;F. The normal A.I.S.C. allowable stress in bending is in the range of 60 to 66% of its yield strength. Since it is reasonable to classify the fire condition as an extreme environmental loading combination, it should follow that for this loading combination the allowable stress should be permitted to approach the yield strength of the material. Therefore, by restricting structural steel temperature to 1000
&deg;F, we are assuring that approximately 63% of the yield strength of the material is preserved. As a result, when we evaluate the structural members for 100% live and dead load and use the normal A.I.S.C. allowable stresses, we are, in fact, satisfying the conditions which would be imposed by a loading combination consistent with the fire scenario.
 
In Section 3.2 of this report, the Energy Balance Method outlined in the previous revision has been expanded to include the heat absorption capability of the concrete. In SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-6 the development of the method it has been assumed that an equilibrium temperature is reached between the structural steel and the first inch of depth of concrete. The assumption of equilibrium concrete heat up to a depth of one inch is considered a reasonable assumption since in actuality the rapid transfer of heat through the air would cause a much larger area than assumed to be heated up. From a structural standpoint heating of the lower 1" of concrete will have a negligible effect on the concrete structural properties since the cover on the reinforcing steel is approximately 4" and in the structural evaluation for slab span capability, the concrete on the underside of the slab is in tension. Tensile concrete is not considered for structural
 
properties.
The following combustibles were generically evaluated, and it was determined that a specific analysis on a case-by-case basis was not required. The remaining combustibles which are represented solely by cable trays are the dominant factor leading to potential high temperatures which would affect structural steel.
 
====3.1.1 Combustible====
Liquids
 
Combustible liquids could present fire exposure to structural steel. The most probable location for heat released, however, would be at the floor level and heat would be released very quickly. The analysis of all fire zones containing combustible liquids, except Fire Zones 1-1G and 2-1G, are bounded by the analysis of Fire Zones 1-1C and 2-1C. Fire Zones 1-1C and 2-1C contain the largest quantity of oil (155 gallons of in-situ oil and, up to, 165 gallons of transient oil) in the smallest room (1374 square feet). This oil is associated with the HPCI Turbine.
Assuming the in-situ 155 gallons or a transient allowance of 165 gallons of oil are spilled on the floor and none of the oil is removed by the floor drains, the calculated fire will not cause a failure of the HPCI Room structural steel. The heat generated during the short duration burning period for this quantity of oil is not sufficient to heat the HPCI Room structural steel to the critical temperature of 1000&deg;F.
The HPCI turbines lube oil system has a maximum oil flow of 60 gpm at 110 psi. The potential for a high pressure leak affecting the steel is low. The piping is seismically designed and automatic open head deluge water spray system protect the HPCI Turbine.
 
Oil sumps located in Fire Zone 1-1G and 2-1G have a 1120 gallon capacity. The construction of these sumps, however, would prevent the ignition and burning of the oil. The sumps are constructed of a steel liner cast into concrete below the Reactor Building Basement. The cover of the sumps is a 1 1/2' thick concrete slab with a 2' x 2 1/2' manhole constructed of a minimum of 3/4" thick steel plate.
 
====3.1.2 Charcoal====
The HVAC units which contain charcoal are provided with fixed deluge systems and are contained within steel enclosures. Because of the physical configuration of the charcoal beds a fire will be slow and smoldering with a low heat release rate. Therefore, these units will not effect building structural steel integrity.
 
====3.1.3 Transient====
Combustibles
 
Investigations by Sandia Laboratories (Ref. 8, Table 3) indicate that transient combustibles produce low heat release rates resulting in room temperatures below 500
&deg;F.
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-7 The presence of transient combustibles is administratively controlled throughout the facility. When present transient combustibles are located at floor level. If transient combustibles are considered along with a cable tray, it would be expected, based on the above referenced Sandia data, that the transient would be an ignition source only if the cable tray was close to the transient combustible. Such a combination of heat release caused by cable trays and transient combustibles at floor level would not effect structural steel located at the ceiling. Additionally, since the structural steel justification was based on 1000
&deg;F critical temperature, there still remains a 300
&deg;F allowance before transient combustibles would produce a local hot spot of 1300
&deg;F (1300&deg;F is the allowable local hot spot temperature during a NFPA 251 test).
 
===3.2 Technical===
Basis This section of the report provides the technical basis used to address the effects of each unique combustible configuration on the required structural steel members.
 
The basic methodology developed in this section is referred to as the Energy Balance Method. The Energy Balance Method provides a means to calculate the energy released from a given combustible configuration, to calculate the energy absorption capability of a given structural mass and to determine by comparing these two calculations whether or not the critical
 
temperature can be exceeded.
 
As discussed below, the Sandia Laboratories' "Fire Retardant Coating Test" (Ref. 1) provides the data necessary to predict the energy release of a cable tray fire. The Sandia Laboratories' "Fire Protection Research Program Corner Effects Tests" Report (Ref. 4) provides additional data to confirm these predictions and predict the heat release effects of the burning cables as a function of the distance of these cable trays from the corner. The heat release data with increasing distance from the corner suggests that the ability of the cables to burn and the resultant energy release is greatly diminished as the reradiation effects typical of the close corner relationship are removed. The energy release figures provided in the corner effects tests are used to baseline the values measured in the "Fire Retardant Coating Tests" and as a conservative prediction of the heat release value to be used in the methodology outlined below.
 
Energy Balance Method
 
Energy Absorption
 
The energy absorption capability of a given structural mass can be calculated as follows:
 
Ec T =  Er x Q
 
where:
 
Ec T = the critical energy needed to heat all the components in a given area to the critical temperature (BTU)
 
Er = Energy required to raise a unit amount of a given component from ambient to the critical temperature.
Q = The total quantity of each component in the area.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-8 The typical components in a given area which would be present to absorb heat are structural steel, concrete, ductwork, piping, air, equipment and even the steel cable tray itself. For purposes of our evaluation only structural steel and concrete will be considered as heat absorbing components.
The heat required to raise the temperature of one pound of structural steel to 1000
&deg;F can be calculated by the following equation:
Er S = CP S x (Tc-To) (Eq. 1a)
 
where:
 
Er S = Energy required to raise the temperature of pound of structural steel from ambient to the critical temperature (BTU/lb)
CP S = Specific heat of steel (Cp = .112 BTU/lb
&deg;F for steel)
To = Pre-fire room temperature = 100
&deg;F  Tc = Critical temperature = 1000
&deg;F  Inserting the given values into equation 1a yields:
 
BTU/lb 8.100)100 1000 (112.==F F F lb BTU Er S  Therefore, approximately 100 BTUs per pound of steel are required to heat the steel to the critical temperature. The critical energy required to heat a given structural member to the critical temperature of 1000
&deg;F is expressed as:
 
Ec S = Er S x W x L (Eq. 2a) where:
 
Ec S = Critical energy needed to heat a given structural steel member to the critical temperature (BTU)  W = weight of structural steel member per foot (lb/ft)
 
L = length of structural steel member subject to direct energy effects (ft)
 
The heat required to raise the temperature of one square foot of concrete 1" deep to 1000F can be calculated by the following equation:
 
Er C = Cp c x (Tc-To) (Eq. 1b) where:
Er C = Energy required to raise the temperature of one square foot of concrete 1" deep from ambient to the critical temperature (BTU/lb)
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-9 Cp c = Specific heat of concrete (Cp - .156 BTU/lb
&deg;F for concrete)
To = Pre-fire room temperature = 100
&deg;F  Tc = Critical temperature = 1000
&deg;F  Inserting the given values into equation lb yields:
 
2/5.1696)100 1000)(12/1)(3/#145 (156.ft BTU F F inch ft ft F lb BTU Er C==  Therefore, approximately 1700 BTUs per square foot of concrete are required to heat the concrete to the critical temperature. The critical energy required to heat a given concrete area to the critical temperature of 1000
&deg;F is expressed as:
Ec C = Er C x A c (Eq. 2b)
 
where:
Ec C = Critical energy needed to heat a given concrete area to the critical temperature (BTU)
 
A C = the effected concrete area Energy Release
 
The energy released from a cable tray can be developed as follows:
 
The heat released from a two-cable tray fire can be predicted from data developed during Sandia Laboratories Fire Retardant Coating Tests (Ref. 1). During small scale testing, Sandia (Ref. 1, Table A-XI) determined the maximum Heat Release Rate to be 134 KW/M 2 which is equal to 11.8 BTU/ft 2 sec.
Sandia performed a full scale free burn test of two stacked 18-inch wide cable trays filled with IEEE 383 cable (Ref. 1 Test 20). The total heat released from this test can be predicted by conservatively assuming the Sandia small scale maximum heat release rate was constant during the entire fire test burn period. This is expressed as:
 
Ht = Hr x At  x  T (Eq. 3)
Ht = Total heat released (BTU)
Hr = Maximum heat release rate (BTU/ft 2 sec) At = Area of cable tray burned (ft
: 2) T = Burn Time (sec)
In this test, the bottom tray was damaged for 24 linear inches and burned 9 minutes. The top tray was damaged for 54 linear inches and burned for 12 minutes. Using this data in equation
 
3 yields:
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-10 BTU x ft inches sq inches x inches x ft BTU 348 , 57 sec 60 min/1 min 12/144 54 18 sec 8.11 Tray Top Release Heat 2 2== BTU x ft inches sq inches x inches x ft BTU 116 , 19 sec 60 min/1 min 9/144 24 18 sec 8.11 Tray Top Release Heat 2 2==  BTU 464 , 76 116 , 19 348 , 57 (Ht) Release Heat Total=+=
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-11 The maximum total heat release per area can be expressed as follows:
 
Hmax = Ht/At (Eq. 4) where:
 
Hmax = Maximum total heat release per area (BTU/ft
: 2)
Substituting our previously developed data into equation 4 yields:
()2 2 2/7842/144 24 54 18 464 76 max ft BTU ft inches inches inches inches BTU , H=+=  This maximum total heat release per area can then be applied to other configurations by the following equation:
 
H' = Hmax x A' (Eq. 5)
 
where:
 
H' =  Predicted heat release for a given configuration (BTU)
A' = Area of cable tray burned for that given configuration (ft
: 2)
Sandia Laboratories also conducted separate corner effects tests of cable trays (Ref. 4) where calorimeters recorded heat flux above the cable tray fires. This additional test series can be used to confirm the predicted maximum heat release value of 7842 BTU/ft 2 and also to determine the maximum heat release values for configurations with different corner configurations.
 
The corner effect test data was obtained during full scale free burn fire tests in a corner configuration. The cable tray type, arrangement, fill and contents were similar to the fire retardant rating tests arrangement. During these corner tests the actual maximum heat flux (heat release rate) was measured by determining the heat release directly above the cable tray with the cable tray located at various distances from the corner (Ref. 5 - Table I and II). The maximum heat flux multiplied by burn time would conservatively indicate the total heat at the
 
upper calorimeter as follows:
 
Hmax = Hf x T (Eq. 6)
 
where:
 
Hf = maximum heat flux (BTU/ft 2 hr)  By substituting the data from the actual corner tests the following data can be generated:
 
Cable Tray Max Heat Flux Burn Time Max Heat Release SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-12 Distance from Corner (Hf) (BTU/ft 2 x hr) (T) (min) /Area Hmax)
BTU/ft 2)    5 in x 10.5 in 18,430 20 6140 BTU/ft 2 10.5 in x 18 in 12,300 24 4932 BTU/ft 2    60 in x 120 in 2,370                25  987 BTU/ft 2 * (See Figure 2.0)
The 6140 BTU/ft 2 is comparable to the 7842 BTU/ft 2 derived from the fire retardant coating test data. This is expected, because at the short corner distance the predicted heat release would nearly equal the measured maximum heat release.
Using this developed data and the results of the Sandia Corner Effects Test (Ref. 4), a determination can be made as to the amount of heat transferred to the structural components in an area due to a fire in a cable tray located some distance below the steel member. It has been
 
determined that 7842 BTU/ft 2 is the maximum heat released at the cable tray or group of cable trays. Figure 1.0 of this report is a reproduction of Figure 7 from the Sandia corner effects test (Ref. 4).
The data in this figure can be used to determine the maximum heat release values as a function of corner configuration.
 
Acceptance Criteria The energy required to heat a given structural mass to 1000
&deg;F is compared with the energy released by a fire in the vicinity of that mass to determine whether or not the fire threatens structural integrity.
 
If the following ratio is satisfied, structural integrity will be assured:
: 7) Eq.(0.1 1 t H Ec  where (as previously defined)
 
Ec t = The critical energy needed to heat all the components in a given area to the critical temperature (BTU).
 
H 1 = Predicated heat release for a given configuration (BTU).
Conservatisms
 
The following demonstrates that the use of this technical basis at Susquehanna is conservative:
 
- The maximum heat release rates used in our analysis were based on cable tray test conducted by Sandia (Ref. 4). In these tests cross linked PE (polyethylene) cables is a loose packed configuration were tested.
EPRI conducted a series of full scale fire tests using the following cable types and packing arrangements:
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-13
- Tightly packed ethylene propylene rubber (EPR)/hypalon cables
- Loosely packed ethylene propylene rubber (EPR)/hypalon cables
- Tightly packed PE cables
- Loosely packed PE cables The results of the EPRI test demonstrated the following relationships.
- The tighter the cable packing, the lower the heat release will be.
 
- The EPR/hypalon cables have a lower heat release than the PE cables.
Since Susquehanna SES used EPR/hypalon cables in a tight packed arrangement, the quantitative test data indicates that the use of the heat release data from the Sandia test has an inherent factor of safety of approximately 8 when applied to our plant.
- The Sandia observed maximum heat release rate data (Ref. 1, 4) was assumed over the entire burn time. During an actual fire, the heat release rate would gradually increase to the maximum and then decrease.
 
- All cable trays were assumed to be full.
- Heat transfer to the room air was ignored.
- Steel was assumed to fail if the 1000
&deg;F critical temperature was reached. The reduced load capabilities of the structural steel at temperatures above 1000
&deg;F were ignored.
- It was assumed that high fire temperatures existed for sufficient time to allow heating of the steel. In many cases the longer heating intervals required for the larger structural steel members will not exist for sufficient time to allow the necessary heat transfer.
 
3.3  Two Horizontal Cable Tray Criteria
 
====3.3.1 Description====
All required structural steel framing members were reviewed. Any member affected by a combustible configuration comprised of no more than two (2) horizontal perpendicular cable trays with no other cable trays within a four (4) foot distance and not less than one foot below the structural steel were determined to be acceptable. (See Figure 3.0.)
 
====3.3.2 Approach====
 
The Energy Balance Method will be used to provide a justification for the criteria by demonstrating that this combustible configuration will not cause temperatures above 1000
&deg;F for the lightest member to which the criteria was applied.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-14
 
====3.3.3 Justification====
 
The following justification is provided to quantitatively demonstrate that the combustible effects from two (2) horizontal perpendicular cable trays one foot below the structural steel are insufficient to cause a structural steel member to be heated to 1000
&deg;F.  (See Figure 3.0.)
 
Therefore, any structural steel member larger than that member justified is acceptable for the described combustible configuration, because larger quantities of heat are required to heat larger steel members.
 
The lightest structural steel member to which this criteria was applied is a W21 x 49.
 
Therefore, a W21 x 49 beam (flange width - 6.52 in, weight lb/ft) and two 24-in wide cable trays must be justified.
 
Energy released at the cable tray
:
From Figure 3.0 it can be seen that the cable tray is 33" below the ceiling. Using a value of 9500 BTU/ft 2-HR for a distance from the ceiling of 30" from Figure 1.0 and using 25 minutes, the longest burn time, from the table on page 10, calculate Hmax for this configuration.
 
Since:
 
H t = H r x A t x t (Eq. 8)
And
 
Hmax = H t / A t (Eq. 9)  Therefore:
: 10) (Eq.602 , 8 2/12 52.6/12 24 958 , 3 958 , 3 max.min 60 1.min 25 9500 max 1 2 1 2 2 BTU H trays x ft inches inches x ft inches inches x ft BTU H ft BTU H hr x x Hr ft BTU t x H H r=====  11) (Eq.800 , 9 100/12 24 ft lbs 49 Ec: F 1000 to beam heat to required Energy BTU lb BTU x ft inches inches x==
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-15
: 12) (Eq.0.1 14.1 BTU 8,602 BTU 9,800: released) energy to required (energy Ratio=  Therefore, the criteria is justified.
 
This justification assumes that the maximum heat release rate of the burning cable tray configuration is a function of the distance of the cable tray from the ceiling rather than from the underside of the structural steel member. This is acceptable because all parts of the cable tray are at least 33" from the ceiling except for a short, 6.5", section beneath the structural steel member. It is unrealistic to assume that the corner effects will dramatically increase in this short
 
distance.
This justification also assumes that only the portion of the cable tray directly beneath the structural steel member contributes to raising the temperature of the steel. This is justified because those portions of cable tray not directly under the steel will cause heat-up of the reinforced concrete slab above them. For each additional foot of cable tray considered 7,916 BTU's is released. Assuming a 45
&deg; distribution of this heat into the concrete slab, the additional heat absorption afforded by the concrete, using the methodology outlined in Section 3.2, is 12,750 BTU'S. Therefore, more energy absorption capability is added than additional heat released.
3.4  NPFA 13 Sprinkler Criteria
 
====3.4.1 Description====
 
The Unit 1 and Unit 2 Reactor Buildings both have areas with automatic sprinkler protection designed, installed and tested to the requirements of NFPA 13. All required structural steel framing members in areas protected by NFPA 13 sprinkler systems and having combustible configurations less than those justified herein were determined to be acceptable.
 
====3.4.2 Approach====
For a given quantity of cable trays, an automatic sprinkler system is capable of preventing structural steel damage by controlling a fire and cooling the steel. Six cable trays have been selected as being a combustible configuration which can be protected by a sprinkler system.
Branch Technical Position CMEB 9.5-1 (Rev. 2) lends credence to this criteria in that it requires automatic suppression systems only when an area contains more than six cable trays. Additionally, extensive large scale fire testing of rack storage arrangements, a far more hazardous combustible configuration than cable tray, have demonstrate that ceiling level automatic sprinklers installed in accordance with NFPA 13 are effective in preventing heat damage to unprotected steel beams and columns. The requirements of NFPA Standard 231C, "Standard for Rack Storage of Materials". (Ref. 4) were developed based on the results of these large scale tests. A comparison between the combustible configurations and fire hazards associated with rack storage and cable trays will be used to justify our criteria.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-16
 
====3.4.3 Justification====
 
Our criteria can be justified by comparing the relative fire hazard of a six-cable-tray fire with that of the rack storage fire which meets the NFPA Standard 231C requirements and does not require structural steel protection.
 
Rack storage of materials, especially most plastic materials, presents a difficult to control fire hazard. The materials and the cardboard packaging holding these materials are easily ignited.
Once ignited, the rack storage configuration provides ideal conditions for rapid and intense combustion. In the rack storage configuration the boxes of materials are surrounded on all sides by sufficient oxygen for combustion, and the flue spaces created between adjacent boxes are ideal for reradiation effects which promote fire spread. Also, the pelletized materials (4' x 4')
present large areas of blockage from sprinkler protection and allow fire growth to a level which can overpower traditional sprinkler systems. Recognition of these conditions led to extensive large scale fire tests. These tests served as the basis for the National Fire Protection Associations's "Standard for Rack Storage of Materials" (NFPA 231C) (Ref. 4).
 
The rack storage test program and NFPA standard clearly show that when an adequately designed ceiling sprinkler system is installed, fireproofing is not required for steel columns or ceiling steel. (Ref. 4 Sec. 3-2.1, 3-2.3, B-3-2.1, and B-3-2.3.)
 
In contrast, the cable trays at Susquehanna contain IEEE 383 qualified cables which require at least 70,000 BTU/hr heat input to ignite the cables. Due to the tight packing of cables in cable trays, there is only limited exposure to air. Cable tray fires are slow developing relative to cardboard packaging materials, and unlike other fuel arrays, cable trays present a fuel arrangement which allows fire propagation in only two directions. Finally, the cable tray itself is constructed of non-combustible steel.
 
In the Reactor Buildings the predominant fire spread is vertically from tray to tray. Horizontal fire spread from cable tray to cable tray is possible, but the majority of the cable trays in the Reactor Building are arranged with spacing which are not ideal for horizontal fire spread.
 
The following example shows how to determine the required ceiling sprinkler system parameters for a high hazard rack storage configuration when structural steel fireproofing is not provided on either ceiling beams or columns.
 
3.4.4  NFPA 231C Sprinkler Design Example
 
The following example uses NFPA 231C requirements to determine sprinkler system parameters for a given rack storage combustible configuration when structural steel fireproofing is not to be used.
a) Problem Definition - Determine the sprinkler density for a ceiling sprinkler system capable of maintaining the building's structural integrity for the following rack storage configuration.
: 1. The stored material is pelletized cardboard cartons containing foamed polystyrene. The pallets and cartons are not encapsulated with plastic.
: 2. The aisle spacing is 8 feet. The rack storage height is 15 feet.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-17 3. There are no in-rack sprinklers.
: 4. Structural steel ceiling beams and columns are not fireproofed.
b) NFPA 231C Requirements
: 1. The combustible material described above would be classified as a Class IV commodity per NFPA 231C Section 2-1.1.4.
: 2. By referring to Table 6-11.1 in NFPA 231C and applying the following conditions:
i) The rack storage height is over 12 feet but less than 20 feet.
ii) The combustible material is classified as a Class IV commodity.
iii) The pallets and cartons are not encapsulated with plastic.
 
iv) An 8-foot wide aisle is used between rack configurations.
v) No in-rack sprinklers are provided.
It can be determined that Figure 6-8.2 can be used to determine the allowable reduction factor to be applied to the sprinkler design density and that Figure 6-11.1d curve E or F is to be used to determine the unfactored sprinkler design density. (Refer to NFPA 231C for figures.)
: 3. Using NFPA 231C Table 6-8.2, it is determined that a 60% reduction factor may be applied to the required sprinkler design density determined below.
: 4. NFPA 231C Table 6-11.d curve F will be used because Susquehanna SES uses 212F rated sprinkler heads. Curve F applies to 165
&deg;F rated heads. Curve E applies to 265
&deg;F rated heads. Using the curve for the lower rated heads results in a more conservative sprinkler density. Using 2500 square feet, which was used as the design area for sprinkler coverage used in the design of the SSES Reactor Buildings, it can be determined that the required sprinkler design density for this rack storage example is:
Required Sprinkler Design Density = .54 GPM/ft 2  5. By applying the 60% reduction factor determined in step 3 above, the final sprinkler density is determined to be:
Sprinkler Density = .54 x .60 = 0.32 GPM/ft 2  6. The requirements of NFPA 231C sections 3-2.1 and 3-2.3 are satisfied by the storage height limitations of 15 feet and the sprinkler design which conforms to Chapters 6.7.8 and 9. Therefore, fireproofing of structural steel beam and columns is not required for this example.
 
c) Conclusion
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-18 A ceiling sprinkler system with a design density of .32 GPM/ft 2 over 2500 square feet is considered sufficient to protect non-fireproofed structural steel (ceiling beams and columns) from damage when subjected to a rack storage hazard with the above parameters.
 
====3.4.5 Comparison====
of Our Cable Tray Criteria With the Fire Hazard of the Rack Storage Example                                                                                   
 
a) Cable Trays Cable trays present an important fire protection challenge to control damage prior to affecting safe shutdown or station availability, but cable tray fires have low heat release rates, spread slowly, and do not pose the danger to structures that the rack storage
 
materials do.
As discussed in Section 3.2 of this report, the Sandia Laboratories Fire Retardant Cable Test (Ref. 1) Table A-XI indicates a maximum of 11.8 BTU/ft 2 sec (134,690 W/M
: 2) for non-coated electrical cables. Therefore, it can be concluded that the total heat release
 
rate for six cable trays would be 70.8 BTU/ft 2 sec. b) Rack Storage
 
Rack storage stores combustible materials in configurative ideal for combustion (i.e., air space around fuel, and distances ideal for radiant heat transfer). Therefore, rack storage presents an extremely difficult fire to control. Rack storage fires have extremely high heat release rates, spread very quickly, and can threaten structural integrity within minutes unless proper sprinkler protection is provided.
Heat release rate data for the rack storage commodity was obtained from Factory Mutual Data (Ref. 10, Table 2, Page 26) which indicates that a pallet of polystyrene in cartons 14 to 15 feet high has an average heat release rate of 300 BTU/ft 2 sec.
c) As a result of the information in a and b above, the following data comparison of critical fire protection parameters can be presented.
DATA COMPARISON
 
Hazard Cable Tray Criteria Rack Storage Example Heat Release Rate 70.8 BTU/ft 2 sec. 300 BTU/ft 2 sec. Sprinkler Density 15 GPM/ft 2 .32 GPM/ft 2 *SSES was designed on the basis of a .15 GPM/ft 2 sprinkler density over a 2500 sq. ft.
area. d) Conclusion The dominant mechanism governing a sprinkler system's ability to extinguish fires and also to protect structural steel from damage is the ability of the sprayed water to absorb SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-19 the heat released from the fire. This absorption occurs as the heat of the fire is used to change liquid water to steam.
The heat release rates of different materials as they are consumed is an indication of the relative fire hazard of the different fires. As the heat release rate increases, larger and larger quantities of water are necessary to absorb the higher heat levels generated.
Therefore, a comparison of the data presented in Item c above on heat release rates and sprinkler densities can be used in demonstrating the adequacy of the Susquehanna sprinkler design for our cable tray configurations. Since the rack storage example above proved that a .32 GPM/ft 2 density sprinkler system could control a fire with a heat release rate of 300 BTU/ft 2  min, using a strictly linear relationship we can predict a
.15 GPM/ft 2 density sprinkler system would control a fire with a heat release rate of 140 BTU/ft 2 sec or 12 cable trays (140 BTU/ft 2 sec divided by 11.8 BTU/ft 2 sec per cable tray). The assumption of linearity applied above would be viewed as being highly unconservative if the light hazard fire test data was used to predict the sprinkler system requirements to protect a configuration with high fire hazard potential. This is valid because as the level of the combustibles doublest effects such as reradiation can have an exponential effect. In contrast, however, to extrapolate results from the higher density system to the lower density system on a linear basis is clearly a conservative and supportable approach.
While this comparison predicts a wide margin of safety over the six-tray criteria, the criteria was limited to six cable trays to be conservative, to parallel the Branch Technical Position CMEB 9.5-1 (Rev. 2) requirements, and to assure that specific orientations and arrangements exceeding the criteria would be looked at on a case-by-case basis to ensure the adequacy of the sprinkler system.
Therefore, the existing ceiling level automatic sprinkler system in the Susquehanna SES Reactor Building can be expected to protect structural steel with a wide margin of safety
 
in the event of a fire involving six cable trays.
 
3.5  Case-By-Case Fire Protection Analysis
 
====3.5.1 Description====
 
For all required structural steel framing members not satisfying either of the two criteria outlined above one of the following approaches was used to justify that structural steel fire proofing was not required:
a) For non-sprinklered areas, a case-by-case evaluation using the Energy Balance Method outlined in Section 3.1 of this report was performed. The most severe cable tray exposure was analyzed for each steel member evaluated. In cases where the most severe exposure was not obvious, several exposures were evaluated.
b) For sprinklered areas, a case-by-case evaluation to determine that the existing combustible configuration would be controlled by the sprinkler system was performed.
 
==4.0 RESULTS==
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6SR-20 All structural steel in the Unit 1 and 2 Reactor Buildings was reviewed in conjunction with the combustible configuration exposing the structural steel to determine if the combustible configuration would cause structural steel temperatures in excess of the critical temperature.
 
No situations were found where the addition of fireproofing materials was determined to be necessary to keep structure steel temperatures below the critical temperature.
 
For areas acting as fire area barriers:
a) The structural steel supporting the roof of the Reactor Building switchgear rooms (Fire Zone 1-4C, 1-4D, 1-5F, 1-5G, 2-4C, 2-4D, 2-5F and 2-5G) were confirmed to already be provided with 3-hour fire rated fireproofing (These are not the subject of deviation
 
request No. 6).
b) The specific combustible configurations and justifications for each of the remaining fire rated areas is contained in Deviation Request No. 6, Non-Fireproofed Structural Steel.
 
==5.0 MODIFICATIONS==
No modifications are required.
 
==6.0 SCHEDULE==
 
Schedule data for modifications is not applicable. No modifications were identified by this analysis.
 
===7.0 COMPENSATORY===
MEASURES
 
Compensator measures are not applicable. No deficiencies were identified by this analysis.
 
==8.0  CONCLUSION==
 
The evaluation of the structural steel in the Susquehanna Steam Electric Station Unit 1 and 2 Reactor Buildings has determined, based on the conservative evaluation criteria outlined in this report, not to require structural steel fire proofing.
With these results, as summarized in Deviation Request No. 6, Non-Fireproofed Structural Steel, all structural steel is justified.
 
SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6APPA-1 APPENDIX A FIGURES SSES-FPRR Text Rev. 12 FPRR Rev. 18 DR6APPB-1 APPENDIX B
 
REFERENCES
: 1. Sandia Fire Retardant Coating Test  12-7-77 to 1.31-78 Sandi78-0518
: 2. NFPA Code 251 - Standard Methods of Fire Tests of Building, Construction Materials 1985 Edition
: 3. NFPA Code 231C - Rack Storage of Materials 1980 Edition
: 4. Sandia Fire Protection Research Program  Corner Effects Tests - Sand79-0966
: 5. Categorization of Cable Flammability Intermediate Scale Fire Tests of Cable Tray Installations - EPRI NP-1881, August 1982.
: 6. NRC's Branch Technical Position CMEP 9.5-1 (Rev. 2).
: 7. Sandia Investigation of Twenty-Foot Separation Distance as a Fire Protection Method as Specified in 1OCFR5O, Appendix R SAND83-0306.
: 8. Manual of Steel Construction - 8th edition AISC, Inc.
: 9. Vendor Drawing M-343 layout drawing and hydraulic calculations.
: 10. Evaluating Upsprinklered Fire Hazards, Alpert and Ward, Factor Mutual Research (RC84-Bt-9).
: 11. Fire Protection Review Report (Rev. 2) Susquehanna Steam Electric Station.
: 12. Chemical Engineers' Handbook - 4 th edition, J. H. Perry.
: 13. Building Code Requirements for Reinforced Concrete, ACI 318-83.
 
SSES-FPRR Table Rev. 11 TABLE DRG--2 Fire Zone Beneath op Of Slab Elevation NFPA 13 Sprinkler Drawing Reference Rated Floor Slab Protection Provided Control Structure 0-21A 676'-0" No E-205986 Sht. 1 0-22A 686'-0" No E-205987 Sht. 1 0-22A (Ceil. Space) 697'-0" No No E-205988 Sht. 1 0-24E (See Note 1) 714'-0" No E-205989 Sht. 1 0-241 See Note 2 No See Note 2 0-24K See Note 2 No See Note 2 0-28S See Note 2 No See Note 2 0-26AI E-N, P, R (See Note 3} 753'-0" Partial E*205922 Sht. 1 0*28A-I 783'-0" No E-205994 Sht. 1 0-28A-11 783'-0" No E-205994 Sht. 1 0-28B-1 783'-0" No E-205994 Shi. 1 0-288-11 783'-0" No E-205994 Sht. 1 0-28C 783'-0" No E-205994 Sht. 1 0-280 783'-0" No E-205994 Sht. 1 0-28E 783'-0" No E-205994 Sht. 1 0-28F 783'-0" No E-205994 Sht. 1 0-28G 783'-0" No E-205994 Sht. 1 0-28H 783'-0" No E-205994 Sht. 1 0-281 783'-0" No E-205994 Sht. 1 0-2BJ 783'-0" No E-205994 Sht. 1 0*28K 783'-0" No E-205994 Sht. 1 0-28L 783'-0,. No E-205994 Sht. 1 0*28M 783 1-0" No E*205994 Sht. 1 0-28N 783'*0" No E-205994 Sht. 1 0-28T 783'-0n No E-205994 Sht. 1 0-228 806'-Qn No E-205995 Sht. 1 0-29B 806'-0" No E-205995 Sht. 1 FPRR Rev. 11 Page 1. of 2
* SSES-FPRR Table Rev. 11
* TABLE DR6-2 Fire Zone Beneath Rated Aoor Slab Top Of Slab Elevation NFPA 13 Sprinkler Protection Provided Drawing Reference NOTES: 1. Only the steel above the Fire Zone 0-24E (below Elev. 714.-0") is not fireproofed.
The remaining main floor steel below elevation 714!*0" is fireproofed.
: 2. Steel beams inside HVAC chases do not require fireproofing.
See the following for location:
STEEL BELOW ELEVATION DRAWING REFERENCE 714'-Qn E*205989 Sht. t 729'*1" E-205990 Sht. 1 741'-1" E-205991 Shl. 1 753'-0" E-205992 Sht. 1 n,*-o" E*205993 Sht. 1 , 3. Fire Zones 0-26At 0-26E and part of 0*26H are located under the floor slab at Elevation 7 41 '-0". FPRR Rev. 11 Page 2 of 2 SSES-FPRR Table Rev. 11 TABLE DR6*1 Fire Zone Beneath . Top Of Slab Elevation NFPA 13 Sprinkler Drawing Reference Rated Floor Slab Protection Provided Unit 1 Reactor Building 1-1F 683'-0" No C-206006 Sht. 1 1 *1 E 683'{)" No C-206006 Sht. 2 1-3A 719'-1n Yes C-206007 Shts. 1 &2 1-38-W 719'-1" Yes C-206021 Sht. 1 1-38-W 719'-1!! Yes C-206021 Sht. 2 1-4A-W 749'-1 11 Yes C-206008 Shts. 1 &3 1-4A-W 749'-1" Yes C-206008 Sht. 2 1-4A-N 1-4A-W 749'-1" Yes C-206008 Sht. 4 1-4A-S 1-4A-W 749'-1" Yes C-206008 Sht. 5 1-4A-N 1-4G 761'-10" No C-206009 Shts. 1 &2 1-SA-S 779'-1" Yes C-206010 Shts. 1 &2 1-SB 779'-1" No C-206010 Shts. 3&4 Unit 2 Reactor Building 2-1A, C & D 670'-0" No C-213472 Shts. 1&2 2-1F 683 1*0" No C-206011 Sht. 1 2-1E 683'-0" No C-206011 Sht. 2 2-38-N 719'-1" Yes C-206012 Shts. 1 &2 2-38-W 719'-1" Yes C-206022 Sht. 1 2-38-W 719'*1'' Yes C-206022 Sht. 2 2-4A-S 749'-1" Yes C-206013 Sht. 1 2-4A-W 2-4A-W 749t* 1" Yes C-206013 Shts. 2&3 2-4A-W 749'-1" Yes C-206013 Sht. 4 2-4A-S FPRR Rev. 11 Page 1 of 2 SSES-FPRR Table Rev. 11 TABLE DRG-1 Fire Zone Beneath Top Of Slab Elevation NFPA 13 Sprinkler Drawing Reference Rated Floor Stab Protection Provided 2-4A-W 749'-1" Yes C-206013 Sht. 5 2-4A-N 2-4G 761'-10!'
No C-206014 Shts. 1 &2 2-5A-N 779*.rt Yes C-213469 Shts. 1 &2 2-5C 779'-1 No C-206015 Shts. 1 ,2,&3 2-SA-S Partial (see note 1) 2-5B Yes 2*6A 799'-1 n No C-206016 Sht. 1 Note: 1. NFPA 13 Sprinkler protection provided in the Northwestern area of the zone 2-5A-S identified as the Valve Access Vestibule Area. Sprinklers are instalred above and betow corridor grating. FPAR Rev. 11 Page 2 of 2 APPENDIX R DEVIATION REQUEST NO. 7
* FIRE SPREAD LIMITATIONS DEVIATION REQUEST: Certain fire zones can be considered to act as a fire area boundary between Fire Areas R .. 1 A and R ... 1 B in the Unit 1 Reactor Building and between Fire Areas R-2A and R-28 in the Unit 2 Reactor Building.
The*fire zones which act as the fire area boundaries are called 11 buffer zones.11 FIRE AREAS/ZONES AFFECTED:
In the Unit 1 Reactor Building the following fire zones are considered to be buffer zones since they provide a tire area boundary between Fire Areas R* 1 A and A* 1 B: 11-68 1-6C I 1-6F 1-7A I 0-6G 0-8A 1-60 In the Unit 2 Reactor Building the fonowing fire zones are considered to be buffer zones since they provide a fire area boundary between Fire Areas R-2A and R-28: 12-68 2-6D , 2-6E 2-6F , 2-7A Q .. BA REASON FOR DEVIATION REQUEST: 1 OCFR50 Appendix R, Section 111.G requires separation of cables and equipment required for safe shutdown by a tire barrier having a 3-hour rating. Furthermore, NRC Generic Letter 86-1 O states that "the term 'fire area* as used in Appendix A means an area sufficiently bounded to withstand the hazards associated with the fire area and, as necessary, to protect important equipment within the fire area from a fire outside the area." Normally, fire areas are separated by a wall or floor having a fire resistive rati~g of 3 hours. The wans of the buffer zones do not have a 3*hour rating but possess sufficient integrity of construction and spatial separation to provide a fire area boundary.
JUSTIFICATION:
The buffer zones are fire zones which occupy the upper elevations (Le.1 779', 799' and 818 1) of each reactor building.
Their location is shown on drawings E-205954, E .. 205955 and E*205956 for Unit 1 and on drawings E-205962, E-205963 and E-205964 for Unit 2. These drawings are contained in Section 8.0. They are zones which are almost entirely devoid of any safe shutdown cables or equipment and the combustible loading in all of these zones is very low. Rev. 10 DR7-1 G :\JJc Docs\FPRR Approved\Deviatlons\fpd_0700_07 .doc 
.. SSES-FPAR These zones are considered to provide an equivalent degree of safety as a fire rated wall for the following reasons: 1. 2. 3. 4. 5. 6. In ail cases, a minimum of 50 ft. horizontal separation exists between the fire zones in Fire Areas R-1A and R-18 for Unit 1 and in Fire Areas R-2A and A-28 for Unit 2. All buffer zones have fire detection except for the following; 1-6F Spent Fuel Pool (filled with water) 2-6F Spent Fuel Pool (filled with water) 0-6H Cask Storage Pit (tilled with water) All buff er zones have very low combustibie loadings and there are no specific locations within these zones which have the potential to cause a fire hazard. The wans which bound these zones are not fire rated yet their construction would contain a fire and the products of combustion reasonably well. The walls are of reinforced concrete construction, the doors are of heavy metal construction and the penetrations in the walls are constructed similar,y as in a fire rated wall. Therefore, although not fire rated, the boundaries would inhibit the transgression of a fire from one fire area to the next~ All buffer zones have manual fire suppression equipment located throughout the area. Typically, the buffer zones are situated such that a fire would have to pass through adjacent buffer zones to spread from one fire area to the next. This is considered extremely. improbable based on the specific configuration of the buffer zones with respect to the fire areas they separate.
: 7. For the purpose of the safe shutdown analysis, the buffer zones were considered to be part of both fire areas which they act to separate.
This approach is conservative since it requires protection of all safe shutdown cables or equipment in these zones regardiess of safe shutdown path. In all buffer zones, both paths (1 and 3) of safe shutdown equipment are protected where necessary.
ln conclusion, it can be stated that the spatial separation, construction techniques and low combustible configurations enable the buffer zones listed in this deviation request to act as a fire area boundary.
Therefore, a fire initiated in Fire Area R-1A of the Unit 1 Reactor Building may impact the buffer zones but will not spread into any other fire zone in Fire Area R-18. Simitarty, a fire initiated in Fire Area R-1B may impact the buffer zones but will not spread into any other fire zone in Fire Area R-1 A. The same assurance can be stated for Unit 2.
* Rev. 10 DR7-2 G:\Uc Oocs\FPRR Approved\Oeviations\jpd_0700_07.doc SSES-FPRR Text Rev. l 1 APPENDIX R DEVIATION REQUEST NO. 8 ONE HOUR FIRE BARRIER WRAP WITH LIMITED SUPPRESSION DEVIATJON REQUEST: The* installation of a three hour fire barrier wrap in Fjre Zones 0-288-1, 0-288-11, 1-20 and 0-28H without automatic suppression in order to comply with 1 OCFR50 Appendix R, Section 111.G.2.a would not significantly enhance the fire protection for those fire zones nor overall plant safety, and therefore a one hour fire barrier is acceptable.
FIRE AREAS/ZONES AFFECTED:
This deviation request applies to Fire Areas CS-17 (Fire Zone 0-288*1), CS-24 (Fire Zone 0-288-11), R-18 (Fire Zone 1-2D) and CS-15 (Fire Zone 0-28H). REASON FOR DEVlATION REQUEST: 10CFR50 Appendix R Section UI.G.2.a requires that redundant safe shutdown equipment/cables be separated by a fire barrier having a 3-hour rating when automatic suppression is not provided.
The redundant safe shutdown equipment/cables are separated by a fire barrier having a 1-hour rating and no automatic suppression is provided.
Fire Hazard Analysis EC-013-1846 evaluated the specific deviations from a tested configuration to assure that their capability is in excess of that required by the specific fire hazards in the vicinity of the deviation.
* EXISTING ARRANGEMENT:
Fire Zones 0-288-1 and 0-28B-II contain safety related load centers*and miscellaneous battery chargers and distribution panels. The 125 VDC distribution panels (10624 and 1 D644) focated in Fire Zone 0-288-U are enclosed with a one-hour protective fire barrier. Two-hour rated barrier walls separate equipment by division and all cabling in these zones is enclosed in conduit or paners. The combustible loading for these fire zones is low. Manual suppression equipment and ionization detectors are provided in these fire zones.
* Fire Zone 1-2D consists of one room (approximately 14' X 25') housing various control cables and Un;t 1 's remote shutdown panel. Approximately 75% of the cabling in the fire zone is contained in conduit. The minority division raceways located on the fire zone consist of control cable for the Emergency Service Water System. The combustible loading for the fire zone is low. Manual suppression equipment and ionization smoke-detectors are provided in the fire zone. FPRR Rev. 11 DRB-1 SSES-FPRR Text Rev: 11 Fire Zone 0-28H consists of one room (approximately 20' x 50 1) housing various cables in conduit and the cold instrument repair facility.
the minority division raceways are* located above a non-rated fatse ceiling and are run jn conduit. The combustible loading for the fire zone is low. Manual suppression and ionization detectors are provided for the fire zone. JUSTIFICATION:
When the combustible loading and reasonable transient combustibles are constdered, fire detection, manual fire suppression, and one~hour rated cable enclosures without automatic suppression provide adequate protection for safe shutdown cables. The combustible loading may change over plant life. *This Deviation Request will remain . valid so long as: a) The calculated maximum average combustible loading does not exceed 45 minutes. b} The in~situ combustibles remain evenly dispersed.
FPRR Rev. 11 DRB-2 SSES-FPRR ) DEVIATION REQUEST NO. 9 HAS BEEN WlTHDRAWN ) () Rev. 10 DR9-1 G:\Uc Docs\FPAR Approved\Deviations~_0700_09.doc SSES-FPRR ) .* DEVIATION REQUEST NO. 10 HAS BEEN WITHDRAWN Rev. 10 DR10-1 G:\Lic Oocs\FPRR Approved\Oeviations\fpc:(0700_
10.doc SSES-FPRR Text Rev. 11 APPENDIX R DEVIATION REQUEST NO. 11 HVAC PENETRATIONS REACTOR BUILDING FIRE WALLS DEVIATION REQUEST: Fire dampers are not required to be installed in the following ventilation duct penetrations in fire rated wall assemblies between affected Fire Zones. Penetration Fire Zone/Fire Zone X-25-3-37 1-3A/1-3B-N X-25-5-23 1-5B/1-4G X-25-5-13 1-58/1-SA-N X-25-5-15 1-5B/1-5A-N X-27-4-16 1-4A-S/ 1-4G X-27-4-17 1-4A-S/ 1-4G X-27-5-29 1-59/1-SA-S X-27-5-30 1-5B/1-5A-S X-28-5-44 1-5A-W /1-5E X-29*5-25 1-5A-W/1-5E X-30-5-4 2-58/2-SA-N X-30-5-5 2-58/2-SA-N X-30-5-32 2-58/2-4G X-30-5-50 2-5B/2-5A-N X-32-4-3 2-4A-S/2-4G X-32-4-4 2-4A-S/2-4G X-32-5-41 2-58/2-SA-S X-33-5-26 2-5A-W/2-5E X-33-5-27 2-5A-W/2-5E FIRE AREAS/ZONES AFFECTED:
This deviation request concerns Fire Areas in the Unit 1 and Unit 2 Reactor Buildings.
REASON FOR DEVIATION REQUEST: NRC guidance to 10CFR50, Appendix Rt Section 111.G.2 requires that fire areas shall have three hour barriers, and such barriers shall have fire rated dampers installed at duct penetrations.
Various fire wails within the Unit 1 and Unit 2 Reactor Building have ventilation system {HVAC) duct penetrations without fire dampers thus rendering the rating of the barrier less than three hours. FPRR Rev. 11 DR11-1 SSES-FPRR Text Rev. 11 EXlSTING ARRANGEMENT:
A description of the wall assemblies penetrated by ventilation ducts is provided in Table DR11~1. . See attached sheets of Drawing C-205789 for details. Attached Drawing A 205790, Sht. 1, provides the legend for understanding these drawings.
JUSTIFICATION:
The NFPA 90A-1985, Section 3-3.2.1.1 states: "Approved fire dampers shall be provided where ducts or air grills penetrate partitions required to have a fire resistance rating of 2 hours or more. 11 The maximum average combustible loading for any Fire Zone in the Reactor Buildings is limited to 1-1/2 hours. This is based on a conservative estimate of in-situ combustibtes and an alJowance of 15 minutes for transient combustibles.
The specific combustible configurations and potential for transient combustibles were evaluated for each duct penetration.
It was concluded that the exposure to these fire barriers due to concentrated combustibles in proximity to the barriers in no case presently exceed one hour. Therefore.
the subject duct assemblies do not require fire dampers per Section 3-3.2.1.1 of NFPA 90A. Attached Drawing C-205789 documents the actual combustible configuration surrounding each HVAG duct assembly and wall penetration in the affected Fire Zones. Cables in cable trays are the primary source of combustible materials contributing to the postulated fire in each Fire Zone. Transient and specific in-situ combustibles were examrned in each affected Fire Zone and are presently calculated to provide average combustible loadings of less than 1-1 /2 hours. Additionally, no localized concentration of combustibles was found which exceeded one hour. All of the subject duct assemblies are* well above their respective flood elevations.
Heat generated from transient combustibles was not found to be of a magnitude which would negatively affect duct assemblies.
tn-situ combustibles in these areas were found to be either of a low magnitude or located in Fire Zones that have an automatic suppression system which would mitigate the heat generated as a result of a fire.
* An analysis was performed by PP&L which examined the effect of the worst case combustible configuration on an HVAC duct assembly.
This case is found in Fire Zone 1-38-N. The analysis postulated that the combustibles concentrated in the vicinity of the duct assembly were consumed and that the area was enclosed to create a localized furnace. With these postulated conditions!
the maximum temperature which could be developed in this furnace area was calculated to be 216&deg;F. The analysis continued by examining the heat transfer effect between the 216&deg;F duct assembly and the cooler supply air belng transmitted through the duct and discharging into adjacent Fire Zone 1-3A. The maximum air discharge temperature into Fire Zone 1-3A was calculated to.be 146&deg;F. FPRR Rev. 11 DR11-2 SSES-FPRR Text Rev. 11 The results of the analysis lead to the following conclusions:
Since the maximum temperature on the fire side of the fire barrier is 216&deg;F. the non-fire side of the fire barrier will remain below the ambient temperature plus a 250&deg;F temperature rise. which is the fire barrier acceptance test criteria.
Since the HVAC duct temperatures remain below 160&deg;F, a fire damper operated by a 160&deg;F or higher fusible link would not operate. All dampers at Susquehanna have fusible links with a 160&deg;F actuation temperature or higher. Since automatic sprinklers in the Reactor Buildings are rated at 212&deg;F minimum, the increased room temperature resulting from an air inlet temperature of 145&deg;F will not result in sprinkler system activation. (The analysis calculated the final room temperature of Fire Zone 1-3A to be 105&deg;F.) Since the configuration in Fire Zone 1-38-N with respect to concentrated combustibles in the vicinity of the duct assembly represents the worst case, it can be concluded that the 216&deg;F calculated furnace temperature represents the worst case situation covered by this deviation request. Automatic sprinkler protection where provided will reduce this maximum temperature.
Equipment and cables in the adjacent affected Fire Zone will not be damaged unless, in the event of a fire in an unsprinklered Frre Zone, sufficient heated air can be transferred via the HVAC duct. Air will not be transferred if the HVAC system is not operating, nor is it possible for hot air to be released from a return air duct. Therefore, only cases where a supply duct in an unsprinklered area transferring heated air to an adjacent Fire Zone need to be ~onsidered.
This limits consideration to only two Fire Zones: 1-38-N and 2-4A-S. As discussed previously.
the analysis of a fire in Fire Zone 1-38-N demonstrates that the adjacent zone (1-3A) is not affected.
The combustible concentration in Fire Zone 2-4A-S is srgnifrcantly less than in Fire Zone 1-3B-N and the corresponding adjacent zone (2-4G) rs sprinklered.
Therefore, based on the analysis for Fire Zone 1-3B-N, it can be concluded that there would be no equipment or cable failures in Fire Zone 2-4G due to a fire in Fire Zone 2-4A-S. Furthermore, a fact-finding report on air duct penetrations through a one-hour fire resistive wall assembly was conducted by Underwriters Laboratories, Inc. (Ref. 1 ). This report describes the performance of HVAC duct penetrations through a one-hour rated fire resistive wall assembly when the wall assembly was subjected to a fire test conducted in accordance with the requirements of the Standard for Fire Tests of Building Construction Materiafs, UL 263 (ASTM E119). The air duct assemblies which penetrated the wall assembly consisted of two square 10 inch by 10 inch inside dimension galvanized steel ducts and one square 10 inch by 10 inch inside dimension Class l rigid fiberglass duct. All the air duct assemblies had open duct drops on both sides of the wall assembly.
None of the air duct assemblies
* FPRR Rev. 11 DR11-3 SSES-FPRR Text Rev. 11 contained fire dampers. The fire resistive wall assembly consisted of 5/8 inch thick gypsum wallboard screw attached to steel studs which were spaced 24 inches on center. The fire performance inctuded temperatures measured and recorded at various locations within, on the top surface of, to the side of and above the air duct assemblies, the structural integrity of the air duct assemblies, the passage of flames through the air duct assemblies, and the passage of flames through the wall assembly.
In the test, the galvanized steel duct assembly was 0.022 inch thick (Susquehanna SES minimum thickness is 0.048 inch), and 1t was exposed to flames of controlled extent and severity in accordance'with the Standard Time-Temperature Curve. In the test, all of the duct assemblies were in the positive pressure area of the furnace which would have aided flame propagation through the ducts to the non-fire side of the wall. The test results showed that the galvanized steel ducts were intact and remained in place with no degradation of the duct assembty. This test confirms the validjty of NFPA 90A, Section 3-3.2.2.&deg;1.1.
It should be noted that all ducting subject to this deviation request is constructed of galvanized steel. Therefore, this test also gives substance to our deviation request in that the ducts in the test experienced a maximum furnace temperature of approximately 1700&deg;F with no degradation whereas the duct in our analyzed worst case combustible configuration has been calculated to experience a maximum furnace temperature of approximately 216&deg;F. The NFPA "Fire Protection Handbook" (14th edition, Pages 7-69) states: "In the gauges commonly used, some sheet ducts may protect an opening in a building construction assembly for up to one hourt if properly hung and adequately fire stopped. Therefore, ducts passing through fire barriers having a rating of up to one-hour fire resistance can be assumed to present no extra-ordinary hazard. If the wall, partition, ceiling, or floor is required to have a fire resistance rating of more than one hour. a fire damper is required ... " The analysis of the worst case combustible configuration covered by this deviation request shows significantly lower postulated fire temperatures than those associated with the one-hour fire referred to in the NFPA handbook.
Also, the minimum 18-gauge (0.048 inch thick) sheet metal ducts used at Susquehanna (Ref: Drawing C-1126) are heavier than the commonly used gauges referred to by the NFPA statement.
The ducts are seismically hung (Ref: Drawing C-1129 through C-1136) and adequately fire stopped. (Ref: Respective penetration drawing for each listed duct penetration on Drawing C-205789, all sheets.) Therefore, it is our position that these ducts adequately mitigate the effects of a fire and do not require fire dampers. Furthermore, this Deviation Request will remain valid for these HVAC. duct penetrations as long as the sprinklered areas remain sprinklered and as long as combustible configuration changes in non-sprinklered areas do not cause: FPRR Rev. 11 DR11-4 SSES-FPRR Text Rev. 11 a) Calculated maximum fire barrier exposure temperatures during a fire to exceed 1700&deg;F (the maximum Standard Time-Temperature Curve value for a one-hour fire test), and/or b) Calculated temperatures in adjacent sprinklered fire areas to reach a revel at which automatic sprinkler systems would be activated.
The following descriptions and drawings (C-205789, all sheets, and A-205790, Sht. 1) provide the basis for our position and address each horizontal ventilation duct penetration on an individual case-by-case basis. Through this case-by-case approach, each duct penetration is shown in its actual combustible configuration in the plant. Parameters such as nearby combustibles, direction of duct air flow, location of duct openings, sprinkter protection, HVAC system and general duct and Fire Zone configuration have been examined to clarify and specifically document the rationale used for this deviation request.
 
==REFERENCES:==
: 1. "Fact-finding Report on Air Duct Penetrations Through One Hour Fire Resistive Wall Assembly," Underwriters Laboratories, Inc., Fi!e NC505-12, Project 84NK29824.
April 17, 1985 (Copyright
&#xa9;1985). FPRR Rev. 11 DR11-5 I i PPll.. FORM 350SA -U/a.4) (x-xx-x) FIRE ZONE BUILDING COLUMN LINE FPP 3 3 HOUR FIRE DAMPER . ~-~~-, PENETRATION NO, ~~---1111.--
SUPPLY AIR REGISTER C":>c;,.-EXHAUST RIR REGISTER FIRE RATED FLOOR AIR FLOH DIRECTION FIRE RATED WALL T.O.G. = TOP OF GRATING 8.0.D. = BOTTOM OF DUCT 8.0.R. = BOTTOM OF REGISTER .8.0.T. = BOTTOM OF TRAY EXAMPLES:
8.0.0. EL. 772'-9" 8.0.R. EL. 772'-9" C16"X24")
(18"X26")
b SECTION SHOHN ON SHEET XX "'-DUCT SIZE "'-REGISTER SIZE 8.0.T. EL. 772'-9" 2MKA CABLE TRAY IDENTIFIER~
(24"X6") ":---TRAY SIZE NOTE1 SIZE OF DUCTS~ REGISTERS
& CABLE TRAYS ARE:SHOHN IN PLAN AS WIDTH X HEIGHT. EX.: (24uxsn).
SHOWN IN'ELEVATION VIEW AS HEIGHT X HIDTH. EX.: csux24u).
AREA NA ELEV. NA SCALE SUSQUEHANNA S.E.S. NON-QUf\L I TY RELATED NA UNIT 1 ~-2 APPENDIX "R" DEVIATION REQUEST t LEGEND NO. 11 -SEE ORRHING C-205789 NO. 12 -SEE DRAHING C-205791 ~ENNSYLVANIA POWER & LI8HT COl'ff'ANY ALLENTOWN ftA. P'P" lL DIUIIU Ng NO. SHEET NO. REV.NO. A-205790 1 0 cc C!) C!l C!) FR"CT1DNAL Q 0 0&#xa3;CINI\L CVOOM I Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES~ DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-25-3-37 1-3A/1-38-N 8"X6" REACTOR BUILDING ZONE I SUPPLY As shown on Shts. 1 and 1A of Drawing C-205789, the duct assembty penetrates the fire barrier wall at Elevation 704'-0". This penetration joins Fire Zone 1-3A with Fire Zone 1-38-N. A supply air register is located on the face of the fire barrier wa!I in Fire Zone 1-3A. Fire Zone 1-3A has an automatic fire suppression system. JUSTIFICATION:
a) Fire initiated in Fire Zone 1-3A with potential to spread to Fire Zone 1-38-N. The combustibles in Fire Zone 1-3A consist of five cable trays located 2 feet to the east of the subject penetration.
The first opening in the duct assembly in Fire Zone 1-3B-N is located approximately 30 feet from the subject penetration.
Based on the UL test results, a fire initiated in Fire Zone 1-3A will not generate enough heat to adverse,y impact any system in Fire Zone 1-38-N. b) Fire initiated in Fire Zone 1-3B-N with potential to spread to Fire Zone 1-3A. Due to the large concentration of combustibles surrounding the HVAC supply air duct assembly in Fire Zone 1-3B-N, an analysis was performed to determine the increase in room air temperature in adjacent Fire Zone 1-3A. This analysis determined a duct discharge air temperature into Fire Zone 1-3A to be 146&deg;F, consequently heating Fire Zone 1*3A to a temperature of 105&deg;F. This increase in room air temperature would not activate the sprinkler system in Fire Zone 1-3A. Additionally, the previously referenced UL test assures that the duct assembly itself will not degrade as the result of a fire in Fire Zone 1-3B-N. Therefore, a fire initiated in Fire Zone 1-38-N will not generate enough heat to adversely impact any systems in Fire Zone 1 .. 3A. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not required in penetration X-25-3-37.
FPRR Rev. 11 DR11-6 A B {; C D E z_:.....;=-
N rt.D._T. E L. 7 0 J'-O'f1 Kl (24" 1 6'') .0 T. El. 70'.l'-G'Tl llH (H" i 6") .0.1. EL. 1tw-o*, u rn (24" x , .. 1 I .a. r. E L 1 0 2 *-s .. U H B *c 2.t" 1 , .. ) 2 3 1 f f 0.1. EL. 703'-o''llff (24" X 6") l!N. TOH. &#xa3;.811'-0'' U P*T D E l. 7 11 '-*7" .fe.O.T. EL J IM'-7' F U F (2-4" l ,t*} I \!I' TO EL ...... , .. ' UP TO !l. 10 1'-D" 4 __Je.O.T. H. 712'-6~ f l P F (24 'X 6") i----. ~-TO!L 6 8D'-D" B.O.T. H. 7l).C'-1 01KHB (H"'X 4") ON. T O (L 693'-D". IIP TO El. 141 '-:." 8.0.L El. 693'-0 .. IPH I (iA" J 4") U P T O El. 701'.:.B" (1 8"J C) DN 10 EL. 675'-9" 5 ? UP 10 ME ll OPEMI N C) ?)' AO l ~, , , 1 0 , ... ,. EL. ,,o*-~*(12" * ., .. > B.0. l. El 707'-0" \PM8 pr*, I") i ....._ __ .J '--~ -,------.. f***.T. El._ 1 1 2'-6" :.1 11.1 (7 1" I") \ :t:: i t* ;~r:~:: ;~:: ~~:::; :::~ MJ NOTE*. I. F O R tEG E NO SH DI G. A-2 0 57 9 0 , S H T. I 2. I O R II T H I SOIG. *H HC-20518!1 S HT. \.l a.a. T. El. 7 1 1 *-o" JP IIB {14'" I 4") . ;.._!J.O.L EL. 7 12'-&'" IP H (7 4'" l 4") \ 8.0.1. H. 111'-I J"rUli (24 .. l 6") -8.0.T EL. lll '1-1'11110 (2A"' l ,t") E OU l,-ENT ACCES S UEA C8E) P llN e E L. 68 3'-0" SUSQ U E H A N NA S.E.S. U N IT I APPENDIX "R" D E VIA TI ON REQUEST NO. 1 1 P ENETRATIO N X-2 5-3-37 A RE A 2~ \E L EV .683'-0'jS CAL E NA P(Hf',ISYL V ANIA POU[R & L lGHT CO MPA NY A LL E N TO W N PR. ;;.c*~~os7as 1**"'i'* r ...... "c:1 6 9 3 SH .I tJ'oR r'f:1 *--_ .. 
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* F l liH tli" 14 ')-,. 10,*-o" lKMB (6
* X 1c 102'-6. IMHB t6" X 14 '1-r (O U I PIIENT ,l,CC[SS AREA C0D r***i*1Trii i j Tii~, 1 1 1 , 1 1 1 ,1 1.1 1 ,:1, , , 1 , , , 1i F="l:'~l~_L____ OCC!~AL 3 HHB 1 [L. 71 S'-0" !.0.T , El. ll2'-6"FI P H (*"I 2J") E L 1J 1 *~o** I PHB (C 'X i* .. ) --8.0.T. EL. 111*-o** fl!I.H (6" i z ,**, ,_.,. _ _Ji-B O.T. El 10 7'-0" IP HB (.t" X H") J0,1. -0 .. I ~H II (6" l 1~ .. ) (L. l(jC'-0" (ti'' l 8") ll. HI U'-0" {1 0" J l l '' l EO U I PM&#xa3;N1 ACCESS A REA * " I ;:Q,;'d~~~
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Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-25-5-23 1-5B/1-4G 24" X 18" REACTOR BUILDING ZONE I EQUIPMENT COMPARTMENT (FILTERED)
EXHAUST As shown on Shts. 2 and 2A of Drawing C-205789, this duct assembty penetrates the P-line wall at Elevation 770'-f'. This penetration joins Fire Zone 1-4G with Fire Zone 1-5B. An exhaust air register is located flush with the wall in Fire Zone 1-4G and another ~xhaust air register is located in Fire Zone 1-58, approximately 18 feet away from the subject penetration.
Neither Fire Zone has sprinkler protection.
JUSTIFICATION:
a) Fire initiated in Fire Zone 14G with potential to spread to Fire Zone 1-SB. Fire Zone 1-4G has minimal combusUbles with no combustibles located within 10 feet of the register in that room. Therefore.
a fire initiated in Fire Zone 1-4G would not generate enough heat to pass through penetration X-25-5-23 and adversely impact any system in Fire Zone 1-58. In addition, there would not be enough heat generated in Fire Zone 1-4G to impact any room through which this duct system passes. b} Fire initiated in Fire Zone 1-SB with potential to spread to Fire Zone 1-4G. Fire Zone 1-58 has minimal combustibles.
As noted in the referenced sketch, a 12 inch x 4 inch cable tray is situated directly under the exhaust alr register in Fire Zone 1-58. However, this cable tray would not generate enough heat to affect the duct assembly and furthermore there are no combustibles in the vicinity of the exhaust air register in Fire Zone 1-4G. Therefore, a fire initiated in Fire Zone 1-5B would not generate enough heat to adversely impact any systems in Fire Zone 1-4G. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not required in penetration X-25-5-23.
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Text Rev. 11 PENETRATION:
ADJACENT Ff RE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-25-5-13 1-58/1 *SA-N 30" X 26" UNIT 1 PRIMARY CONTAINMENT DRYWELL PURGE EXHAUST TO STANDBY GAS TREATMENT As shown on Shts. 2 and 2A of Drawing C-205789, this duct system penetrates the fire barrier waif at Elevation 772'-7". This penetration joins Fire Zone 1-SA-N with Ffre Zone 1M5B. There are no openings in the duct assembly in Fire Zone 1-5A-N or Fire Zone 1-SB. Neither Ftre Zone has sprinkler protection.
JUSTIFICATION:
a) Frre initiated in Fire Zone 1-SA-N with potential to spread to Fire Zone 1-58. Since this duct system performs a primary containment purge function, there are no openings in the duct system throughout its entire length. Therefore, a fire initiated in Fire Zone 1-SA*N wourd not generate enough heat to breach the duct system and transfer heat into Fire Zone 1-56 or rnto any other Fire Zone through which this duct passes. b) Frre initiated in Fire Zone 1-58 with potential to spread to Fire Zone 1-SA-N. Since this duct system performs a primary containment purge function, there are no openings in the duct system throughout its entire length. Therefore, a fire initiated in Fire Zone 1-58 would not generate enough heat to breach the duct system and transfer heat into Fire Zone 1 .. sA-N or into any other Fire Zone through which this duct passes. CONCLUSION:
Based on the above discussion, NFPA 90A Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not required in penetra.tion X-25-5-13.
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" R" DEV I I\T !ON REQ UES T NO. l 1 I ! P ENETRATIONS X.*25'5*1 3', ! l\*2 5'5*15 4. X-2 5*5.*23 AREA , 25. IE LE V .1 411'-l'i SCA L E NA PCNMSY L YR NlA POMEA &. LIGH T CO MP~HY : A LL CNTOM f,I P R. p:*:*205788 1**2A&deg; l"'2"' '""'t-i693 SH .2A
* Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-25-5-15
* 1-5B/1-5A
.. N 22" X 18'' REACTOR BUILDING ZONE I EQUIPMENT COMPARTMENT
{Fll TERED) EXHAUST As shown on Shts. 2 and 2A of Drawing C-205789, the duct assembly penetrates the fire barrier wall through penetration X-25-5-15 at Elevation 770 1-1 11* This penetration joins Fire Zone 1-5A-N with Fire Zone 1-58. An exhaust air register is located in the duct in Fire Zone 1 SB. Neither Fire Zone has sprinkler protection.
JUSTIFICATION:
a) Fire initiated in Fire Zone 1-5A-N with potential to spread to Fire Zone 1-5B. There are no openings in the duct assembly in Fire Zone 1-SA-N within at least 50 feet of the subject penetration.
If a fire were initiated in Fire Zone 1-5A-N, the heat generated as a result of that fire would have to travel through at least 50 feet of ductwork before reaching into Fire Zone 1-5B. As the heat would escape from the exhaust air register in Fire Zone 1-5B, it would migrate upwards away from cable tray F1PL and not have suffident heat content to adversely affect this cable tray or any other system in Fire Zone 1-58. b) Fire initiated .in Fire Zone 1-5B with potential to spread to Fire Zone 1-5A-N. Fire Zone 1-58 has minimal combustibles.
As noted on the referenced drawing, a 12 inch x 4 inch cable tray is situated directly under the exhaust air register in Fire Zone 1-59. However, this cable tray would not generate sufficient heat to affect the duct assembly in Fire Zone 1-5A-N, and since there are no openings in the duct assembly in Fire Zone 1-SA-N within at least 50 feet of the subject duct penetration, sufficient heat would not be generated by a fire in Fire Zone 1-SB to adversely affect any system in Fire Zone 1-5-N. CONCLUSION:
........ Based on the above discussion.
NFPA 90A, Section 3-3.2.1.1, the physical layout of the . adjacent Fire Zones and the combustible configuration within the Fire Zones, *a fire damper is not required in penetration X-25-5-15.
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* i:J i UNIT I f\PP E NO!X "R"-*** D EV!f\TION REQUEST NO. 11 PEN ETRATIONS X-25*5*13, X-25'5*15
* X*Z5*5*23 . AREA Z5. !&#xa3;LEV. ra*-rl scAL E NA Pt:t,INSYLV~NHI
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Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSS10N:
SSES-FPRR X-27-4-16 1-4A-S/1-4G 30" X 18 REACTOR BU~LDING ZONE i SUPPLY As shown on Shts. 3 and 3A of Drawing C-205789, the duct assembly penetrates the fire barrier at Elevation 743'-3". This penetration joins Fire Zone 1-4A-S with Fire Zone 14G. A supply air register is located in Fire Zone 1-4G near the face of the fire barrier wall. Fire Zone 1-4A-S is a fully sprinklered area. JUSTiFICATION; a) Fire initiated in Fire Zone 1-4G with potenUal to spread to Fire Zone 1-4A .. s. Fire Zone 1-4G has minimal combustibles with the only combustible near penetration X-27-4-16 being cable tray F1KY. Based on the previously referenced analysis, the consequences of a fire in Fke Zone 14G would not adversely impact any systems in Fire Zone 1-4A-S. Therefore, a fire generated in Fire Zones 14G would not generate enough heat to adversely impact any systems in Fire Zone 1-4A-S. b) Fire initiated in Fire Zone 1-4A-S with potential to spread to Fire Zone 1-4G. Fire Zone 1-4A*S is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-4A-S as a result of a fire in Fire Zone 1-4A .. s. Thereforet a fire initiated in Fire Zone 1-4A-S would not generate enough heat to adversely impact any systems in Fire Zone 1-4G. CONCLUS10N:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zonesj a fire damper is not required in penetration X*27-4-16.
FPRR Rev. 11 DR11*10 I I , . I t A B C 0 E. 8. O.D. EL. 74 2 '-r 12~ .. l 16") 8. 0. T. {l. 741 '-9"' llJC (24" l 4") 2 3 -,-----:::-
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n u "~ :.;:;:* "' ' ' B""' .,.;~~ ..,:;,:. '"= B~*;::::~u.* l(EY PL/I l l .,.,....., , 1)11 1 , ........ N O TE: 1 FDR L(C(H O S U Oil.. A-2Cl579 D , S H L I. 2. JORK l HI S 0 ,C. 11TH C-2 0:57B 9, S HT. 3. Ill Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-27-4-17 1-4A-S/1-4G 12" X 12" TRANSFER DUCT As shown on Shts. 4 and 4A of Drawing C-205789, this duct assembly penetrates the fire barrier at Elevation 743'-0". This penetration joins Fire Zone 1-4A-S with Fire Zone 1-4G. A supply air register is located in Fire Zone 1-4G near the face of the fire barrier wall. This duct system is a transfer duct which supplies air from Zone 1-4A-S to Fire Zone 1-4G at a rate of 500 cfm. Fire Zone 1-4A*S is a fully sprinklered area. JUSTIFICATION:
a} Fire initiated in Fire Zone 1-4G with potential to spread to Fire Zone 1-4A-S. Fire Zone 1-4G has minimal combustibles with the nearest combustible (cable tray F1 KY) located approximately 5'-2" beneath the duct supply air register.
Cable tray F 1 KY is fire wrapped in Fire Zone 1-4A-S. After cable tray F 1 KY enters Fire Zone 1-4G, it drops to a distance of approximately 7'-3" beneath the duct supply air register.
Based on the low combustible loading of Fire Zone 1-4G and the distance between the supply air register and the nearest cable tray, a fire in Fire Zone 1-4G will not generate enough heat to adversely impact any system in Fire Zone 1-4A-S. b) Fire initiated in Fire Zone 1-4A-S with potential to spread to Fire Zone 1-4G. Fire Zone 1-4A-S is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated by a fire in Fire Zone 1-4A-S. The one cable tray (F1 KY} located near the duct opening is fire wrapped. Therefore, a fire initiated in Fire Zone 1-4A-S would not generate enough heat to adversely impact any system in Fire Zone 1-4G. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not required in penetration X-27-4-17.
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[ ; L--l! E* 0~790 , SHT. I. ~01 ,;, ll&fNO SU &deg;";,;;\.,am9. SHI. U. 2. IOU T II I S DfU II NC SUSOUE H f\NN-f\ S. E . S. U N IT I APPEND IX " R" D EVIA T ION REQUEST NO. 11 PENET R f\lIO N X-2 7-4-1 7 0 REA 27 J ELEV .719'-0" Jsrn L E N A <,. P(N NSY LVIH UA f'O\..'E:R t LlG U T COMPrlN'I' I . OLL ENl O U N P A_c..* -~--1 ... c:'2os7B9T*Li
** *"*c: j 593 SH . 4 
! l I A B C D E 1 i I "T .~. &#xa2; ..... a ... ------2 FL. [L. 74&'-1" .. *4 *~. * 'I'.,-4 4ll.'Q*. 3 I+ i B.D.D. _H , 140'-0'" s.o, (l 731'*1" rin r~_-_.J_H_ .. ) rm&#xa3; \i'R~P f[U I N nPE ZOM* 1-"U,~S fl. Et. 711J'-I .. S&#xa3;CJJ01j "4A-4A" t!llJL C ONTAI NMEN T ACCESSwAY J.'ALL O MITTED FOR CLARIT Y I._Q._D _ _E l. 743'-0 .. lillll S T EAi P I PUAT 111_:_:_r 5 i 6 7 Br.,::.~:
EJ"" u."'''"' l'l'l'~*lt":'.':!:..
B:::::. a ...........
NOT(: I fD A lEG E l ll SE[ DIG . .l-21!5 19D , Stt T. 1. z. IORl THI S 011uu11: 11TH C-205789 , !.HT .... ,;. S U S Q U E HANN A S. E
* S _--U NIT I . f\PPENDIX
" fl" DEV!f\TION REQUEST N O. 1 1 PE N ETRATIO N X-27-4.-17 !IB_~I!_ 21 !ELE V .719'-1 *j S CAL E NA P&#xa3;HN5YLYANIA POM!:R & L 1GHT t.:O M PR NY ---~"L"'L"-'EN=lO\JN PA. I '"c'.::*2os7s9:=r4*A*
1"'* *** "{.'._j'G93 SH .4A Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-27-5-29 1-5B/1 ~SA-S 18 11 X 18" REACTOR BUILDING ZONE I SUPPLY As shown on Sht. 5 of Drawing C-205789, the duct assembly penetrates the fire barrier wall at Elevation 771'-6''.
This penetration joins Fire Zone 1-SA-S with Fire Zone 1-58. A supply air register is located against the face of the fire barrier wall in Fire Zone 1-SB. Fire Zone 1-SA-S is a fully sprinklered area. JUSTIFICATION:
a) Fire initiated in Fire Zone 1-SA-S with potential to spread to Fire Zone 1-58. Fire Zone 1-5A-S is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-SA-S as a result of a fire in Fire Zone 1-5A-S. Therefore, a fire initiated in Fire Zone 1-SA-S would .not generate enough heat to adversely impact any system in Fire Zone 1-5B. b) Fire iniUated in Fire Zone 1-58 with potential to spread to Fire Zone 1-5A-S. Fire Zone 1-5B has minimal combustibles and the only combustibte near the duct opening is located above the top of the duct. Therefore, a fire initiated in Fire Zone 1-58 would not generate enough heat to adversely impact any system in Fire Zone 1-SA-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physi~al layout of the adjacent Fire Zones and the combustible configuration with,n the Fire Zones. a fire damper is not required in penetration X-27-5-29.
FPRR Rev. 11 DR11-12 Fl B C 0 E 2 z;..;.----=-:
N J.O. T. H. lH'-0" 11',], tl (6" I 6") a.a. T. lL. HJ.-'" 1 10.~ {2&'" 1 6") 1.0.D. ll. 111 *-6"-SUNDBY CO NTROL SlS H I AREA 3 'I 5
* 6") P R IIU'f C ONUllllllM l 6 7 B~*~= EJ .... 11 . .0 , ... -*~~-* +-c--a_ . ..: /glQUfgf *,un __ , 1*""~~*-oil~((i), Ti.e,n.,T
* Tu,11., T &#xa9;-1'-"'*o**a..c.. -*..-a.oo. ,.-...m I r;-r;r::r;;r I I I I El::~ ~UM.II':-"'"-"" =.*i.~::.r:.~J~~~r.5..~: 1~ . .-..*r 10*0* ~f -**}+.W.; iii7 .,.,.,. ~-:-;:-IMIIE: 1 FOJI UC.(M D SU O IS. A-2D!i 7IO $11 , I SUSQUEHANNA S.E.S. UNIT I I\PPENO I X "R" OEVII\T!ON REQ U EST NO. 11 P E N ETRI\TION X-2 7-5-29 A REA 27 E LE V .)41'-l '1s C A LE ~A PENNS Y L YA MJA PO\./E R 1 LIGHT C O M P A N Y R LL(NT O l,/H PA, '"c*.::*205789 L 5 .. c~*i ,693 SH. 5 : I ;;-*
Text Rev. 11 . PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILA TtON SYSTEM: DISCUSSION:
SSES .. FPRR X-27-5-30 1-58/1-SA-S 30" X 26" UNIT 1 PRIMARY CONTAINMENT DR'M'ELL PURGE EXHAUST TO STANDBY GAS TREATMENT As shown on Sht. 6 Drawing c .. 205789, the duct assembly penetrates the fire barrier wall at Elevation 772'-r. This penetration joins Fire Zone 1-5A-S with Fire Zone 1-5B. Fire Zone 1-5A-S is fully sprinklered area. JUSTIFICATION:
a) Fire initiated in Fire Zone 1-SA-S with potential to spread to Fire Zone 1*5B. Fire Zone 1-5A-S is protected by an automatfc fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-5A-S as a result of a fire in Fire Zone 1-5-S. Also, there are no openings in the duct assembly in either Fire Zone. Therefore, a fire generated in Fire Zone 1-5A-S would not generate enough heat to adversely impact any system in Fire Zone 1-5B. b) Fire initiated in Fire Zone 1-5B with potential to spread to Fire Zone 1-5A-S. Fire Zone 1-59 has minima\ combustibles and there are no openings in the duct assembly in either Fire Zone 1-5B nor Fire Zone 1 *SA-S. Therefore, a fire in Fire Zone 1-58 would not generate enough heat to adversely impact any system in Fire Zone 1-SA-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones. a fire damper is not required in penetration X-27-5-30.
FPRR Rev. 11 DR11-13 l f A B C D E ' =-N 8.0.T. El. 765'*0 u:uv (U" l 6 .. )~ 8.0.T. H. 8.0. T. H. 8.0.T. El. 71 2'*4\ .. IUG (14" l 4"~ 8.0.1. EL. 774'-0 \HH {E"l 6*") B.D. T. EL. 71J'-<4" lU.B (24" I 6") 2 STAli081 CONlROl SYSHI 1,RU @ I I I 3 4 117 '*1'' (J D" X 76"} ... 1111\NARY COKUIMN[Nl 5 1 I I 9.0.T. El. n**-J" (24" I &") 6 7 ffil~ .. -C ttl)IO Jt ,( ..., .. _.fl ,.., *-* -~. B:~. ~I I IIU:1-MJ;:Y f'l..~t,I u~ a'.=.'t. ~~::r=~-~}"ca ~~-1~. ~..., *** .. ,-a* ..,., *o* Ko*** 11'i'J* C-10'0" I , 'I" CT'l'O' """!.:.!:.....!-! ,r,,t*1* u:1*** 1 n,*,* "1 10*0* 1 1 *1* ;::~: ~::: : i:-~1-"1' 7, :-_~ 1 ..... ,...... 'I*,*** 1-----f!-+-
--JIOT&#xa3;: 1. FOR l i G E NO SH o,r;. A-2 0 HS0. SH. I sus b UE H RNNA S.E.S. UNIT I f\PPENDIX
" R" Oc VI ATION REQUEST NO. 11 PENETR/\TION X-27-5-30 I AR E A 27 E L EV .i"'4i*~1~*\SCALE NA PtNNSYLYANI~
P O WER , LIGHT CO MPFIN Y AL.l.ENTO\JN PR. ""c'.:*2o s7 s 9 1***6 ... "f~j5*93 SH. 6 I Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-28-5-44 1-5A-W/1-5E 18" X 12" REACTOR BUILDING ZONE I EQUIPMENT COMPARTMENT (FILTERED)
EXHAUST As shown on Shts. 7 and 7 A of Drawing C-205789, the duct assembly penetrates the fire barrier wall at Elevation 771'-3 11* This penetration joins Fire Zone 1-5E with Fire Zone 1-5A-W. An exhaust air register is located against the face of the wall in Fire Zone 1-5E. JUSTIFICATION:
a) Fire initiated in Fire Zone 1-SE with potential to spread to Fire Zone 1-5A-W. Fire Zone 1-SE has minimal combustibles with no combustibles located near the subject penetration.
Also, there are no duct openings ~ocated within 50 feet of the penetration in Fire Zone 1-5A-W. Therefore, a fire generated in Fire Zone 1-5E would not generate enough heat to adversely impact any system in Fire Zone 1-5A-W. b) Fire initiated in Fire Zone 1-5A-W with potential to spread to Fire Zone 1-SE. Fire Zone 1-5A-W is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-SA-W as a result of a fire in Fire Zone 1-5A-W. Therefore.
a fire initiated in Fire Zone 1-5A-W would not generate enough heat to adversely impact any system in Fire Zone 1-5E. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper fs not required in penetration X-28-5-44.
FPRR Rev. 11 DR11-14 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
z 3 R @ B ti.~* **~~t~* I I I C D B.O. t. H. E I fZ27ZZZTIZbZTITIZZZTIZ2 ll 5 25 fl. lL. 119'-1 '' *:~~\~~: .. ;:~.~i l T 1 0P{N(!RH I O N@ .. ,ll.0.1. El ---.. , *r-a.o.o. EL. 8. D .D. E l. 1'55 '-1 "*(.eQ" X &G ") T O ftNfTRATIDN S ICTI DN 1A-.JA '\!!J I J. J r 0.D.I. , L. 7il'*II 1_m (<'' X 24&#xa5; t 6 7 NOTE: I. F OR l(G (Ml SH D IG. A-1057 90 S HT. I *o:i .. T H IS DUi. IIT II C-20Sl89 SMT. 7 l a S U SQUEHANNA S.E.S. U N IT! APPEND! X " R" DEV !A T! ON REQUEST NO. 1 1 PENETRAT!DN X-28-S-44 Af\O X-29-5-25 . V ]49'-l " I SCALE ARF.A 29 \E LE I PI.HHS YL\'PHlA POWER & LlGHT C OnPAHY ALL[J'(!OW" P~. ~*t-=*2os7s9 11:ir .. "c':_jE393 SH * ?A
* Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SJZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-29-5-25 1-5A-W /1-5E 12" X8" REACTOR BUILDING ZONE I SUPPLY As shown on Shts. 8 and 7 A of Drawing C-205789, the duct assembly penetrates the fire barrier wall at Elevation 766'-9". This penetration joins Fire Zone 1-SE with Fire Zone 1-5A-W. A supply air register is located on the face of the fire barrier wall in Fire Zone 1-5E. JUSTIFtCATION:
a) Fire initiated in Fire Zone 1-5E with potential to spread to Fire Zone 1-5A-W. Fire Zone 1-5E has minimal combustibles with the nearest combustible approximately 10 feet from the supply air register.
Alsot there are no openings in the duct assembly in Fire Zone 1-SA-W located within 30 feet of penetration X-29-5-25.
Therefore, a fire iniUated in Zone 1-5E woutd not generate enough heat to adversely impact any system 1n Fire Zone 1-SA~W. b) Fire initiated in Fire Zone 1-SA-W with potential to spread to Fire Zone 1-SE. Frre Zone 1-5A-W is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-SA .. w as a result of a fire in Fire Zone 1-5A-W. Therefore, a f,re initiated in Fire Zone 1-SA-W would not generate enough heat to adversery impact any system in Fire Zone 1 .. sE. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combusttble configuration within the Fire Zones, a fire damper is not required in penetration X-29-5-25.
FPRR Rev. 11 DR11-15 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
R B C D E I
* 2 @ *.~:.:~:-I t,,~.od* **:<1:0:tt:i-*
I 3 I 12""11"~~ " 25 I -'-T D PEHl1'A1 /OH '\9 5 fl. H. 771'-1" 1D P E NfJRIJIDN@
.. ... L-,rll.Q.I [l, ~:_:.:/\B.O.D. EL. e.O.D. H .. n~*-1 ***t 4D"" J Ii&"') ,..... !_,____Q_,_T. &#xa3;L _ H2 '._-11 1 Plt J.~" ~-H__1) 3 !~ ,l. n. m*-1 * '2$ pazir/27ZhTflZT//ZZZZZl221ZZ7ZVZZZ7JZZZ?m22VZl IZVJ2ZZZTJTJ7Z?JZZZVZZ SfCTIIIC 1A-1A 6 7 &sect;~ .. -... ..... *-* ~-~,,_ ,~ .. """"'" "'""" ~-** ,--i. * .-, "-1-,-~11..111-a..11.a. n..1-.m-a..U.na:;_~
_...,.. Q., 1w.*o* -*O" -*r ..,.,. * ,"'9'0" , ...., .... 0 *** j O ft0 *** .... " ~-11..,-1 ,;--~ 1"'.::o'?ii:!
T.111''.f" -'"~ NO T[: 1. F O R L HEJII SU on. ,l-2D~7ID SHT. 1 :. *o u THIS o ,t. 1 1TH t-20~789 SHL J &. I ~USQUEHANNA S.E.S. UNIT! f\PPENDIX "R" DEV If\ T JON REQ UE ST ND
* II PE NETRATION X-28-5-44 At-0 X-29-5-25 . A REA 21 /ELEV ;09*.1 "/SCALE NI\ PlNNSYL'IANIA PO\l[A & ll~MT COf1PANY RlLUHOMN PR , "c-=*2os7s9 11:ir .... c:.jt393 SH .7A 411 Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-30-5-4 2-5B/2-5A-N 18" X 18" REACTOR BUILDING ZONE II SUPPLY As shown on Sht. 9 of Drawing C-205789, this duct assembly penetrates the fire barrier wall at Elevation 770'-9''.
This penetration joins Fire Zone 2-58 with Fire Zone 2-5A-N. A supply air register is located in Fire Zone 2-58 at the face of the fire barrier wall. Fire Zone 2-SA-N is a fully sprinklered area.
* JUST~FICATION:
a) Fire inibated in Fire Zone 2*59 with potential to spread to Fire Zone 2--5A-N. Fire Zone 2-5B has minimal combustibles and the nearest combustibfe to the duct supply air-register is cable tray E2KK which is offset horizontally from the duct by approximately 6 feet. Based on the minimal combustibles in Fire Zone 2-5B and the nearest opening in the duct assembly in Fire Zone 2-5A-N being greater than 35' from penetration X-30-5-4, a fire initiated in Fir_e Zone 2-58 would not generate enough heat to adversely impact any system in Fire Zone 2-5A-N. b) Fire initiated in Fire Zone 2-5A-N with potential to spread to Fire Zone 2-58. Fire Zone 2-5A-N is protected by an automatic fire suppression system which would mitigate the consequences of the heat generated in Fire Zone 2-5A-N as a result of a fire in Fire Zone 2-5A-N. Therefore, a fire initiated in Fire Zone 2-5A-N would not generate enough heat to adversely impact any system in Fire Zone 2-58. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not required in penetration X-30-5-4.
FPRR Rev. 11 DR11-16 A B {> C D E 2 =--N 3 4 YAlYE A CC E!;S ARIA 8.0.1. H. 11 1"-1" E7 U..t3 D" X 5") ----I~ t t i~ PR I IJRY CONU.IHIENl P UN'! EL. 70'-l" 5 S UND-BT CO NTROL S TSTUS ARIA ---r-''<-+------1 Q G 7 ffij"" ... (*l<><l!o.i IIU IU<l l'II ..l-i;:;:--El_::,;~*.~~ I FOR L[6E H O SEE O IC. l-20 5790 , S HY. I SUSGIUEH RN NR s .E .S. U NIT 2 A PPE NDIX "R" D E VI A T ION REQU ES T N O. 11 PE NET RAT ION X-30-!:l-4 AREA 3 0 IELEV .1,s*-1*jscAL E N A P[NfiS Y LV A HlA POMER 1 LIGH T Cl'.IM PR M'I' ALl.ENTO"N PR . ... c*.::*2os7s9 , .... ,s " c'.'..'.'1593 S H .9 I ~I "'
Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-30-5-5 2-5B/2-SA
... N 22" X 22'* REACTOR BUILDING.ZONE II EQUIPMENT COMPARTMENT (FILTERED)
EXHAUST As shown on Sht. 10 of attached Drawing C-205789, the duct assembly penetrates the fire barrier wall at Elevation 773'-3 11* This penetration joins Fire Zone 2-5B with Fire Zone 2-5A-N. Fire Zone 2-5A-N is a fully sprinklered area. JUSTIFICATION:
a) Fire initiated in Fire Zone 2-58 with potential to spread to Fire Zone 2-SA-N. Fire Zone 2-5B has minimal combustibles and there is an exhaust air register in the duct assembly tn Fire Zone 2-5B. However, the first opening in the duct assembly in Fire Zone 2-SA-N is greater than 30 feet from penetration X-30-5-5.
Therefore, a fire initiated in Fire Zone 2-58 would not generate enough heat to adversely impact any system in Fire Zone 2-5A-N. b) Fire initiated in Fire Zone 2-SA-N with potential to spread into Fire Zone 2-59. Fire Zone 2-5A-N is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 2-5A-N as a result of a fire in Fire Zone 2-SA-N. Therefore, a fire iniUated in Fire Zone 2-5A-N would not generate enough heat to adversely impact any system in Fire Zone 2-5B. This automatic suppression system would also mitigat$ the effects of heat being further transmitted through the duct assembly into Fire Zone 2-4G. As this duct assembly continues, it enters Fire Zone 2-4G, which also must be separated from Fire Zone 2-5A-N. However, using the same reasoning as in the above paragraph, a fire in Fire Zone 2-5A-N would not have a path capable of spreading fire to Fire Zone 2-4G. CONCLUSION:
Based on the above discussion, NFPA 90A Section 3-3.2. 1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not required in penetration X-30-5-5.
FPRR Rev. 11 DR11-17 
=-N Fl 8 -l: C D E 2 NOT&#xa3;; *AIN STEAi f'IPUAY HO CABLE lRIYS 11Jfl1N 5' OF DUCJ IN THI S nu 'i'.lUE -cctSS .I.RU FLOOR [l. 161'-lD"' *ri1~ PR!IART C DNlAINl[NT P L AN P fl. 149'-1" 3 LI SUND-BY C DNTRDl STJHJS Alill 5 31~ 8.0. o. (l. 755'-1" (27" J 22" l NUT A(GlSlER >25' U.'1 ~-@ 6 GJ~.'::.7.~
g.,.Ull..:I
~GJ-.. ~~=n ....... l"-* [;;'J .. n, a,,..a:::n.a NOTE I. fOR LfCiEND SEE OJt , A-205J9D. SKT. I SUSQUEHANNA S.E.S. UNIT 2 APPEND [ X "R" DEVIAT[ON REQUEST NO. 11 PENETRATJON X-30*5-5 .S. X.,-30-5*32 AREA 30 !ELEV .749'-l'i&sect;CALE NA PENNS'f'L\IANIA POWER & LIGHT COMPANY ALLENTOWN PR. 2 "c:*2os7s9 1**T6' "('..'.:."(f;S3 SH . 10 -m-nTTITmTTTI"TTITTTITrr.rrrrTTTTTmTITTITTT,mTITrr--r;;,-,..,,-,-r-r;::_T"T""...,.,.....~, _:-,-, .,..-r-,-,--,-..,,..,.-,--,-,--.-,-,-
* .-.. -,-,. ,.,.,... , --.-. ___,..,,~.,...,.,,.." r--~
Text Rev. 11 PENETRATION:
ADJACENT Ff RE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-30-5-32 2-5B/2-4G 24'' X 18" REACTOR BUILDING ZONE ll EQUIPMENT COMPARTMENT FILTERED EXHAUST As shown on Sht. 10 of Drawing C-205789, the duct assembly penetrates the fire barrier wall at Elevation 773'-3". This penetration joins Fire Zone 2-5B with Fire Zone 24G. An exhaust air register is located within Fire Zone 2-4G and Fire Zone 2-5B. JUSTIFICATION:
a} Fire initiated in Fire Zone 2-4G with potential to spread to Fire Zone 2-5B. Fire Zone 24G has minimal combustibles and there are no combustibles located near the exhaust air register in Fire Zone 24G. There is an exhaust air register in the duct assembly in Fire Zone 2-58. Therefore, a fire initiated ,n Fire Zone 2-4G would not generate enough heat to adversely impact any system in Fire Zone 2-5B. Additionally, the lack of combustibles in Fire Zone 2-4G fnhibits the effect of a fire in Ffre Zone 2-4G from adversely impacting any system in Fire Zone 2-SA-N. b) Fire initiated in Fire Zone 2-5B with potential to spread into Fire Zone 2-4G. Fire Zone 2-5B has minimal combustibles and there is an exhaust air register in the duct assembly in Fire Zone 2-58. Additionally, there are no combustibles located near the exhaust air register in Fire Zone 2-4G. Therefore, a frre initiated in Fire Zone 2-58 would not generate enough heat to adversely impact any system in Fire Zone 2-4G. CONCLUSION:
Based on the above discussion, NFPA 90A. Section 3-3.2.1.1, the physical tayout of the adjacent Fire Zones and the combustible configuration within the Fire Zones. a fire damper is not required in penetration X-30-5-32. FPRR Rev. 11 DR11-18 A B *-t:: C C E 1 I ~N 2 frrlOTE: 111N STEAi P I PEIAT NO CJ.Ill[ TROS IITHI H S' OF DUCT IM TtllS ARU, YAlY[ JCC[SS AREA CED HDOR H. 7&1'-IU" 'lAH El El. 149'-1" 3 315: SUND-*BT CONTROL SlS TUS Uf(I 5 B.0.0. [l. a,*-1** Cl2 .. l 22"\ Nlll REGISHR) 2)' ,l,Ul . Q 6 ~~"-~*1111'1 110. IUU ,.111 1111 .. -I MIM'11 """"'" NOTE: 1 FDA L llilND SH 016 , A-2 0!179 0. SHT. I S U SQ U E H ANNA S.E.S. UNIT 2 AP PENOI X "'R" DEVI AT I O N RE Q UEST NO. 1 1 PENE TR ATIO N X-30-~ &.. X-30-5-32 AREi\ JU !ELEV .149"-l'jscALE NA I J>ENNS Y~VRNIR P C\.l[R ' LIGHT ccnPRNY RLJ.~NTC\JN PA. :**c~*2os7s9 l" T6 , . , .. c=Y G93 sH. 10 1 l Jll1IIJll]ll11111*
1 1 1jj j ,j j 1!JjJ1!1 ll 1 il11ll[I J j\[jl l l n l 1 1 1 , n, 1' j-14 1'"'1 I I I I'"' I I I 1-1-*-*-1-1 I"') [f] 2 II SSES-FPRR Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATJON SYSTEM: X-30-5-50 2-5B/2-5A-N 30 11 X 26" UNIT 2 PRIMARY CONTAINMENT DRYWELL PURGE EXHAUST TO STANDBY GAS TREATMENT DrSCUSSION:
As shown on Shts. 11 and 11A of Drawing c .. 205789, this duct assembly penetrates the fire barrfer wall at Elevation 770'-9&deg;. This penetration joins Fire Zone 2-58 with Fire Zone 2-5A-N. There are no duct openings in either Fire Zone. Fire Zone 2-5A-N is a fully sprtnklered area. JUSTIFICATION:
a) b) Fire initiated in Fire Zone 2-58 with potential to spread to Fire Zone 2-SA-N. Fire Zone 2-5B has minimal combustibles and the nearest combustible is approximately 5 feet from the duct assembly.
Also, there are no openings in the duct assembly ,n this zone. Therefore a fire initiated in Fire Zone 2-59 woutd not generate enough heat to adversely impact any system in Fire Zone 2-SA-N. Fire initiated in Fire Zone 2-SA-N with potential to spread to Fire Zone 2-58. Fire Zone 2-5A-N is protected by an automatic fire suppression system and there are no openings in the duct assembly in this zone. The automatfc suppression system would mitigate the consequences of any heat generated in Fire Zone 2-SA-N as a result of a fire in Fire Zone 2-5A-N and. therefore, a fire initiated in Fire Zone 2-5A-N would not generate enough heat to adversely impact any system in Fire Zone 2-58. CONCLUSION:
Based on the above discussion.
NFPA 90A, Section 3-3.2. 1.1, the physical layout of the adjacent Fire Zones and the combu~tible configuration withrn the Fire Zones, a fire damper is not required in penetration X-30-5-50.
FPRR Rev. 11 DR11-19 
) I I R B {, C D E ---1 2 =-N 33 = ;; :::, ~1 HU lijj H v v Y t I .I.._ D. 0. T El. b 'fUY( AC C[SS AR E A CBD B.Q.1. ft. 172'*8'' lHK 13 0** I 6") 1.0.1. H. 1s1*-o"rau (6"1 G''l 3 8.tl. L [L. 11J*.:,~ Ultl (H" l ti") SUND-Bl CONTROL S1STUS ARU Pl.lH e [L. 7'9'-1 ------------
------*-----* " 5 6 7 [&sect;"" ... {, ,,;.,,, .. INIUJh~ -*~~r -l-i=-B_, =* l s=i I 0i I Ml i .... u.,., A~ .;;;;;"Pl @l~" *** .'~".:: ;g; , I T , .. 11 ., T 'I T , .. 11 ., T . -.}9~:*-:;-i* ~j';;-r: f;r.", *:-r,;i . jt ~J.~l i_l l;~-1:t BEV*_ :::::~ 00-'0-". ~~~~(;,.)~ .... ".'..,= .!... *.. =* "~-~ ,. !2!b_~D ! :.:.:* . .~;,!. ... "C:1w , *1...u ........... ,o-~~!:.::~ 1<: E Y Pl ... N ...... 1 ... ~-1--~-H ,I , .. ,_, t-, I * - FOR t[G[II O S[f D I G. i-20 5 190. S.H T. I ,. I ORt nu s DI C. tl lH C-20S J 89 , s t n. IIA EI.D.t. fl. 75 9*-11 "E H~ (JD'' I 6'') B.0.T. H. , n*~**c a,; (6"'1 G") ~* *-8.0.l. El. 77J"-3' [2 U C.10" J 6") DOIH T O EL 111*-9** k~ ~~-~--:~**::-:'.~~~'~ 1"""".'" i L i_!; !I --;1 , , -1 1 --1 -1 1 l=i' -----*-*-------1 I S US O UEH n NNn S.E.S. -LJ 1, 1 I I 2 /\Pi>L:.1*1n I X " I<" DEV II\ T ! 0 1.J RU!UEs*: N O. , : P E Ni::T:<1', TlllN X-30-5-50 P.RE A 30 j E L E V .l'9'-1 " j~"-n!:.L._:~~-FENNSY\..VAN 1A P O\.I E:R t L IG HT C: Q ,'"l;>A N'f . ALL.Z: t l TO\.IN PA , "*c'.:'2os 789 l" i "i i'* ., ~I (I U,.ht ~o. ; I C-1693 SH. 11 l I , t A C l 2 3 -~-,:,-I{ . ----11.U.D. EL. 71l"-I" El. llil'-0" (lJN l6" J 6") 711 '-1" 21,;e (,t" l 2***) J.t9'-J" 6 i I. FDR UGEND SEE DrC. A-105790. SHT. I 2. IORl THIS IJIC. 11 tH C-20SH19, SHl. 11 Text Rev. 11 PENETRA TtON:* ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
*SSES-FPRR X*32-4-3 2-4A-S/2-4G 30" X 18tt REACTOR BUILDING ZONE 11 SUPPLY As shown on Shts. 15 and 15A of Drawing C-205789, this duct assembly penetrates the fire barrier wall at Elevation 741'-11 ". This penetration joins Fire Zone 2-.4A-S with Fire Zone 2-4G. A supply air register fs located in Fire Zone 2-4G near the face of the fire barrier wall. Fire Zone 2-4A-S does not have sprinkler protection in the area of concern and Fire Zone 2-4G has no sprinkler protection.
JUSTIFICATION:
a) Fire initiated in Fire Zone 2-4G with potential to spread to Fire Zone 2-4A-S. Fire Zone 2-4G has minimal combustibles with the only combustibles near penetration X-32-4-3 being two E2KJ cable trays. Based on the previously referenced analysis in this deviation request, the consequences of a fire in Fire Zone 2-4G would not adversely impact any systems in Fire Zone 2-4A-S. Therefore, a fire generated in Fire Zone 2-4G woufd not generate enough heat to adversely impact any systems in F,re Zone 2-4A-S. b) Fire initiated in Fire Zone 2-4A-S with potentiaJ to spread to Fire Zone 2-4G. As discussed within the justification for this deviation request, the combustible configuration and fire hazards of this portion of Fire Zone 2-4A-S are bounded by the analyzed condition in Fire Zone 1 *38-N. The first opening in the duct assembly in Fire Zone 2-4A-S is greater than 25 feet from the subject penetration.
Therefore, the combustible configuration in this portion of Fire Zone 2-4A*S would not generate enough heat to adversely impact any system in Fire Zone 2-4G. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones) a fire damper is not required in penetration X-32-4-3.
FPRR Rev. 11 DR11-20 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
) A B 0 C 0 d E , ... 1 FL. EL. 1Aq'~ t'" e.o. o. u. r.s 1'-1." {~** 14") e.o.T. EL 73q*.7* 31., * ;j_ E 2KJ (24'. o.') , . . I e.o.R. EL. 740 * (ZA
* 2A ') F L. EL. 7\q'. \" . :J; .... 2 --i (2-4A* ':>) 3 E1KH (31;;",0,")
e,.O.T. El..14\'-1&deg; E 2 KJ (2 4'* <.") *~\. .5 '::iECTION "15A
* 15A' " 5 <<* 33 EL. 74 I'-I I' ( 30&deg;, 1e,:_] __ I B.O.T. ei..1 n,.*-0* E 2<J (2 4', o,") '-. *--~-0.T. a.' 134'*<," E?KJ (24'*l.') EL. ,~5*-0* c,2*. , n I MAl>J 5TEAM P I PEWl'V C8&sect;) 6 7 --1-z;:::,-
K E"I'~ IJO T E'=>: I. *OR LEC.E.>JO 5EE. owe.. A*205 7q o, 5H. t. 2. WO RK T1,1 15 OWG,. W ITH C-205"711~, 5H. 15. S USQUEHA NNA S.E.S. UNIT 2 APPElslDIX
'R' DEVIA'TIOIJ REQUEST N O. f l PEislE'TR.t-'TION':>
X*32-4*3 4 X. * =i'Z
* 4
* 4 /\REI\ 32 !ELEV .719~JS CIILE NA P'INNSYLYRNJR PDV[R & LlllNT COf'Pfl'fY ALLINTDUN P'A. C-205789 15A 0 C-1693 SH.15A Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-32-4-4 2-4A-S/2-4G 12" X 12,. TRANSFER DUCT As shown on Shts. 15 and 15A of Drawing C-205789, the duct assembly penetrates the fire barrier wall at Elevation 735'-0". This penetration joins Fire Zone 2-4A-S with Fire Zone 2-4G. An air register is located in Fire Zone 2-4G near the face of the fire barrier wall. This duct system is a transfer duct which supplies air from Fire Zone 2-4A-S to Fire Zone 2-4G at a rate of ~00 cfm. Fire Zone 2-4A-S does not have sprinkler protection in the area of concern and Fire Zone 2-4G has no sprinkler protection.
JUSTIFlCATION:
a) Fire initiated in Fire Zone 2-4G with potential to spread to Fire Zone 2-4A-S. Fire Zone 2-4G has minimal combustibles with the nearest combustibles being two E2KJ cable trays. These trays are located at approximately the same elevation as the air register of the duct system. Any heat generated by these two cable trays would have a minimal effect on this transfer duct. Therefore, a fire initiated in Fire Zone 2-4G would not adversely impact any systems in Fire Zone 2-4-A-S.
* b) Fire initiated in Fire Zone 2-4A-S with potential to spread to Fire Zone 2-4G. There are no significant combustibles in area beneath the transfer duct grill in Fire Zone 2-4A-S. Any heat generated by the combustibles in Fire Zone 2-4A-S would migrate upwards and not be significant enough to impact the transfer duct. Therefore, a fire generated in Fire Zone 2-4A-S would not generate enough heat to adversely impact any systems in Fire Zone 2-4G. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper ;s not required in penetration X-32-4.4.
FPRR Rev. 11 DR11-21 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
A B C D E 1 T I 2 3 .s: E"1.KH (::,o", <.;) FL. EL. ?Aq'. 1" I I l'>0.1. EL. ~.o.o. EL. 141~t.." (~., o;IA-) eo., EL. Bq'. 7" EUJ (24'* <.") ' .
* 1. e.o.R. El. 1A0 *:> (2A
* i* ) FL. EL. 11q*. 1* *-.1 , : , ... (2-M,-<;,) e.O.T. E.L.141'* 1* HK.I (24 *, <.") . ' SECT I ON "15A*15A' q 5 3:, I e.o. r. EL.I 7 31,'-o
* c 2<.r (2** * <.") e.o:T. EL.1 'T~4**~* E'2KJ('ZA 0*l:} EL. , 3 s'o* {1_2*. ,n I MA.I~ ~TEAM P\PEW.,..,V 6 -, +-=-Kf.Y PLAl.J IJOTE':> : I. FOR LE.GENO 'oEE. DWG. 1'*2D57q0, <;,H. I. 2. WORK rn1,; OWG. WITM C.*20515'1, <;,H. 1:5. SUSQUEHANNA S.E.S. UNIT 2 APPEi'JOIX
'R' OE.VI.A.iiO;J REQUE';;i NO. 11 PENETR.A.i\Ot.J":>
;,<.* 3'2*4 *3 4 ~-~'2-4-4 It: A-:,R-::-EA,--,3cc2-rclEL EV
* 719'
* 1* J SCALE HA f'( .... S'FLVANIA POWER & l.18NT CD,.ANY ALL I[ NTOWN PA. C-205789 15A 0 C-1693 SH.15A Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-32-5-41 2-5A-S/2-5B 30'' X 26" UNIT 2 PRIMARY CONTAINMENT DRYWELL PURGE EXHAUST TO STANDBY GAS TREATMENT As shown on Shts. 12 and 12A of Drawing C-205789, the duct assembly penetrates the fire barrier at Elevation 769'-9 11* This penetration joins Fire Zone 2-SA-S with Fire Zone 2-5B. There are no duct openings in either Fire Zone. JUSTIFICATION:
a) Fire initiated in Fire Zone 2-5A-S with potential to spread to Fire Zone 2-58. There are no openings in the duct assembly in Fire Zone 2-5A-S or Fire Zone 2-58 and the only combustibles near the duct assembly in Fire
* Zone 2-SA-S are on the side of and above the duct. Therefore, a fire initiated in Fire Zone 2-5A-S would not generate enough heat to adversety impact any system in Fire Zone 2-5B. b) Fire initiated in Fire Zone 2-SB with potential to spread to Fire Zone 2-5A-S. The duct assembly in Fire Zone 2-5B has no openings and the combustible loading in this zone is minimal with no combustibles within 5' of the duct. Therefore, a fire initiated in Fire Zone 2-58 would not generate enough heat to adversely impact any system in Fire Zone 2-5A-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not required in penetration X-32-5-41.
FPRR Rev. 11 DR11-22 
{ ) I .') A B C D E ,------::=-
N 2 Rf*C70Rl,t7fl CUUI-UP BiCKIASH IUC[ IVINli TUil ioo* e.o.r. &#xa3;L. T51i'-6" z ,iu ar 1 6" , 8.0.1. EL. ns'-6"(7U (30" X Ii") 8.CI.D. ll 75!'~9" 130" J 26") ----'-----'-
./ .t_EL, no*~z 1/1 6"' R 1----+---PLAN El H. 7 61 "-111 .. 3 I.\ El. 169'-9" (]0" I 2:lii") a.o.T. &#xa3;L. 111*-c'" 1ns ar t6') ! [l. 711'*6" PRIIAflT co ,..r~ 1H1&#xa3;H r s = 6 I 7 -l -*-~:...... +--=--:::..r::-.~, I EJ:::~:::l .... l *1 6 .;;; .. *.,,. ~" " ----, ,.
... ~::,?~-~ -1 I **E.i ::>>:*, I : i~1~ ' -:;;-q ~*-&#xa9;-.. "'.!... * "'"**** **1** -_1-1 '\::;::J.2...
---~1-~1 i "-*~ *-0-;:-';1~\;:-1:;-~1.:;1~ -;;-r~~ l-~,U 0c.5=:----;; ~i~*,~c+,--1~1 ! * .2:/L.i!2!....-':'..
J~" L_t'. m*. " 0-.J;,:. ..,.'.,',:.
::.'.~::\.~ ffil~!n;'ii.,..
rr.:EY P\.llt: .. -l --' ' ........ ,,..... *-1 .. ,-** -t --***-I-** MOTE: I. FOR USfND S EE DI&. A-7 0579 0 , S HT. 1. 2. I OR ll T HIS Olli,. 11TH C-205789.
S Hl. 11:J.. .. L l j I: *, -, SUS~UEH AN NP, S.!::.S. i 3 U N I T 2 APPEl*!O I X " R" OE V!A T:ON RE DU EST N O. :: PENE: i~li TI O N X-32-5-4 1 A R EA 32 i EcEV J49'-l"/SC A cE P[.NNS'l'L V AN t rl PO\.IER &. LI G HT cor:Pl=I N'r' ___ ALLt t'10'.lN PA. I .. c*:*2os-=/a9-rr~r j'" ., "c'.:i693 S H .12 
---------** 2 3 4 5 6 I ., " ' 1 1 ; : t A J B r:.* C D E I fl. EL. 779'-1" Fl. H. l lil *-10" e.o.r. Et. 1!i,._, .. E2l~ 16" l lD" \ 2UB 16 .. l 14 .. ) Fl. H. H9'-1" CED R EACTOR 1Al(fl Cll .. N-UP B,l,CJ.USH REC E IVING UHk ROOI T. 0. G. El. 761. -IO" *b.-~4". . ~-... d*11,"l&,i i..~O:* h.. *. A ** ~4<.it.~ ",4: S(CTIOH "1 lA-1 2A' &#xa9; I t2 U (6''1 J D'") 2 1~8 "' .. 1 zr1 ffi:j;:;*r.~ IIJ l.,P I IG 0 t8""' , .. , .... , 1 111.J1:J\.III&
KtY Pl.l't l NOTE I. FOR L[G(NO S&#xa3;&#xa3; o ,i.. A-2D57 9 0 , SH l. 1. 2. IOR'-TII IS DI C. IIT II C-1 0 578!1. SHT 17. -8.0.D. El. 769'-9" (76" X 11l" l fl. E L. H il'-1 0" S U SQUEHANN A S.E.S. I~ UN I T 2 P.PPENDIX "R" DEV I A T I ON REQ U EST N O. 11 PE N E T RATI ON X-32-5-4 1 ~llEA 32 !E L EV .7 4 9'-1'jS C ALE NA PENNSY L V AN T A P O\JEfl' L LIGHT COMPANY A LL EN lO\J N PA. J r c: ii39 3 SH.12A , , 0 ,1 1 1.,, 1 , 1, 1 1 1 1 2 1 1 1 111 1 1 (, 1 1 1 11111 , 1111 1,.1111 111 11 11 1 1 ......... , r., I 1 ,. 1 4,., .... ,. 1 11 ..... 1 11 ...... _, ... , n ,-* ,_, 1 ... 1 l'~JI, O U*I II O .. O. C-205789 12 A fRI\CTIONI\L Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-33-5-26 2-5A-W /2-5E 12" X 8 11 REACTOR BUILDING ZONE II SUPPLY As shown on Shts. 13 and 14A of Drawing C-205789, this duct assembly penetrates the fire barrier wall at Elevation 767'-1". This penetration joins Fire Zone 2-SA-W with Fire Zone 2-5E. A supply air register is located in Fire Zone 2-SE near the face of the fire barrier wall. Fire Zone 2-SA-W is a fully sprinklered area. JUSTIFICATION:
a) Fire initiated in Fire Zone 2-5E with potential to spread to Fire Zone 2-5A-W. Fire Zone 2-SE has minimal combustibles.
The first opening in adjacent Fire Zone 2-5A-W is approximately 18 feet from the supply air regrster in Fire Zone 2-5E. Therefore, a fire initiated in Fire Zone 2-5E would not generate enough heat to adversely impact any system in Fire Zone 2-SA-W. b) Fire Zone 2-5A-W is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 2-5A-W as a result of a fire in Fire Zone 2-SA .. w. Therefore, a fire initiated in Fire Zone 2-5A-W would not generate enough heat to adversely impact any system in Fire Zone 2-5E. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not required in penetration X-33-5-26.
FPRR Rev. 11 1~ : l I~ A B C D E --=-N ""?--2 .~ NON-RE&ENEU TIVE tHU fJCHJNli(R 1100 1 CI:D 3 I LD.O. H. 7'!1"-1 .. (72" l A2") + JR~P ifi D UNO *RU 1-----7"0-'-'._! [ll[RGlNCr StlltttCUR L o*o C E NHR R OOI C8D LI 5 PO,l(ifU T JON A OO W -------**-~t] ______ , --1 I ..,.. ___ 1: ,;~*1_ ---C.11.0.T. EL 153"-P" 2P U (24" J ,t" l B.0.R. n. 111*-,r F--~ c 22*1 7 Z-) v,-_ B.D.T. H. 1U'-J .. 2U&f 3D"'X6" -------.'( _______ ---~ s: e.o.,. n. O[Rt(NCY S IIT CIIGEAA LD~O C[HHR RO D II CED 6 7 tffi"" .* (, ,.,.1, o1; ou 1 w 1, o1 +-=-~.~:*.~ ' 1 (.1)~ {>>) 1* c;i e(,l)?., -~-::;;;-; I. ..... 1 1
* T ..... *1T ._ &#xa9; n-1 .... ......,_ "-'"''''"-""""* *~,' .. 1-;;-1,:_~:,.,, 1~ ~l~P~'.!..i' ooJi,~~.~; & 7* l_n !_~1 l\ 1) II ** l~I ~, , ... ,&#xa5;; -~&1--, .. <~"'(B'J* ~,-;;-::::::=11
* ~-*** l , -.~ --, ~;':";._ .... ~-I ,. ** '" .. ";---\ : *.*. (v-*-*!., -::-. ~L-LJ .. ~. ,-,.~. 1 1-.o.;1u..
M.M:luo 11&.M: I UO li:;~I OII li((Yt,.,U I 0 MOHS: L fDI lEli[HII SEE D RAW I NG .l-205790 , SH UT I. 2. t O A'l TH I S OIU IIMli 1 1T H C-2 0 5 7"9, 3HEET 1 u*. I (I I : j I .=:i -----@ PL~N@ EL. 74''-1" S U SOUE HR NNf\ S.E.S. 1 1 UI\J I T 2 APPEi-JD IX "R" OEV!RTION REQUES T NO. 1 1 PENETR f\ T ION X-3 3-5-Zo iiRifiCiLJELEV
.7'9'-iiS CA~ PEHNSY L VA N JA POWER l l?GHT C OMPA NY \ A LL CU T O l,m Pn. I ... c*:*2os7-s-9l;
;rr r * "c=it93 sH .13
* 2 3 -r---::=--N A B C D &#xa3; 33 LI B.O.R. El. 1&2'-1 O" (l2"' 1 2l-l SECT I ON 141'-14A 5 @ I -~~-I. O.D. (L. 771 '-11" ().C" l liO") E L. 16!'-0"0e.;.l 17 .. ) ll. 1&A7:f""~l]f'')
H. 163'-9" 2 PU 1.r* l 2'") fl. l67'-1 1"7 UG U"J 1'") ---=,-C SOR r s 6 -., 8~1'.: EJ-., ui , .. ,~-~"-... $+::::: I ~*~: I ~*!: I ~:~: I H O T ($: I r oR l[riENO S EE DR.t, IPU I ~-7D~J 90. SH~El I. 2. IO R l THIS II RAI I H C. 11TH C-70~11 9 , S H UH 13 1 14. S U SQUE H F\NNA~E. S. UNIT2 A P PENDIX "R" DEVIATION R E Q U EST NO. 11 P E N ETRATION X-33-5i6 AND X-33-5-27 AR E A Jl ELEV. J.9'-1 'ISCALE NA PtNNSYL\'RHSR POMtR & LJ:GMT COMP~NY RLL[N T OWN PR. '"'c'-='205789 I 1 4 A "c"'~(593 SH. ILIA Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-33-5-27 2-SA-W /2-5E 18" X 12" REACTOR BUtLDING ZONE U EQUIPMENT COMPARTMENT (FILTERED)
EXHAUST As shown on Shts. 14 and 14A of Drawing C-205789, the duct assembly penetrates the fire barrier wall at Elevation 769'-0". This penetration joins Fire Zone 2-SA-W with Fire Zone 2-5E. An exhaust air register is located at the face of the wall in Fire Zone 2-5E. Fire Zone 2-5A-W is a fully sprinklered area.
* JUSTIFICATION:
a) Fire initiated rn Fire Zone 2-SE with potential to spread to Fire Zone 2-SA-W. Fire Zone 2-5E has minimal combustibles and there are no openings in the duct assembly rn adjacent Fire Zone 2-5A-W. Therefore, a fire initiated in Ffre Zone 2-SE would not generate enough heat to adversely impact any system in Fire Zone 2-5A-W. b) Fire initiated in Frre Zone 2-5A-W with potential to spread to Fire Zone 2-5E. Fire Zone 2-5A-W is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated as a result of a fire tn Fire Zone 2-5A-W. Therefore, a fire initiated in Fire Zone 2-5A-W would not generate enough heat to adversely impact any system in Fire Zone 2-SE. CONCLUSION:
Based on the above discussion, NFPA 90A} Section 3-3.2.1.1, the physical layout of the adjacent Fire Zones and the combustible configuration within the Fire Zones, a fire damper is not requked in penetration X-33-5*27.
FPRR Rev. 11 DR11-24 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
A B .. f) . -~ C L , ,:-) E 1 I I =-N 2 3 33 q 1.0.R. El. 7'2.'-10'' (2Z" I 22"' l SECTION 1411--141'
~""-_ _I~ I I I I I ____ --1&i,ffii
... -~. T"I' s 8.0.D. EL [l~ Er:-Ji4-*--f.--2UG
--(6'&deg;1 J [L lil'-B" 2PM EL. Hil'-11'"111' ----------"'" @ ~4..t fL fl_ JU'-1" 6 -, ffi1~"-t)l,UOI"'-... -0 ..... &sect;-IIOTES: I. FDR l(UHO S[E DR.UHi& A-2D~79D , SH([T 1. ?. IOU. nus DRHIH; IITK C-10:1169.
SHUTS 13i M~ SUSQUEHANNA S.E.S. UNIT2 APPENDIX "R" DEVIATION REQUEST NO. 11 PENETRATION X-33-5~6 ANO X-33-5-27
/\REIi 3\ ELEV .1,9*-l'!SCALE NA P[NNSYLVFINJFI PO\.l[R & LlGMT tDMPANY All[HTOWN PA. "c:*2os7s9 , 14A .. c****r't93 sH. 1LJA Text Rev. 11 FPRR Rev. 11 SSES-FPRR ATTACHMENT 1 to DEVIATION REQUEST NO. 11, HAS BEEN DELETED DR11ATT1-1 SSES-FPRR Table Rev. 11 TABLE DR1H Fire Zone/ Penetration Duct Size Zone Zone Without Drawing C-205789 Fire Area Sprinklered Duct Ooenino Reference UNIT 1 1 *3A/1 *3B*N X-25-3-37 a* X 6" 1*3A Neither Shts. 1&1A 1*5B/1-4G X-25-5-23 24" X 18" Neither Neither Shts. 2&2A 1-5B/1-5A-N X-25-5-13 3o*x 26* Neither Both Shts. 2&2A 1 *5B/1 -5A-N X-25-5-15 22" X 18" Neither Neither Shts. 2&2A 1-4A-S/1-4G X-27-4*16 30" X 18" 1-4A*S Neither Shts. 3&3A 1-4A*Sl1*4G X-27-4*17 12" X 12* 1-4A-S Neither Shts. 4&4A 1-SB/1-SA-S X-27-5-29 18" X 18" 1-SA*S Neither Sht. 5 1 *58/1-SA*S X-27-5-30 30" X 26" 1-SA-S Both Sht. 6 1-5A-W/1-5E X*28*5-44 18" X 12" 1-SA*W Neither Shts. 7&7A 1-5A-W/1*5E X-29-5-25 12" X 8" 1*5A*W Neither Shts. 8&7A UNIT2 2-58/2-SA-N X-30-5-4 18" X 1a* Both Neither Sht. 9 2*58/2-SA-N X-30-5-5 22* X 22* Both 2-SA-N Sht. 10 2-5B/2-4G X-30-5*32 24" X 18" 2-SB Neither Sht. 10 2-58/2-SA-N X-30-5-50 30" X 26" Both Both Shts. 11&11A 2-4A-Sl2-4G X-32-4-3 30" X 18" Neither Neither Shts. 15& 15A 2-4A-S/2-4G X-32*4*4 12" X 12" Neither Neither Shts. 15& 1 SA 2-5B 2*5B/2-5A-S X-32-5-41 30" X 26" Both Shts. 12&12A 2-SA*S (Part) 2-SA-W/2-SE X-33-5-26 12" X a* 2-SA-W Neither Shts. 13&14A 2-5A-W/2*5E X-33*5-27 1s:x 12" 2*5A-W 2-SA-W Shts. 14&14A FPRR Rev. 11 Page 1 of 1 Text Rev. 11
* SSES-FPRR APPENDIX R DEVIATION REQUEST NO. 12 FfRE BARRIER WITHOUT FIRE DAMPERS IN VERTICAL VENTILATION DUCT PENETRATIONS DEVIATION REQUEST: Fire dampers are not required to be installed in the following ventilation duct penetrations in fire rated floor/ceiling assemblies between affected fire zones. Penetration Fire Zone/Fire Zone X-27-6-17 1-5A-S/1-6A X-27*6-18 1-5A-S/1-6A X-27-6-50 1-5A~S/1-6A X-27-6-51 1-5A-S/1-6A X-27-6-83 1-5A-S/1-6A X-28-5-66 1-4A-W /1-SA-W X-29-5-34 1-4A-W/1-5A-S X-29-5-54 1-4A-W /1-5A-S X-34-5-4 2-4A-S/2-5A-W FIRE AREAS/ZONES AFFECTED:
This deviation request concerns Fire Areas R-1A, R-1Bt R-2A and R-2B. REASON FOR DEVIATION REQUEST: NRC guidance to 1 OCFR50J Appendix R, Section 111.G requires fire rated barriers between Fire Areas. The guidance documents provided by the NRC indicate these barriers shall be rated for 3-hours fire resistance and ventilation ducts that penetrate
* such barriers shall have fire dampers installed.
The floor/ceiling assemblies identified to be upgraded in PP&L's September 4, 1985 response (PLA-2529) conta[n ventilation duct penetrations which do not contain fire dampers. EXISTING ARRANGEMENT:
A description of the floor/ceiling assembHes penetrat~d by ventilation ducts is provided in Table DR12-1. See attached sheets of Drawing C-205791 for details. Attached Drawing A-205790, Sht. 1 provides the legend for understanding these drawings.
FPRR Rev. 11 DR12-1
* SSES-FPRR Text Rev. 11 JUSTIFICATION:
NFPA 90A-1985, Section 3-3.2.1.1 states that "Approved fire dampers shall be provided where ducts or air grills penetrate partitions required to have a fire resistance rating of 2 hours or more." The maximum average combustible loading for any fire zone in the Reactor Building is limited to 1-1/2 hours. This is based on a conservative estimate of in-situ combustibles and an allowance of 15 minutes for transient combustibles.
The specific combustible configurations and potential for transient combustibles were evaluated for each duct penetration.
It was concluded that the local combustible loading exposure to these fire barriers is less tha_n 1 hour. Therefore, the subject duct assemblies do not require fire dampers per Section 3-3.2.1.1 of NFPA 90A. Furthermore, all of the fire zones located beneath the penetrations in question are protected by an automatic fire suppression system. In the event of a fire in one of the fire zones beneath these penetrations, the automatic suppression system wou!d mitigate the heat generated in those zones and prevent the fire from impacting the fire zone located *above the rated floor. Conversely, the fire zones located above the penetrations in question do not contain sufficient combustibles to generate enough heat to adversely impact the fire zones located beneath the penetrations.
This statement is substantiated by the analysis prepared for Deviation Request No. 11. This analysis conservatively concluded that with the worst case combustible configuration in Deviation Request No. 11 1 the maximum air temperature in the duct assembly would be 146&deg;F. Although this analysis was conducted for a horizontal duct assembly, the combustible configuration would not raise the air temperature in the vertical duct above unacceptable limits. The results of the analysis demonstrates the following:
Since the maximum temperature on the fire side of the fire barrier is 216&deg;F, the non-fire side of the fire barrier will remain below the ambient temperature plus a 250&deg;F temperature rise, which is the fire damper acceptance test criteria.
Since the HVAC duct temperature remain below 165&deg;FI a fire damper operated by a 165&deg;F or higher fusible link would not operate. Since automatic sprinklers in the Reactor Buildings are rated at 212&deg;F minimum, the increased room temperature resulting from an air inlet temperature of 145&deg;F will not result in sprinkler system activation. (The analysis calculated the final room temperature of Fire Zone 1-3A to 105&deg;F.) A fire in Fire Zone 1-38-N with a resultant 21(?&deg;F room temperature represents the worst case covered by this deviation request, because Fire Zone 1-3B-N contains a more severe combustible loading than any case covered by this deviation request. Automatic sprinkler protection where provided will reduce this maximum temperature.
Equipment and cables in the adjacent affected fire zones will not be damaged, in the event of a fire in an unsprink!ered fire zone, sufficient heat air can be transferred via the HVAC duct. Air will not be transferred if the HVAC system is not operating.
nor is it possible for hot FPRR Rev. 11 DR12-2 SSES-FPRR Text Rev. 11 air to be released from a return air duct. Therefore, only cases where a supply duct in an unsprinklered area could transfer air to the adjacent fire zone needs to be considered.
Air flow temperatures which could actuate sprinklers in adjacent fire zones are not a problem in the ducts with vertical penetrations because either: The duct has no openings in either fire zone or on either side of the fire barrier. -OR-The supply duct to a sprinklered fire zone has no openings in that fire zone. -OR-The fire zone is sprinklered and in the event of a fire in that fire zone, the fire would be controlled before it could heat the HVAC duct supplying air to the adjacent fire zone on the opposite side of the fire barrier. The NFPA 11 Fire Protection Handbook" (14th edition, Pages 7-69) states: "In the gauges commonly usedt some sheet metal ducts may protect an opening in a building construction assembly for up to 1-hour, if properly hung and adequately fire stopped. Therefore 1 ducts passing through fire barriers having a rating of up to 1-hour fire resistance can be assumed to present no extraordinary hazard. If the wall, partition.
ceiling or floor is required to have a fire resistance rating of more than 1-hour, a fire damper is required ... n The minimum 18 gauges (0.048 inch thick) sheet metal ducts used at Susquehanna (Ref: Drawing C-1126) are heavier than the commonly used gauges referred to by the NFPA statement.
The ducts are seismically hung (Ref: Drawings C-1129 through C-1136) and adequately fire stopped (Ref: Respective penetration drawing for each listed duct penetration on Drawing C-205791, all sheets). A 3-hour fire resistance rating can be achieved by a fire damper constructed of 24 gauge steel. It is therefore reasonable to conclude that HVAC ducts without openings in the fire zone and constructed of a minimum of 18 gauge steel will not be breached by a fire. Therefore, it is our position that these ducts adequately mitigate the effects of a fire and do not require fire dampers. Furthermore, this Deviation Request will remain valid for these HVAC duct penetrations as long as the sprinklered areas remain sprinklered and as fang as combustible configuration changes in sprinkler areas do not cause: FPRR Rev. 11 DR12-3 SSES-FPRR Text Rev. 11 a) Calculated maximum fire barrier exposure temperatures during a fire to exceed 1700&deg;F (the maximum standard) time-temperature curve value for a 1-hour fire test) and/or b) Calculated temperatures in adjacent sprinkfered fire areas to reach a level at which automatic sprinkler systems would be activated.
The followrng descriptions and drawings (C-205791, all sheets) provide the basis for our position and address each ventifation duct penetration on an individual case-by-case basis. Through this case-by-case approach, each duct penetration is shown in its actual combustible configuration in the plant. Parameters such as nearby combustibles, direction of duct air flow, location zone configuration have been examined to clarify and document the justification for this deviation request. FPRR Rev. 11 DR12-4 PP&I. FOftM SOD 11./MJ (x-xx-x) FIRE ZONE ~-~~-, PENETRATION NO. FIRE RATED FLOOR FIRE T.O.G. = TOP OF GRATING 8.0.0. = BOTTOM OF DUCT H.O.R. = BOTTOM OF REGISTER B.O.T. = BOTTOM OF TRAY EXAMPLES*:
BUILDING COLUMN LINE FPO 3 3 HOUR FIRE DAMPER
*suPPLY AIR REGISTER C\::., ... EXHAUST Al R REG I STER AIR FLOW DIRECTION RATED HALL b SECTION SHOHN ON SHEET XX 8.0.D. EL. 772'-sn C16"X24ul
"--DUCT SIZE 8.0.R. EL. 772'-9" c1eux2su1 REGISTER SIZE. 8.0.T. EL. 772'-Su 2MKA (24"X6ul CAB-LE TRAY IDENTIFIER . TRAY SIZE NOTE1 SIZE .OF DUCTS, REGISTERS i CABLE TRAYS ARE. SHOHN IN PLAN AS HJDTH X HEIGHT. EX.: C24&deg;X6&deg;l.
SHOWN IN ELEVATION VIEW AS HEIGHT X HIDTH. EX.t (6&deg;X24").
SUSQUEHANNA S.E.S. NON-QUAL lTY RELATED AREA NA ELEV. NA SCALE NA UNIT 1 t 2 APPENDIX "R" DEVIATION REQUEST~ LEGEND NO. 11 -SEE DRf\HING C-205789 "NO. 12 -SEE DRI\HINQ C-205791 ~ENNSYLVANIA POWER & Ll8HT COl'PANY ALLENTOWN fl'A. l'l'lL DIUlNIN8 NO. SHE:ET Na. REV.NO. 1~-205790 . 1 J 0 CD 0 a FRACTIONAL Q 0 DECIMAL CYOO:N Text Rev. i 1 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-27-6-17 1-5A-S/1-6A 26" D1AMETER REACTOR BUILDING STANDBY GAS TREATMENT SYSTEM SUCTION FROM RECIRCULATION SYSTEM As shown on Shts. 1, 1 A and 1 B of Drawing C-205791, the duct assembly penetrates the fire barrier floor at Elevation 779'-1". This penetration joins Fire Zone 1-SA-S with Fire Zone 1-6A. Fire Zone 1-SA-S is a fully sprinklered area. JUSTIFICATION:
a) Fire initiated in Fire Zone 1-5A-S with potential to spread to Fire Zone 1-6A. Fire Zone 1-5A-S is protected by an automatic suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-5A-S as the result of a fire tn Fire Zone 1 *SA ... s. Therefore, a fire initiated in Fire Zone 1-SA-S would not generate enough heat to adversely impact any systems in Fire Zone 1-6A. b) F;re initiated in Frre Zone 1-6A with potential to spread to Fire Zone 1-SA-S. Fire Zone 1-6A has minimal combustibfes, and there are no openings in the duct assembly in this fire zone. Therefore, a fire generated in Fire Zone 1-6A would not generate enough heat to adversely impact any system in Fire Zone 1-5A-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within the fire zones. a fire damper is not required_
in penetration X-27-6-17.
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Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-27-6-18 1-5A-S/1-6A 32" DIAMETER UNIT 1 PRIMARY CONTAINMENT DRYWELL AND SUPPRESSION POOL PURGE EXHAUST TO STANDBY GAS TREATMENT As shown on Shts. 21 2A and 2B of Drawing C-205791, the duct assembly penetrates the fire barrier floor/ceiHng at Elevation 779'-1&deg;. This penetration joins Fire Zone 1-5A-S with Fire Zone 1~6A. There are no openings in the duct assembfy in Fire Zone 1-SA-S or Fire Zone 1-6A. Fire Zone 1-SA-S is fully protected by an automatic suppression system. JUSTIFICATION:
a) Fire initiated in Fire Zone 1-5A-S with potential to spread to Ftre Zone 1-6A. Fire Zone 1-SA-S is protected by an automatic suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-5A-S as a result of a fire in Fire Zone 1-SA-S. Therefore, a fire initiated in Fire Zone 1-SA-S would not generate enough heat to adversely impact any system in Fire Zone 1-6A. b) Fire initiated in Fire Zone 1-6A with potential to spread to Fire Zone 1-SA-S. Fire Zone 1-6A has minimal combustibles and there are no openings in the duct assembly in this fire zone. Therefore, a fire generated in Fire Zone 1.:.6A would not generate enough heat to adversely impact any system in Fire Zone 1-5A-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within the fire zones, a fire damper is not required in penetration X-27-6-18.
FPRR Rev. 11 DR12-6 A B C D Q E 2 3 =---N :21.s e.0.1. ll. 111*-s** , ue DDfN TO El. 765'-6" 17'"1.S"\ a.o. T.H. 11 2*~1/2~1u 1:. DOIN TO El. 166'-7" C14" l 4'') .'*~~~~( * *..* r.*f* 1.0.I L n. 111*-r* C3 D" I 76'') SllND!IT CONU OL $YST(l111:E,l ,r~ ~.* PLAN* E l. H9'-1" FL. EL. 7&2'-IO" LI 5 8.0. T. tl. ll~' -4 ** I UA C 1 2''l .t"l UPT O 7 91'-6" V.llV[ A C C&#xa3;SS .I.AU 6 7 r.;1::.1~~,!I G..,*..o*.o  --i=-B _ .. -........ """' ~8 -El ~**~ *~*Ml: *-l<EY PLI\N --&ii;~ n.1:~.l-~~J.i~I~. 1----!--+m'" I "'T I ;,;r I 'l"'P" \ii;""J" i !!!!:!:..
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--B.0.0. EL. 7 77'-7" oo** x 25* 1 SUSQ UE HA N N A S.E.S. UNIT I APP E N D IX "R" OEV:AT]Oi, R l:::;)U i:ST N0.1 2 PC:;,C:TRf'T J O I*; >:-~7-6-I B AREA 27 E:LEV .74 5"::i'1SCA LE NA PEN NS YL Vl='NJA PO\.IER & \.IG MT CO MPA NY fl;LL[NTDW~
P A, "'c*.::*3;3579 1 !"2 .. "c*.:..y595 sH _ 2 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
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ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: rnsCUSSION: -SSES-FPRR X-27-6-50 1-5A-S/1-6A 30" X 20,r REACTOR BUILDING ZONE 1H UNFILTERED EXHAUST As shown on Shts. 3, 3A and 38 of Drawing C-205791, the duct assembty penetrates the fire barrier floor/ceiling at Elevation 779'-1 11* This penetration joins Ftre Zone 1-SA-S with Fire Zone 1-6A. Fire Zone 1-5A-S has full sprinkler protection.
JUSTIFICATION:.
a) Fire iniUated in Fire Zone 1-5A-S with potential to spread to Fire Zone 1-6A. Fire Zone 1-5A-S fs protected by an automatic suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-SA-S as a result of a fire in Fire Zone 1-SA-S. Therefore!
a fire initiated in Fire Zone 1-SA-S would not generate enough heat to adversely impact any systems in Fire Zone 1-6A. b) Fire initiated in Fire Zone 1-6A with potential to spread to Fire Zone 1-5A-S. Fire Zone 1-6A has minimal combustibles and there are no combustibles in the immediate area of the duct a~sembly.
There are no openings in the duct rn Fire Zone 1-6A; however, there is an exhaust air register in adjacent Fire Zone 1-61. There are no combustibles located near this exhaust air register.
Sufficient combustibfes do not exist in Fire Zones 1-6A and 1-61 to generate enough heat to adversely impact any systems in Fire Zone 1-SA-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within these zones, a fire damper rs not required in penetration X-27-6-50.
FPRR Rev. 11 DR12-7 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
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N RI fu-~~-,0, :is*. :;;:\ Q . " . -* :::::J mo.~~ :N n 1:11 a Ma ~* B C D E: FUEL PODl HOLD ING PUIIIP ltODI (EC) SU AGE TAU YAUL T CED 138 8. 0.0. El. 191 (18" l 12") 6' 50 .!P.~** PUN ti EL. 7 79'-I" ICCtSS AREA CIE:> SPEMT FUEL POOL CED C (' 8*-EJ~ MEYP\M NOTES: I. FOR UGEMI SH OR A i ING A-205790. SHEET 1. 2.. IOU T K I S ORlltNG 11TH C-71157 9 1. tiil&#xa3;ET S ] .S, 39. SUSQUEHANNA S.E.S. UNIT I /I P PENOIX "R" DE VI/ITIDN REQUEST NO. 1 2 PE NETRIITION X-27-6-5 0 A R EA 2 7 !ELE V .779'-rjSCALE NA P[J4NSYLYANIA POIJ,tR 4 LIGHT CO,.ANY RLLf.HTOWN PA * .. 1::=*2 os791 1 3A "~c: i696 SH. 3A Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM~ DISCUSSION:
SSES-FPRR X-27-6-51 1-5A-S/1-6A 30" X 20 1* REACTOR BUILDING ZONE Ill SUPPLY As shown on Shts. 4, 4A and 48 of Drawing C-205791, the duct assembly penetrates the fire barrier floor/ceiling at Elevation 779*-1 ". This penetration joins Fire Zone 1-SA-S with Fire Zone 1-6A. Fire Zone 1-5A-S has full sprinkler protection.
JUSTIFICATION:
a) Fire initiated in Fire Zone 1-5A-S with potential to spread to Fire Zone 1-6A. Fire Zone 1-5A-S is protected by an automatic suppression system which woufd mitigate the consequences of any heat generated in Fire Zone 1-5A-S as a result of a fire in Fire Zone 1-SA-S. Therefore.
a fire initiated in Fire Zone 1-5A-S would not generate enough heat to adversely rmpact any system in Fire Zone 1-6A. b) Fire initiated in Fire Zone 1-6A with potential to spread to Fire Zone 1-5A-S. Fire Zone 1-6A has minrmal combustibles and there are no combustibles in the vicinity of the duct assembry.
This duct assembry also goes through Fire Zone 1-61; however. that zone also has minimaf combustibles with no combustibles in the vicinity of the duct assembly.
There are no openings in the duct assembly in Fire Zone 1-SA-S. Therefore, sufficient combustibles do not exist in Fire Zones 1-6A or 1-61 to generate enough heat to adversely impact any systems in Fire Zone 1-5A-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within the fire zones, a fire damper is not required in penetration X-27-6-51.
FPRR Rev. 11 DR12-8 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
1 I A B C D E _I 2 =-N run PO OL HOLD I NS f'UIP ROPa CED 8.0.0. i1.;~r--.1 ( 3 ) ...., -Zv"v"'x'f';,('X! ------' I Ll 5 4E3l '.7. acuss uu ::: :r::::::==r: ( 8.0.D. EL. 119'-l" f H''l 24".) H. I ,mm,m, >2 s* nn -~{ii \I ~.f.'"'* I 481 .,.,., SURGE TAMIi VAULT .CED ~"[l'T r uu POOL c;::D 1tt PL*N@ EL. 779' _, .. 6 7 B~:: l!!Jaiu.o1oa
~'""' .~--...,""" ,uni--~ CDfflQ. U'fll. ~9-'0.Q., -** ..,., -"" NOTES: 1, fOR LE 6[NO $[[ ORAIINli A-205798 , SHEET I. 2. IORl T H IS DA.H I N G 11TH C-700)791 , SHEETS' I 4 8. SUSQUEHANNA S.E.S. UNIT1 APPENDIX "R" DEVIA T ION REQUES T NO. 12 PENETRATION X-27-6-51 AREA 2 7 !ELEV. 779'-l'!S C A L E NA Pl!H"'S Y L V AHlR POWER & LIGHT C01'1PANY RLL[NTOWN PA * .. c:*205791 1*~4A "'"c"~i696 SH. 4A Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Text Rev. i 1 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSJON:
X-27-6-83 1-5A-S/1-6A 20"X8 11 REACTOR BUILDING HVAC ZONE I EQUIPMENT COMPARTMENT (FILTERED) EXHAUST SYSTEM Note: This duct section has been blanked off and abandoned in place. As shown on Shts. 5, 5A and 5B of Drawing C-205791, the duct assembly penetrates the fire barrier floor/ceiling at Elevation 779'-1 11* This penetraUon joins Fire Zone 1-5A-S with Fire Zone 1-6A. Fire Zone 1-5A-S has full sprinkler protection.
It should be noted that this duct section has been blanked off at Elevation 780'-1 11 and has been abandoned in place. JUSTIFICATION:
a) Fire initiated in Fire Zone 1-5A-S with potential to spread to Fire Zone 1-6A. There are no openings rn the duct assembly in Fire Zone 1-SA-S and heat generated by a fire in Fire Zone 1-SA-S would be mitigated by the automatic
* suppression system in Fire Zone 1-5A-S. Therefore!
a fire initiated in Fire Zone 1*5A-S would not generate enough heat to adversely impact any system in Fire Zone 1-6A. b) Fire initiated in Fire Zone 1-6A with potential to spread to Fire Zone 1-SA-S. The duct assembly is capped one foot above its floor penetration f n Fire Zone 1-6A and there are no combustibles in the vicinity of this one foot length of duct. Therefore, a fire initiated in Fire Zone 1-6A would not generate enough heat to adversety impact any system in Fire Zone 1-SA-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within the fire zonest a fire damper is not required in penetration X-27-6-83.
FPRR Rev. 11 DR12-9 I l R B c* 2 =-N il.0.1. El. 773'-4" UIO (24"~ ii") l~A , .. 1.: . 771!-IO"UKB (24"16") fl.[l.J62'-1D''~ D.O.D. El. 165'-ID" C U" J 1 4") SUND-Bf COHTIIO L STSHl .\RU C*~.,..-,)
DI H I E J " 5 2-fil PLAN* El. 749&deg;-1" VALVE ICCESS uu 6 8:a.:': E:]*m.J)I OIII -* *-* ..... .. -... ,_ --l<EYPUVI l~': . .::_~:. =.'.t'. ~Sll.nal5.
~-... ,. -*o* ...., .. .....1-,.J.....
*O* -** ao*o* l"Tl'II" I iio,o** '11" ~-* **, 11*0* -** ~::: ~!!:i: n,*,* ,::,*.1::: 1**0* .,,, ,, 4*9-MOU w,,.:,:_ '-""=--I. FOi LEGEND SH DIG. A-20~190 , SNT. 1. 2. ,c,ur;, TH I S D IC. ltTN C-20~791, SHTS. ~A A til O 5 9. SUSQ U EH ANNA S.E.S. U NIT 1 I\PPE N OI X "R" DEV 1 1\ T ION REQUEST NO. 1 2 P E N ETRATION X-27-6-83 A RE A .Ti .f ELEV .1~f-1" j SCA LE NA PE:NHSYI..YANlR POWCR & LIGHT CO M P A NY ~LL&#xa3;NTOWN PA. ~c:*205791 , .. u50 , """c":_i696 S H 5 
* 't R B C 0 E 1 2 3 ~,=--N S HIELD Ull d SHPLE S T ATION RODI q TOP Of DUCT CAP'f'lOU El. JU'-1" (20"1 S") /i.(~~ ,*a**, ACCESS AREA. @D SKIHD UU 5 6 8~= 6*m,4l* r;i ..... El-= c:,;::: ,_ 7 .., PUN 1. roA L[li[ND SH 0 16. A-205790 SH. 1. B.,~',:, *-* ~-2. IORI!. U\IS DIG. 11111 C-20 5791. SH. 5 , ~!. ~. '.:*.~ ;~., + ------= 1 ..,<'"' + l ---,._. :,.*. ~I ...... Ll&sect;_ ,* a ',,. ' " . 1--------------. ; *, ... 0: ~! . .------!----------' ,Q .,,. ,
* SPENT run f'OOl \'.//? f
* ll " ' (BO PUN &#xa3;L. 779'-1" SUSQUEHANNA S.E.S. UNIT I APPENDIX "R" DEV I ATION REQU ES T NO. 1 2 PENET RATION X-27-6-83 AREA 27 * !ELEVJt'l'l'Js CA L E N R P"[NNSYL'i'ANfA
.-owr:R & LUiHT COl"TPANY ALL[NTOWN PA , "c.:*2os791
*sA* "~CM-i696 SH . SA '+
I I A B C D E __'illE_ 2 SHIELD WALL 8.0.1. EL. 113"-C" 111.18 o** X 24") 3 B.O. l. EL. 77 1:.10** IIU (6" l U" (20**1 r 1 FL. H. 162'-I D". REACTOR PROTECTION SUHI Iii sns ',\'.*.~.:.: STUrlll-BY CONTROL SYSlUI ARU GED rL. n. 1u*-1 ** d.t* .. *<*;,* SECT I ON "58-58" 0 I 1 'I T I I ; I I 'p* o7" r;-*. -.-,-,-,-,-1 ,'" I"'. i "'I'. I II I j 'I I 1
* 1 1 1 6 F""Rl'.CTTONAl.
* ~=.:.:.~-"t.
t G I lB___LJ ,', 4 5 18 0'-1" (2 0" X I"' l @ J '*' l&#xa3;L LL.U L IJC.'H i(.r i ((!JE S 775 '-4" INU (12 .. l 4**) 71 7'-5 N ... (*i~ VALVE ACC[SS lJl[A ~sca,lf-1 6 GJ~"-c,...e,,,, ... _ ... u., a .... -* ~-8""" El*---NOT E: OD fUH ~*:.1 ,::.rr:_-1~-1~~=:...1~1 ' :-~::: : =~:~~--~ 1-.*t"' I-~* I "11'0" I 1 1!'0" ~-e* l!!.:..!!
J l!''" .:.l~ ____!'H__'._~
L_?EI..'._ ** I. F O R l(i;(N O S U Qti;. A--10~790 , S N I. J. 7. I O U T H I S D I G. 11 T H C-20 51!11. S H T S. 5 AN O S l. S U S Q UE H ANNA S.E.S. UNIT l /I PP E N DIX " R" DE V I IITIO N R EQ U EST N 0.1 2. P E N ETR/IT!ON X-27-6-8 3 ,ARE A 2 7 I E L E V .1.~*-1" I SC A LE NA P[NNS Y LVANZ:A POVER & 1.?GHT COM PA NY RLL.[NTO~N PFI. ... c:*2 os791 nss .. '"c-:_i696 S H . 5 B Text Rev.
11 PENETRATION:
ADJACENT FtRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR
* X-28-5-66 1-4A-W /1-5A-W 22" X 22 11 REACTOR BUILDING EMERGENCY SWITCHGEAR ROOMS COOLING UNITS SUPPLY r~ As shown on Shts. 6, 6A and 66 of Drawing C-205791, this duct assembly penetrates*
the fire barrier floor at Elevation 7 49'-1 11* This penetration joins Fire Zone 1-4A-W with Frre Zone 1-5A-W. Fire Zone 1-4A-W has full sprinkler protection.
JUSTIFICATION:
a) Fire initiated in Fire Zone 1-4A-W with potential to spread to Fire Zone 1-SA-W. Fire Zone 1-4A-W is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 1-4A-W as a result of a fire in Fire Zone 1-4A-W. Thereforet a fire initiated in Fire Zone 1-4A-W would not generate enough heat to adversely impact any system in Fi re Zone 1-SA-W. b) Fire initiated in Fire Zone 1-5A-W with potential to spread to Fire Zone 1-4A-W. Fire Zone 1-SA-W is protected by an automatic fire suppres~ion system which would mitigate the c~msequences of any heat generated in Fire Zone 1-5A-W as a result of a fire in Fire Zone 1-5A-W. Therefore, a fire initiated in Fire Zone 1-SA-W would not generate enough heat to adversety impact any system in Fire Zone 1-4A-W. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within the fire zones, a fire damper is not required in penetration X-28-5-66.
FPRR Rev. 11 DR12-10 1i I I. R B C D E 1 ==--N L 8.0.T -.f.~EIPJ (2.4'"1 24") e ! IRAP AROUNG AIIU B.O.T. H. H0'-1 .. UP TO EL 7G2'-4" ON TOEL. llJ'-1" 2 B.0.0, El H2"-8* (38" J 2' 'l Ef"IERGEM(T
$WITCH {.E,1 , IR ~QOM 3 i +/- (TOP OF ROOM 5LAA I> El. 739*.9*) T l k ,o-* ' JD' L.&sect;J;l I~' ' r. -(''. >.,*I-I.' r*L,.-J111 1 1i1:11r11i1z
~/i\CTICW\L I 1111 I' l 1 1 I I I: Ii I I I'' I I b DE C'i foll\l.. :E PUN@ El. 719'-1" lG( L&sect;J FP11-J THRU SOU AT EL. 5 10**, Ja:* 28"116"._J
' EMEi.GE NC 'I' SWI re 1-1 (,[AQ POOM (TOP OF' J.OOM ~LAeC?(L.T J**:f-C:, 0) G:K:) i -I--0 I;; I I I B 10111 IC:.i IF I riORTsl 6 .., 8~:-: 6 .... l.1.11 ... -=~ *-* ~. .. _ -,n...,.. ,,,_,,. .__ __,.. Oltm.. """""14 comq. -aa.o.. aai.a... a4llll.&. ~n.~ * .,..a.. -*o* ... ,.,--** ** -*** -** .-n** ~. *---*-* _, ... .............
_ ... . g-u---. " NOTES: I. fOi:t LEGEND SH OAUING .1-105790, SHT. J , 2. 10R"-T!OS OUJING 11TH C-205.191, SHlS. SA,68 I. B SUSQUEHANNA S.E.S. UNIT! /\PPEND IX "R" DEVI/\TJON REQUEST NO. 12 PENETRATION X-28-5*66 AREA 2Bl29 !ELEV 719'-1" !SCALE NA* P[NNSYL.\'ANJA POUER & LIGHT CDr1PRNY RLL[NTOUH PA. '"c:*205791 I 6 .. "c'.'...i696 SH . 6 11, .... 0Wl.1 I ; I Security-Related Information Figure Withheld Under 10 CFR 2.390
 
1~ I~ .t z._:...:=-
N 'i"j./J! B. D. T. El. 16 3' -:-1 ,. I PIIC I 24 ,. 4"') 8 0 Q E,l 7&sect;D'-G"" wPAP A~OU NO Al?[,' UllRGlNCT SIITCH G[U AOOI G.;u E*EIH;[HCl SI I TCH S U.A ADDI C2D I. FDA lEGUW S EE DR ,'IING A-U~79D. SHT. I. 2. I QR I( THI S ORU IHC 11TH C-205791.
SHTS.
Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-29-5-34 1-4A-W /1-SA-S 36" REACTOR BUILDING ZONE I SUPPLY TO UNIT 1 PRIMARY CONTAINMENT DRYWELL AND SUPPRESSION POOL PURGE SUPPLY As shown on Shts. 7, 7A, 78 and 7C of Drawing C-205791, the duct assembly penetrates the fire barrier floor at Elevation 749'-r'. This penetration joins Fire Zone 1-4A-W with Fire Zone 1-5A-S. Both Fire Zone 1-4A-W and Fire Zone 1-5A-S have full sprinkfer protection.
Additionally, there are no openings in this duct run with both ends having normally closed dampers. JUSTIFICATION:
a) Fire initiated in Fire Zone 1-4A-W with potential to spread to Fire Zone 1-4A-S. There are no openings rn the duct assembly rn either fire zone and heat generated by a fire in Fire Zone 1-4A-W would be mitigated by the automatic suppression system in Fire Zone 1-4A-W. Therefore, a fire initiated in Fire Zone 1-4A-W would not generate enough heat to adversely impact any system in Fire Zone 1-5A-S. b) Frre initiated in Fire Zone 1*5A-S with potential to spread to Fire Zone 1-4A-W. There are no openings in the duct assembly in either fire zone and heat generated by a fire in Fire Zone 1-SA-S would be mitigated by the automatic suppression system in Fire Zone 1-SA-S. Therefore, a fire initiated by Fire Zone 1-5A-S would not generate enough heat to adversely impact any system in Fire Zone 1-4A-W. CONCLUSION:
Based on the above discussion.
NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within the fire zones, a fire damper is not required in penetration x .. 2 .. 5 .. 34, FP.RR Rev. 11 DR12-11 I :I Al 8 C 0 E 1 [_.......--="" N C RD l!E rAIR RODI Q3D 2 tR DHY ORA ULIC SYSTEI ARU O~*':U 8.0. T. El. H0'-4" lKJC (2"' X 6") 3 B.0.T. EL. 737'-0"IIOC
!H"t 6"l b q /' 8.0. T. El. 7Jl ._ ... UIC 117"'J 6"l 8.0.D. El. HD'-1 ** B.D.1. EL. HI. _ _." IPJC {~4 .. X ,4") 8.0.l. E l. 137'-D"III.JC (2rx Ii") ' 1-PU)I !" H. 719'-1" 5 PRII.IIT tONTA I NIENT 74 1 '-4" \Pit C H"l 4".\ ON. T O U. 71 1 "-.C" _zJ HH i\llDUNO AREA G:&sect;) El[RG(MC1 SI I T C tl 6U R RODI Gu 6 I 7 ~~"-0t.m1M11 .. 11.,.11, .. ..... l*T...<< """""' KEY F\M 1~1~.1..-:.~.1=-::.
1~~1 .. L....L___L_.,._,, =* no*o* -* *-* ..... --..w.o.. ~*_[:::: M OT E: I. F O R L E GEND SH Olli. A-ZD~HO, SH T. I. 2. IDAl THIS 01&. 1 1TH C-2 0:ilDI, S H TS. 7A, l B , JC. SUS QU E H ANNA S.E.S. UNIT I AP P E N DIX "R" DEVIA T ION R EQUEST N O. I? PENETRATIO N X-2 9-5-3~ AREA 29 !E L[V .719'-l')SCALE N~ PENNSYLVANIA POM[A & LIGMT CO MPANY ALLENTD'-'N PA. ~c:*~*205791 I 7 .. ~C-:_i696 SH. 7 
..--I Al ! B C D E 1 I z::_::...=-
N :27.$ 2 k 3 e.o. T. n. 112*-o" i nc n..-x , .. 1 e.o.t. n. 110'-&"E IPl <2*"1 , .. > B.0. T. EL. 7H'-2" (Ill (2-t" l 8'") 1.0. T. El. " 161'-0" IPlC (24" I 4") B.0.1. El. JU'-1" 11'' (!I'' I I") 8.0.1. H. 764'-l"EIU (21" 1 I") 11.0.T. H. JJ.t'-D"IHC (24'"1 4'") 1.0.1. H. 772'-l"Clf'I'.
CU" J 4") 1.0.T. EL. 771'-2" l1U. (24 .. l G") HANO-BT LIOUIO COMlllDl Jll(A PLAN i' H. 1 49'-1" ll EL. li3' -0'~ (40""1 ZI .. ) 11.D , 0. E L. 7&9'-0" (O" X 2 1'') t 5 NIIART CONlAIKIENT 6 ... *A-.6 .*l' ** &#xa5; .. PUETUflDN
.... .~ ... ~..... ; ... G 7 Hi]~"** 0...1.f'l t<I{ .... , ui , ... ..... I N Hltl ........ iJ NOTE: I. FOR LE~NO SU Dt;. A-20~790, SH T. 1. 2. IORl lH I S D". 111H t-1 D519J, SH TS. J, 1 8 l J C. S U S Q U E H A NNA S.E.S. U N IT I /\PP E ND I X "R" D EV!A T!O N R EQU ES T N O. 1 2 PE NETR A TI ON X-29-5-3 4 AR E A 2 9 E L EV .7'9'-l"ISC A LE N A FENNS't\. VAN IR POUCFt l LIG H T CO MP ANY ALLC J HOMN PA. "" c'.'.: '2 05 79 1 I 7A .. "c*~i 696 SH . 7 A I f A B C D e: l 2 FL , El. 70'-1" 8.0.T. El. 14 0'-t"ll'ilC (6" l 24") 4(*f~. **~,:. El. 129'-9" FL. EL. 719'-I .* 41 6"..f, .*. 36 D ll. 3 I ,l, Q I 5 -I 6 7 24" O il. S ECTION " 78-78" lli"OIA. 8.0.T. ll. 7 41'-t" IP J C (4"1 7'") a.0.1. H. m*-o" ,m c&" t w*i I PJC (4"1 24") DOIN TO EL. 731'-4'' t<1.i. ..... , ......... !\* UAP UOU N D .UU 8~:: 691.!I L.11 1"8 -* *-* -* .. _ -ICEY PUH = ,~i:.1~.1~.1~~1s.,~. * .!!!:.2! -l..'.r ,,,.,.-1 ,.,*:* I I .. *1"'...:m-::oa.:
,* r.-T 11**a* _;::f: m*rJ~ .. ;-N O TE: 1. FD R Lfli[N O S EE D lli. A-20 S l 90 , S H 1. I 2. , O R'-T HIS 0'6. 11T H C-2 0 57 9 1, S IIT S. 7 , 1 A , 1 C. S US QU E H AN N A S.E.S. U N IT I I\PP E N O IX " R" DEVI I\TJ O N REQU E ST NO. 1 2 P ENE T R ATI ON X-2 9.-5-3 4 A R E A 1 9 jE L E V .119'-l'j SCALE NA P[NNSYLVANIA POU E R .t. LIGHT COMP~NY ALL[N TOI.IN PA. "'c.:'205 7 9 1 1 7 B .. ~c":.i595 SH. 78 
.. ---A B -!' C D E 2 FL. H. 779*-1" ~*~/:~ e.o. T. El. 77-4'-D" IP .. C {4" l 24") .EI.O.T. EL. 717'-I'.' El Pit (-4" X 24") B.D.D. ll. 769*-o** (211"140" B. 0 .1. EL. 1&1 '-0" I PK C (-4" 1 24") B.D.T. El. 76!)-8'' flH ("'I 2-4") B.0.1. ll. 7U'-2" [IU. (6" I U") 3 8.0.D. El. 76J'-u** 128 .. 1 40** -~.:~i'A", SUN D-B Y llD UID CONTP.Ol *RU FL El. 1'9'-1" q I S 6 7 36"01l. SECTION *1c-1c-.. *..... A. ,* ,.,,; r.;i~i:',.:': a ... , u:..~ @IN l"I "I" I.: T I' ~" l H t:,':'.:;.
;.;:];!~:, EJ11 .. 1.,:: 11 .. ..: n PlllH :,;:;;-,;., ;;;;;..,, , ,,.,. 1 **;.7.""r.;
.;,~-;:, .._ _ _,_ _ _,:.=.:....:..Jl&.D,I.
: u. . .,.,.w A1~ "''~'*'t I"'-* u.l :~tt~:~: **-... : -?!t:.!.:..J
,*J" l!"J!,;.*.I V..:.._ -* f~--*~~~~ill N OTE: 1 F OR l E GUO S H D IC. A-20579 0 , S Hl. I. 2. I D flP. T HI S Olli. JllH C-20579 1 , SH 1S. 7 , 7A , lB .a.o.T. IL. 7 72'-0" ll'l C (C-l 24") B.O.T. H 110'-I" EIP K (-4" l 24") *e.o. T. ll. 7 69'-2" uo. (&" 1 1r l PEHlTRlT I ON ROD I CBD S U SQUEHANNA S.E.S. UNIT I A PPENDIX "R" D EVIATIO N REQUEST NO. 1 2 PENETRATION X-29-5-34 A RE A 29 j ELEV ]4 9'-1" [ SCALE N A PENHSYI..YA NJA PO~ER & 1..JGMT CO M PANY AL.LCN10t.lN PA ,. "'c*.::*205791 1~1*c .. "c":._i696 SH . 7C Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SIZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-FPRR X-29-5-54 1-4A-W/1-5A-S 22" X 22" REACTOR BUlLDING EMERGENCY SWITCHGEAR ROOMS COOLING UNIT SUPPLY As shown on Shts. 8, 8A and 88 of Drawing C-205791, the duct assembly penetrates the fire barrier floor at Erevation 749'-1 11* This penetration joins Fire Zone 1-4A-W with Fire Zone 1-SA-S. Both Fire Zone 1-4A-W and Fire Zone 1-5A-S have full sprinkler protection.
JUSTIFICATfON:
a) Fire initiated in Fire Zone 1-4A-W with potential to spread to Fire Zone 1-SA-S. There are no openings in the duct assembly in either Fire Zone 1-4A-W or Fire Zone 1-SA-S. A fire in Fire Zone 1-4A-W would be mitigated by the automatic suppression system in Fire Zone 1-4A-W and therefore, a fire initiated in Fire Zone 1-4A-W would not generate enough heat to adversely impact any system in Fi re Zone 1-SA-S. b) Fire initiated in Fire Zone 1-5A-S with potential to spread to Fire Zone 1-4A-W. There are no openings in the duct assembly in either Fire Zone 1-SA-S or Fire Zone 1-4A-W. A fire in Fire Zone 1-SA-S would be mitigated by the automatic suppression system in Fire Zone 1-SA-S and therefore, a fire initiated in Fire Zone 1-SA-S would not generate enough heat to adversely impact any system in Fire Zone 1-4A-W. CONCLUSION:
Based on the above discussion, NFPA 90A Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within the fire zones, a fire damper is not required in penetration X-29-5-54.
FPRR Rev. 11 DR12-12 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
A B C D E 2 ~N I (D I 3 q I --I-SHNOBY LIQUID CO NTROL AREA B.D.0. H i t INSTRUl[Mr IIEPAIR RODI C0_D J OAD CEN TER RODI a(~.~ .. /~2..1: 0*-o** Ci.:!i' J PLAM@El. 70'-t" FPll-l fil21 "':~,,~,,,,,,,,nolf'"''l"'~'l
!GI I J I jG\ I I I 'f' !G I l~TTl OE CIM~L ---* LQC~_TI J)rJ_cooe:s
__ 5 6 ~~,, .. -*" ~=-.. -,-........ ..,. PI.M n.t1:11 "--11* *~ -...,,...,._
D 1 iiii c-,,oJ,. -CD<f911.
u, a.Clll ,& ....... &a.a..~""'-~
........ -~*'"* -*o* -* * -* * .,. ............. -** .. .,. .. . --*** -**-rl"I' * ,.... -~--,.... . . , .... ,._,. -.~; .* ---=* . fl'!I** ,.. * ' ....... . -" ,,, .. .,.,. ... . M -* --** --*-* NOTES; I F OR l (GEND .S H O UI IN& .t.-20)7 9 0, S ll EET I. 2. I OR J; T H IS D RU I NG 1 11 H C-2037 9 1, S H UTS I & 18. SUS QU EHRNN A S.E.S. U N IT I APPEND IX "R" DE V !AT! ON R EQUE ST NO. 1 2 PENETRATION X-29-5-54 AREA 29 jELEV 1'9'-1" !SC A L E NA P[NNSYL\l'ANlA POWER l LIGHT COMPANY RLL[MTOMN PA. ~c.:*2os79 1 1 s A .. "*c:i(;95 SH . S A Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Text Rev. 11 PENETRATION:
ADJACENT FIRE ZONES: DUCT SJZE AT PENETRATION:
VENTILATION SYSTEM: DISCUSSION:
SSES-.FPRR X-34-5-4 2-4A-S/2-5A-W 40" X 28" REACTOR BUILDING HVAC ZONE ll SUPPLY TO UNIT II PRIMARY CONTAINMENT DRYWELL AND SUPPRESSION POOL PURGE SUPPLY As shown on Shts. 9, 9A and 98 of Drawing C-205791 1 the duct assembly penetrates the fire barrier floor/ceiling at Elevation 749'-1". This penetration joins Fire Zone 2-4A-S with Fire Zone 2-5A-W. Both Fire Zone 2-4A-S and Fire Zone 2-SA-W have automatic suppression system protection in the vicinity of the subject penetration.
Additionally, there are no openings in this duct run wrth both ends having normally closed dampers. JUSTIFICATION:
a) Fire irtitiated in Fire Zone 2-4A-S with potential to spread to Fire Zone 2*5A .. w. The combustibles located near the duct assembly in Fire Zone 2-4A-S are two cable trays. A ftre in Fire Zone 2-4A-S wou!d be mitigated by the automatic suppression system in Fire Zone 2-4A-S. Therefore, a fire initiated in Fire Zone 2-4A-S would not generate enough heat to adversely impact any system in Fire Zone 2-5A-W. b) Fire initiated in Fire Zone 2-5A-W with potential to spread to Fire Zone 2-4A-S. Fire Zone 2-5A-W is protected by an automatic fire suppression system which would mitigate the consequences of any heat generated in Fire Zone 2-5A-W as a result of a fire in Fire Zone 2-SA-W. Therefore, a fire initiated in Fire Zone 2-SA-W would not generate enough heat to adversely impact any system in Fire Zone 2-4A-S. CONCLUSION:
Based on the above discussion, NFPA 90A, Section 3-3.2.1.1, the physical layout of the adjacent fire zones and the combustible configuration within the fire zones. a fire damper is not required in penetration X-34-5-4.
FPRR Rev. 11 DR12-13 I I
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Security-Related Information Figure Withheld Under 10 CFR 2.390
 
SSES-FPRR Table Rev. 11 TABLE DR12*1 Fire Zone/ Zone Zone W~hout Drawing C-205791 Fire Area Penetration Duct Size Sprinklered Duct Opening Reference R*1A to R*1B: 1-5A-S/1-6A X-27-6-17 27" Dia. 1-5A-S Both Shts. 1. 1A & 18 1-5A-S/1-6A X-27-6-18 32" Dia. 1-5A-S Both Shts. 2, 2A & 28 1-5A-S/1-6A X-27-6-50 30" X 20" 1-SA*S 1-SA-S Shts. 3 , 3A & 38 1-SA -S/1-6A X-27-6-51 30" X 20" 1-5A-S 1-SA-S Shts. 4, 4A & 40 1-5A-S/1-6A X-26-6-83 20" X 8' 1-SA-S Both Shts. 5, SA & 56 1-4A-W/1 -5A-W X-28-5-66 22*-x 22* Both Both Shts. 6, 6A & 68 1-4A-W/1 *SA-S X-29-5-34
.36" Dia. Both Both Shts. 7, 7A & 7B & 7C 1-4A-W/1-5A-S X-29-5-34 22" X 22" Both Both Shts. 8, BA & 88 R-2A to R-2B: 2-4A-S/2-5A-W X-34-5-4 40" X 28" Both Both Shts. 9 , 9A & 98 FPRR Rev. 11 Page 1 of 1 SSES-FPRR Text Rev. 11 APPENDIX R DEVIATION REQUEST NO. 13 ESSENTIAL REDUNDANT RACEWAY PROTECTION DEVIATION REQUEST: a) Protection of redundant safe shutdown cables in a fire zone may be accomplished through the use of one or a combination of methods identified in 10CFR50, Appendix R, Section fli:G.2a, b, and c. b) The safe shutdown cables required to ensure availability of a safe shutdown path in a particular fire zone need only be protected within that fire zone. The criteria for fire spread is documented in Deviation Request Nos. 4 and 7). c) All raceways are protected by the use of a 1-hour fire rated barrier where automatic suppression/detection exists or by the use of a 3-hour fire rated barrier where automatic suppression/detection does not exist (See attached Drawing 8-213424).
FIRE AREAS/ZONES AFFECTED:
This deviation request applies to all fire areas in the Unit 1 and Unit 2 Reactor Buildings.
REASON FOR DEVIATION REQUEST: 1 OCFRSO Appendix R Section 111.G.2 requires that where cables or equipment of redundant trains of systems necessary to achieve safe shutdown are located within the same fire area, one of 3 means (111.G.2.a,b,c) of ensuring that one of the redundant trains is free of fire damage shall be provided.
When using the methods of Sections IIJ.G.2.b or c for raceway protection, it is required that the fire detection and an automatic fire suppression system be installed in (throughout) the fire area. Although* we have fire detection, where appropriate, throughout the fire areas, we do not have an automatic fire suppression system installed completely throughout the fire areas. Based on the fire spread limitation criteria outlined in Deviation Request No. 7 and the wraparou*nd area concept in Deviation Request No. 4, protection of the essential redundant train throughout an entire fire area is not warranted.
In addition, certain fire zones have only partial automatic suppression coverage within the fire zone. EXISTING CONDITIONS:
The 3-hour fire barrier method (111.G.2.a) and the 1-hour fire barrier with automatic fire suppression/detection method (111.G.2.c) are used to protect essential redundant raceways at Susquehanna SES. The choice of methods depends on the availability of automatic fire suppression/detection.
There are two specific types of exceptions to this general criteria.
In one case, Fire Hazards Analyses have been used to justify the use of 1-hour rated fire barriers to protect FPRR Rev. 11 DR13-1 SSES-FPRR Text Rev. 11 redundant safe shutdown raceway even though there are no sprinklers installed in the area. For these cases, a 10 CFR 50.59 Safety Evaluation has been used to demonstrate*
that the condition does not adversely affect the ability to achieve and maintain safe shutdown.
This satisfies the SSES Licensing Condition for changes to the approved Fire Protection Prograrry.
The areas listed below are the Fire Zones where this approach has been used. *
* Fire Zone FHA Reference Safety Evaluation No. 1-5B EC-013-1834 98-3014C 1-6{ EC-013-1081 98-30140 2-SA-N EC-013-1823 98-3013C 2-SC EC-013-1082 98-3013C 2-6A EC-013-1824 98-3013C In the other case, specific deviation requests have been submitted to and approved by the NRC allowing the use of 1-hour fire rated barriers on redundant safe shutdown raceway. Deviation Request Nos. 8 and 15 fall into this category.
The wraparound areas at Susquehanna SES contain both divisions of redundant safe shutdown raceways and both divisions of these raceways are protected within the wraparound areas (see Deviation Request No. 4). The wraparound area provides a spatial separation between fire areas and the protection of both redundant safe shutdown raceway divisions within the wraparound area assures the availability of a safe shutdown path based on the limitation of fire spread across the wraparound area. The fire spread limitation criteria (see Deviation Request No. 7) states that a fire will only propagate to the next adjacent fire zone. Therefore.
different safe shutdown paths could be protected in fire zones remote from each other. JUSTIFICATION:
The purpose of Appendix R, Section 111.G.2, is to assure that one train of safe shutdown raceway and its associated circuits are free of fire damage so that they remain availab1e for safe shutdown of the plant. The method of protection for these essential redundant raceways outlined in this deviation request is different than that required by Appendix R, Section 111.G.2. but accomplishes the same purpose and intent of Section tu.G.2. Due to the large configurations of some of the Reactor Building fire areas and the fire spread limitation criteria presented in Deviation Request No. 7, the installation of an automatic suppression system throughout the fire areas would not significantly enhance the safety of the plant. Moreover, where an automatic suppression system does not exist. essential redundant raceway are protected by a 3-hour fire rated barrier. The exc~ptions to this itemized above have been justified on an individual basis separately.
FPRR Rev. 11 DR13-2 SSES-FPRR TextHev. 11 .In fire zones where automatic suppression is not complete throughout the entire fire zone, both one-hour and three-hour raceway protection (wrapping) is used. There are four fire zones at Susquehanna which have partial automatic suppression coverage within the fire zone. These four zones are listed below along with the conservatively developed.
in-situ combustible loading as determined from the Combustible Loading Analysis.
_ Fire Zone In-situ Combustible Loading 1-3B-N 40.4 minutes 1-4A-N 22.9 minutes 2-3B-N 55.5 minutes 2-4A-S 25.9 minutes Actual in-situ combustible loading durations are provided to document existing ment and justify the deviation request. These values are based on the initial combustible loading analysis.
Modifications subsequent to this analysis have revised these values with the possibility of future modifications revising them again. The governing criteria for the combustible loading analysis is that the fire area resistance rating exceed the combustible.
loading duration.
The combustible*
loading durations specified in the deviation request will not be updated in the future since program commitments require that all modifications be evaluated to assure that additional combustibles are controlled to remain below the fire area fire resistance rating. In all cases, the conservative maximum combustible loading for each ofthese fire zones is less than 60 minutes. This is the tested acceptance level for the 1-hour wrapping used at Susquehanna.
Additionally, wherever the 1-hour wrapping is being used, automatic suppression protection exists to mitigate the heat effect that a postulated fire would have on the wrapped raceway. Inspection of the boundary areas for each of these partially protected fire zones reveals that there are no significant fire hazards on either side of this boundary for a minimum distance of approximately 20 ft. (See attached Drawing B-213424).
Therefore, we are assured that adequate protection exists for the given combustible configuration in each of these boundary areas. Based on the criteria and justifications presented in this deviation request and in Deviation Requests No. 4 and No. 7 t we are assured that one of the redundant trains of a required safe shutdown system is free from fire damage. FPRR Rev. 11 DR13-3 I, ' . J I I/ . t A B C :ii 0 1 '2D~O" NO SIC;iNIF \C>,>JT f1~~ !1A.?.ARDS AIJiCMATIC:
StrPP~ESS l oN AUTOMATIC DETrCTION T 2 '20~0" No 51(~1JIFIC:A>JT i:1~1; KAc.AC2.0S AuTOMA.TIC DETl:CT10N fZZZ//JY~ . I CA~l..'c 1~.A."( * ,
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'o"-1, 3 " L. =~ E ,JC Will-l \-\It. WR.A.P *@i -:i H~. W li:P..P S U SQUEHA N NA *S.E.S. UN I Ttl~2 AP P. R-DEVIATIO N REQ.'13 ESSENT I AL RED U NDANT R A C EWAY PROTECTION ARE A -!ELEV. -!S CA LE -PENNSYl VANIA POIIER & LIGHT COMPANY . ' 'ALLENTOWN PA. f'P,IL D"f'W(NO NO. S H UT ND, !REV , ND, B213424 1'1&#xa3; Dl:11.NUt; HO~ C-1 8 36 I 0 SSES-FPRR Text Rev. 11 APPENDIX R DEVIATrON REQUEST NO. 14 REACTOR BUILDING FIRE ZONES WITHOUT FIRE DETECTION DEVIATION REQUEST: Fire detection need not be provided in fire zones which do not contain safe shutdown raceway or do not represent an exposure hazard to safe shutdown equipment even if a fire zone within the same area contains redundant safe shutdown raceway. The provision of automatic sprinkler protection in lieu of fire detection is acceptable in Fire Zones 1-2C and 2-2C. FIRE ARENZONES AFFECTED:
This deviation applies to Unit 1 and Unit 2 Reactor Buildings, Fire Area: R-1 A, R-1 B, R-2A and R-2B. REASON FOR DEVIATION REQUEST: 10CFR50, Appendix R, Section 111.G.2 require fire detection.
The NRC guidance indicates fire detection should be provided throughout a fire area. Fire detection has not been provided in the Reactor Building fire zones listed below under Existing Arrangement.
EXISTING ARRANGEMENT:
The following fire zones do not have fire detection:
Fire Area Fire Zones Reason A*1A 1-2C Railroad Afrlock/Access Shaft -No detection -Automatic sprinklers provided 1-4E CRD Rebuild Room -No reQuired sate shutdown cables -very low combustEb/e loadinQ 0-6H Cask Storage Pft -Filled with water. HB Recirculation Fan Room -No required safe shutdown cables . -very low combusttble toading 1-6F Spent Fuel Pool -Rited with water. R-18 1*1J Stairwe!~no safe shutdown raceway or combustibles 1-6F Spen1 Fuel Pool -Filled with water. 1*5C Reactor Backwash Receiving Tank Room -No required safe shutdown cables -Very low combustible loadtng 0*6H Cask StoraQe Pit -Filled with water. A-2A 2*2C Same as 1-2C 2-4E Same as t-4E 2*6F Same as 1-6F R-2B 2*1J Same as 1-1J 2*6F Same as 1-6F FPRR Rev. 12 DR14-1 SSES-FPRR Text Rev .. 11 JUSTIFICATION:
Fire Zones 1-2C and 2-2C have been provided with automatic sprinkler protection.
Detection of a fire ts provided via the sprinkler flow alarm when heat activates a sprinkler head. The remainder of the fire zones listed above do not contain required safe shutdown cables or equipment.
None of the zones listed above represent a frre hazard which impacts on adjacent fire zones. The NRC requested additional detection for Fire Zones 1*78 and 1-6F in FSAR Question 281.17. Our response to the staff and our Fire Protection Review Report both indicated that additionat smoke detection would be provided in zones which contain or present a fire exposure hazard to safe shutdown equipment.
The fire zones delineated in this request do not present an exposure fire hazard to safe shutdown equipment.
FPRR Rev. 12 DR14-2 SSES-FPRR Text Rev. 11 APPENDIX R DEVIATION REQUEST NO. 15 FIRE AREAS CONTROL STRUCTURE WITHOUT FIRE SUPPRESSION DEVtATION REQUEST: Automatic fire suppression is not required for the protection of 1-hour wrapped redundant safe shutdown raceway in Frre Areas CS-11 and CS-20. FIRE AREAS/ZONES AFFECTED:
This deviation applies to Fire Areas CS-11 (Fire Zone 0-28A-1) and CS-20 (Fire Zone 0-28A-II).
REASON FOR DEVIATION REQUEST: The requirements of 10CFR50t Appendix R Section Ill G.2.C require fire suppression if a one-hour fire rated barrier for cables and equipment is provided.
Fire Areas CS-11 and CS-20 are not provided with automatic fire suppression.
Fire Hazard Analysis EC-013-1846 evaluated the specific deviations from tested configurations to assure that their capability is ~n excess of that required by the specific fire hazards in the vicinity of the deviation.
EXISTING CONDITIONS:
Fire Areas CS-11 and CS-20 contain safe shutdown cables enclosed in conduits which are protected by a one-hour fire barrier. In addition, Fire Area CS-20 contains two 125V DC distribution panels (2D624 and 2D644) which are enclosed with a one-hour protective fire barrier. The combustible loading for these fire zones is low. Manual suppression equipment and ionization detectors are provided in these fire zones. All cables are in conduits or panels. No cable trays which could add to the combustible loading are located in either fire area. Actual in-situ combu~tible loading durations are provided to document existing arrangement and justify the deviation request. These values are based on the initial combustible loading analysis.
ModificaUons subsequent to this analysis have revised these values with the possibility of future modifications revising them again. The governing criteria for the combustible loading analysis is that the fire area fire resistance rated exceed the combustible loading duration.
The combustible loading durations specified in the deviation request will not be updated in the future since program commitments require that all modifications be evaluated to assure that additional combustibles are controlled to remain below the fire area fire resistance rating. FPRR Rev. 11 DR15*1 SSES-FPRR Text Rev. 11 JUSTIFICATION:
Fire Areas CS-11 and CS-20 are identical in function and hazard to Fire Zones 0-28B-1 and 0-288-H which were the subject of a request for variance (See Deviation Request No. 8). The combustible loadings may change over plant life. This Deviation Request will remain valid so long as: a) The calculated maximum average combustible loading does not exceed 45 minutes. b) The in-situ combustibles remain evenly dispersed.
FPRR Rev. 11 -DR15-2 SSES-FPRR
* DEVIATION REQUEST NO. 16 HAS BEEN WITHDRAWN
*
* Rev. 10 DR16-1 G:\Lic Docs\FPRR Approved\Oevlatlons\fpd_0700_
16.doc SSES-FPRR Text Rev. 11 DEVIATION REQUEST NO. 17 HAS BEEN WITHDRAWN FPRR Rev. 11 DR17-1 SSES-FPRR
* THtS PAGE INTENTIONALLY LEFT BLANK * ** Rav. 10 DA18-1 G:\Uc Docs\FPRR Approved\Deviations\fpcl_0700_
18.doc SSES-FPRR Text Rev. 11 APPENDIX R DEVIATION REQUEST NO. 19 INCOMPLETE AUTOMATIC SUPPRESSION IN DIESEL GENERATOR FIRE AREA D-1 DEVIATION REQUEST: Existing fire protection in Fire Area D-1 t consisting of automatic suppression and detection in the basement (Elevation 660'-0'')
and ground floor (Elevation 677'-0") and fire detection only on the top floor (Elevation 710'-9 11), is adequate to protect 1-hour fire barriers installed on required safe shutdown raceway located within the fire area. Specifically, no automatic suppression is required for the top floor (Elevation 710'-9").
FIRE AREAS/ZONES AFFECTED:
This deviation covers Diesel Generator Fire Area D-1 (Fire Zone 0-41A). This is the A Diesel Generator Building and is the only Diesel Generator Fire Area that has required safe shutdown raceway protected with a 1-hour fire barrier. REASONS FOR DEVIATtON REQUEST: 1 OCFR50, Appendix R Sections 111.G.2.c requires that fire detection and automatic suppression be installed in the fire area when required safe shutdown raceway are protected with a 1-hour fire barrier within the fire area. NRC guidance indicates fire detection and automatic suppression should be provided throughout the fire area. Contrary to thisf the Diesel Generator A Building does*not satisfy this requirement.
The Diesel Generator A Building, Fire Area D-1, does not have automatic suppression on Elevation 710'-9 11* EXISTING ARRANGEMENT: . Fire Area D-1 contains redundant safe shutdown raceway protected with a 1-hour fire barrier on Elevation 660'.0". Automatic suppression and fire detection is provided for the basement (Elevation 660'-0") and the ground floor (Elevation 677'-0 11) of this fire area. The top floor of this fire area (Elevation 710'-9 11) is provided with fire detection (alarm only) but is not provided with automatic suppression.
JUSTIFICATION:
The top floor*(Elevation 710'-9 .. ) of this fire area contains fan equipment, safety related electrical panels for substituting Diesel Generator E for Diesel Generator A and a safety related HVAC panel. The SSES Appendix R Safe Shutdown Analysis demonstrates that the loss of this equipment, due to a fire in this fire area, will not affect the ability to achieve and maintain safe shutdown.
Additionally, Elevation 710'-9" of the Diesel Generator A Building has minimaJ combustibles and has installed fire detection.
This installed fire FPRR Rev. 11 DR19-1 SSES-FPRR Text Rev. 11 detection will assure identification of a fire and insure timely response by the plant fire brigade. Due to the limited amount of in-situ combustibles on Elevation 710'-9 11 , the manual fire fighting effort will more then compensate for the lack of automatic suppression on this elevation.
Consequently.
the lack of automatic suppression on this elevation does not present a hazard to required safe shutdown raceway protected with a-1-hourfire barrier located on elevation 660'-0" of the A Diesel Generator Build_ing where fire detection and automatic suppression is inst~lled.
CONCLUSION The existing fire protec_tion features provided on Elevation 710'-9 11 of the A Diesel Generator Building, Fire Area D-1, provide a level of fire protection equivalent to that required by 10CFR50 Appendix R Section 111.G.2.c.
This conclusion is based on the lack of effect on post fire safe shutdown capabilities, minimaJ combustibles, ~nd existing fire detection as described above. FPRR Rev. 11 DR19-2 .... ***-* .. ****---... **-* .. *----------------------**--***--*----*
-*-* --...... 
* *
* I SSES-FPAR APPENDIX R DEVIATION REQUEST NO. 20 PENETRATION SEALS -CONDUITS DEVIATION REQUEST: It is acceptable to seal new and existing conduits at Susquehanna SES which penetrate fire rated barriers by installing a non-combustible seal internal to the conduit in order to contain the products of combustion within the fire area of fire origin. FIRE AREAS/ZONES AFFECTED:
The requirements for sealing penetrations through fire rated barriers are contained in a specification and are applied throughout the facility.
Therefore, this deviation request applies to all fire area boundaries.
* REASON FOR DEVIATION REQUEST: The requirements of 1 OCFR50, Appendix R, Section lil.G.2 require fire areas to have rated fire boundaries.
In NRC Generic Letter 95 .. 10, Section 8.8, the NRC indicated guidelines tor sealing conduits as they passed through fire rated boundaries.
The conduits passing through fire rated barriers at Susquehanna SES are protected in an equivalent manner . The purpose of this deviation request is to document that equivalency.
EXISTING ARRANGEMENT:
The specification criteria along with an in .. plant inspection of all conduits which penetrate fire rated barriers assures that the conduits are seated internally with a non-combustible material to contain the products of combustion within the fire area of fire origin and maintain the integrity of the fire area boundary.
JUSTIFICATION:
In accordance with NRC Generic Letter 86-10, the term fire area as used in Appendix A means an area sufficiently bounded to withstand the hazards ~ssociated with the fire area and, as necessary, to protect important equipment within the fire area from a fire outside the area. The installation of a non*combustible seal internal to.conduits penetrating tire area boundaries accomplishes the above purpose. Typically, these seals consist of a ceramic fiber damming material topped with either silicone foam or a fire retardant putty installed at the first availab,e access point on one side of the fire barrier. See attached drawing B-213419 for examples of some typical installations . Rev. 10 DR20-1 G:\Uc Docs\FPRR Approved\Deviations\fpd_0700_20.doc 
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DE:TAlLS 0 lGJile,101, I *.":-* ..:a. *SUSQUEHANNA S.E.S. UNIT* l 2 APPENDIX R-OE V I ATION , REQUEsrtzo CONDUIT SEALING DETAILS f\REf\ -IELEV. -!S C ALE -PENNSYLVANIA POWER & LIGMT COMPANY ALLENTOWN PA. fPIL DRA*ING HO. I H!E f NC. IRl>, HO, 6213419 I I *E Clt*MtND NC, C-1833 -* j *-**-----
SSES-FPRR
* APPENDIX R DEVIATION REQUEST NO. 21 VOID *
* Rev. 10 DR21 ... 1 G:\Uc Docs\FPRR Approved\Deviations\tpd_0700_21.doc SSES-FPRR
* THIS PAGE INTENTlONALL Y LEFT BLANK *
* Rev. 10 G:\Uc Oocs\FPRR Approved\Deviations\tpd_0700_22.dOC 
* *
* SSES-FPRR APPENDIX R DEVIATION REQUEST NO. 23 CONTROL STRUCTURE FIRE AREA CS-9 PARTIAL FIRE SUPPRESSION DEVIATION REQUEST: Fire protection provided in Fire Area cs .. 9 is adequate to protect the* identified hazard. Spectfically, the fire area is constantly manned by operations personnel who-would detect and react to a fire, the area is provided with partial suppression, manual suppression is available, and the capability to achieve safe shutdown through alternative equipment is provided by the remote shutdown panel located outside the fire area. FIRE AREAS/ZONES AFFECTED:
This deviation applies to Fire Area CS-9. REASON FOR THE DEVIATION REQUEST: Dedicated shutdown capability in accordance with Appendix A, Section 111.G.3 has been provided for use in the event of a fire in the control room. The above was provided since separation of redundant trains of safe shutdown equipment within the control room does not satisfy the requirements of 10CFR50, Appendix Rt Section 111.G.2. Complete Fire suppression has not been provided throughout Fire Area CS*9. EXISTING CONDITIONS:
The following conditions exist in Fire Area CS-9: Zone Protection Safe Shutdown Equipment 0-26A None None 0-26E None None 0-26F Manual Spurt C(n under f Joor (Fixed Piping) Yes 0.26G . Manual Spurt C(h under floor {Fixed Piping) Yes Cr26H Manual Spurt C~ under floor (Fixed Piping) Yes 0-26t Manual Spurt CCh under floor (Fixed Pipino) Yes 0-26J Manual Spurt CCn under floor (Fixed Pipino} Yes 0-26K Automatic Sprinkler Protection Yes 0-26L Automatic Sprinkler Protection Yes 0-26M Manual Spurt C~ {Fixed Piping Yes 0-26N Manual Spurt CO2 (Fixed Piping Yes 0-26P Manual Spurt C&deg;' (Fixed Piping , Yes 0-26R Manual Spurt COz (Fixed Piping) Yes Rev. 10 DR23-1 G:\Lic Docs\FPRR Approved\Deviations\tpd_0700_23.doc SSES-FPRR The release of CO2 is controlled manually to minimize the effects of a CO 2 discharge on
* plant operation.
Manual control stations are provided both insrde and out~ide the fire area. Fire Zones with constant occupancy (0-26G, 0-26H, and 0-261) are provided with under floor protection only. Complete automatic sprinkler protection has been provided for Fire Zone 0*26K and 0-26L. Fire Zones 0-26F and 0-26J are vestibules and contain safety related cables below the raised floor. These cables are protected by manual spurt CO2. Portable extinguishers are avaHable for use in the fire area. A hose station is avaitabfe within the control structure for use in the fire area. JUSTIFlCATION:
It has been demonstrated during the performance of startup and test program that full shutdown is achievable without reliance on the Control Room. The existing protection provided in Fire Area CS-9 is adequate to protect the identified cable hazards. It is expected that since the control room is constantly manned by operations personnel, any fire woutd be detected and extinguished prior to activation of a suppression system. The addition of more suppression capability would not enhance, to a significant degree, the
* protection of safe shutdown functions.
* Rev. 10 G:\Lic Docs\FPRR Approve<ti0eviations\tpd_0700_23.doc
* SSES-FPRR APPENDIX R DEVIATION REQUEST NO. 24 AUTOMATIC FIRE SUPPRESSION IN RRE ZONE 2-SD DEVIATION REQUEST: The installation of an automatic fire suppression system in Fire Zone 2-5D in order to comply with Appendix R, Section 111.G.2.b would not significantly enhance the fire protection for that zone nor overaU ptant safety, and therefore is not required.
FIRE ZONE AFFECTED:
This deviation request applies only to Fire Zone 2*50, which is in Fire Area R-2A. REASON FOR DEVIATION:
1 OCFRSO, Appendix R, Section m .G.2.b requires the existence of an automatic fire suppression system, in addition to fire detectors, in those fire areas where separation of redundant safe shutdown cables and equipment is greater than 20 feet with no intervening combustibles.
Fire Zone 2 .. 50 contains cables for HV*E21-2F005A (Div. I) and power cables from 20613 and 20653A (Div. I) as well as Valve HV-G33-2F004 (Div. II).
* Redundant safe shutdown equipmenVcables in Fire Zone 2-5D are separated by a horizontal spatial distance of approximately 50 feet with negligible intervening combustibles.
No automatic fire suppression system exists in the fire zone. Fire Zone 2-50 is a fire zone in whtch relief from the automatic fire suppression system requirement of Appendix R, Section 111.G.2.b is sought.
* EXISTING ARRANGEMENT:
RWCU Outboard Isolation Valve HV-G33-2F004 is nonnally open during power operation and is required closed to isolate reactor coolant letdown to the RWCU System when perfonning plant shutdown for an Appendix A scenario.
ln the event valve HV-G33-2F004 is unavailable, the RWCU Inboard Isolation Valve HV-G33-2F001 may be called upon to close to isolate reactor coolant letdown~ Valve HV-G33-2F001 is located inside containment (Fire Zone 2-4F) and HV-G33*2F004 is located in Fire Zone 2-5D. For a fire in Fire Zone 2-50 (physical location of valve HV-G33-2F004), HV-G33-2F004 (Div. JI) and Its cables may be disabled.
The valve and its cables are located in the West comer of the fire zone (refer to Drawing C-1824). The cables travel West to Fire Zone 2-SC. No cables for Inboard Isolation Valve HV-G33-2F001 (Div. I) are located in
* Fire Zone 2 .. 50, Cables for Valve HV-G33*2F001 and its power supply wrapped in adjacent (i.e., communicating)
Fire Zones (2-4A-W and 2-SA-W} except for 2-4A-S for which 3-hour barrier upgrades are provided between zones. Refer to Figures C-1732, sh. 1, R 1, and C".' 1731 , sh. 1, R 1, for applicable fire zone layouts. Rev. 10 DR24-1 G:\Lic Docs\FPRR Approved\Oeviations\tpd.:..0100_24.doc SSES-FPRR The total in-s~u combustible loading in Fire Zone 2-5D is less than 10 minutes assuming* all combustibles are fully consumed.
The combustibles consist of a total of flve (5) gallons of lube oil (five separate one gallon locations) and cable in cable trays. Actual in-situ combustible loading durations are provided to document exis!ing arrangement and justify the deviation request. These values are based on the initial combustible loading analysis.
Modifications subsequent to this anatysis have revised these values with the possibility of future modtfications revising them again. The governing criteria for the combustible loading analysis is that the fire area fire resistance rating exceed the combustible loading duration.
The combustible loading durations specified in the deviation request wiU not be updated in the future since program commitments require that all modifications be evaluated to assure that additionat combustibles are controlled to remain below the fire area fire resistance rating. Division I cable trays E2PK, E2KK, 2PKB, _and 2KKB are located at the east end of Fire Zone 2-5D and are separated from Valve HV-G33-2F004 (Div. II) by a horizontal distance of about 49 feet at the closest point. The effect of combustible
*oil in the fire zone was evaluated with respect to Div. I cable trays. The five gallons total of rube oil in the f~re zone is composed from 1 gallon in each of the Cleanup System Recirculation Pumps (2P221 A and 8) and 1 gallon in each of three valves (HV-G33-2F042, HV-G33-2F044, and HV-G33-2F104-each are non-safe shutdown valves). The pumps are located in
* individual cubicles each equipped with a floor drain which contains any spilled lube oil
* within the pump cubicles.
The spatial separation between HV-G33-2F004 and the closest pump lube oil is approximately 17 feet and is separated by a pump cubicle wall. The pump cubicles are totally enclosed by concrete and/or masonry walls and communicate
* only with the valve HV-G33-2F004 area via a few penetrations in the labyrinth wall arrangement.
The three valves and hence the three gallons of lube oil, are separated from varve HV-G33-2F004 by approximately 35 feet of horizontal spatial separation.
Within the 35 feet between the valves exists two floor drains which woutd preclude a tube oil fire from affecting valve HV-G33-2F004.
The fube oil is the only intervening combustibJe between HV-G33-2F004 and the redundant safe shutdown equipment cables (refer to C-1824). The above-mentioned cable trays constitute the only other combustibles in Fire Zone 2-50. However, the large horizontal spatial separation of the cabfe trays from HV-G33 .. 2F004 and the intervening labyrinth wall arrangement make these combustibles inconsequential.
Fire Zone 2-50 is equipped with fire detection.
JUSTIFICATION:
A study perfonned, which included analyzing the combustibfe loading configuration of Fire Zone 2*50, determined that a fire occurring in Fire Zone 2-SD is highly improbable based on the negligible level of in-situ combustible loading. However, assuming a fire did start in
* Fire Zone 2-50, approximately 50 feet horizontal spatial separation exists between Rev. 10 DR24-2 G:\Uc Docs\FPRR Approved\Devlations\fpc:1_0700_24.doe 
* *
* redundant safe shutdown equipment/cables.
Currently, the only intervening combustibles are five gallons of lube oil which are protected for spillage by pump cubicles and floor drains such that any spilled lube oil will not contribute to the propagation of a fire. Additionally, the closest lube on to Valve HV-G33-2F004 is approximatety 17 feet separated by an intervening concrete/masonry wan, which provides substantial assurance that a fire will not disable redundant safe shutdown equipment/cables that are approximately 50 _feet apart. Based on the low probability of a fire in Fire Zone 2-50, and the insignificant consequences of a fire (due to the configuration of the room) if one were to start, the only possible concerns, therefore, are: 1) a fire may start due to the presence of transient combustibles, and 2) a fire may spread from an adjacent fire zone to Fire Zone 2-50 with the existence of transient combustibles as the fire propagation medium. Both of these concerns are alleviated by controlling the level of transient combustibles in Fire Zone 2-50 and by zone barrier upgrades to prevent such communication between zones where different shutdown paths are specified.
The introduction of transient combus1ibles into Fire Zone 2-50 would be limited due to infrequent access to the room since the fire zone is a high radiation area during normal operation.
Additionally.
NRC Generic Letter 86-1 O, Section 3.6.2 stipulates that transient combustibles need not be considered intervening combustibles.
The second concern is further addressed in the communicating fire zone discussions below . Fi(e Zone 2-50 has five adjacent fire zones as follows: 2-4A-S, 2-4A-W, 2-SA-S, 2-SA-W and 2-SC. Only Fire Zones 2-4A-S, 2-4A-W and 2-SA-W contain cables-for redundant isolati<;>n valve HV-G33-2F001 or its power supply (2A203). A study conducted concluded that a fire involving the worst case spatial separation would have to start in Fire Zone 2-4A-S (a fire zone with low in-situ combustibles) damaging cables for valve 2F001 or power source 2A203, traverse into Fire Zone 2-5D through the small penetration (3 inch diameter, X-34-5-71
), propagate 50 feet horizontally via negligible in-situ combustibles in Fire Zone 2--50, and damage cables for valve 2F004 or the valve itself. This scenario is highly improbable based on the large spatial separation and low amounts of combustible loading in both fire zones. Hence, operability of RWCU lnboarcflsolation Valve HV-G33-2F001 is assured for a fire in Fire Zone 2-50. For a fire in Fire Zone 2-4A-S, HV-G33-2F004 is assured operable.
Therefore, based on the existence of: 1) large spatial separation between redundant safe shutdown equipment, 2) fire detection, 3) minimal in-situ combustibles and 4) negligible intervening combustible loading in Fire Zone 2-SD, the-current configuration provides an equivalent degree of safety as that required by Section 111.G.2 of Appendix R. The installation of an automatic fire suppression system in Fire Zone 2-50 to meet the requirements of 1 OCFR50 Appendix R, Section UI.G.2 would not significantly augment the level of fire protection for that fire zone.
* Rev. 10 DR24-3 . G:\Uc Ooc:s\FPRR Approved\DeviationsVpd_0700_24.doc SSES-FPRR Future Appendix R compliance is assured by: 1) Wrapping safe shutdown raceways that are needed for a fire in Fire Zone 2-5D, 2) installing three-hour fire rated penetration seals for any future penetrations in the barrier separating Fire Zones 2-50 and 2-4A-S and 3) by controlling the level of transient combustibles in Fire Zone 2-50.
* Rev. 10 DR24-4 G:\Uc Docs\FPRR Approved\Deviations\fpd_
0700_24.doc
* *
* Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Security-Related Information Figure Withheld Under 10 CFR 2.390
* SSES-FPRR Text Rev. 11 APPENDIX R DEVIATION REQUEST NO. 25 SEPARATION OF REDUNDANT SAFE SHUTDOWN CAPABILITY rN FIRE ZONE 1-3A DEVIATION REQUEST: The current locatton of the Core Spray flow instruments and the automatic suppression and combustible loading configuration in Fire Zone 1-3A provides an equivalent degree of safety as that required by Appendix R, Section HI.G.2.b.
The affected components for CS include F1S-E21-1N006A, FT-E21-1N003A, F1S-E21-1N006B, FT-E21-1N003B and circuits tor these components.
FIRE ZONE AFFECTED:
This deviation request applies only to Fire Zone 1-3A (Unit 1 Reactor Building Elevation 683'), which is in Fire Area R-1 A. REASON FOR DEVIATION:
10 CFR 50, Appendix R Section flJ.G.2.b requires the existence of an automatic fire suppression system, in addftion to fire detectors, in those fire areas where separation of redundant safe shutdown cables and equipment is greater than 20 feet with no intervenrng combustibles.
The redundant Core Spray flow instruments in Fire Zone 1-3A (in Fire Area R-1 A) are separated by greater than 20 feet (approximately 45 feet) with automatic fire suppression and full detection in Fire Zone 1-3A. Fire Area R-1 A 1 however! does not have automatic fire suppression throughout.
In addition, there are a few intervening combustibles (e.g. raceway with Thermo-Lag fire barriers and cable trays) located between the redundant Core Spray flow instruments.
EXISTING ARRANGEMENT:
In Fire Zone 1-3A, Division II of safe shutdown equipment is assured availabte for plant shutdown.
Core Spray (CS) System flow instruments F1S-E21-1N006B and FT-E21-1 N0038 are located in Fire Zone 1-3A and are required to function in support of the Division II CS System. The Division U CS flow instruments are separated by approximately 45 feet from Division I CS flow instruments FlS-E21-1 N006A and E21-1 N003A, including instrument tubing for the respective instruments.
There are addrtional rnvision II circuits in this same area that also rely upon spatial separation equivalent to that required by Appendix R Section rl!.G.2.b.
Refer to Calculation EC-013-1837 for information on circuits in Cable Tray Sections F1KH15 and F1KL 15 in FPRR Rev. 11 DR25-1 
-SSES-FPRR Text Rev. 11 this portion of Fire Zone 1-3A that also rely on spatfal separation as a part of their qualification basis. Automatic fire suppression exists in all of Fire Zone 1-3A. The 45 feet separating the redundant CS flow instruments
[s also fully covered by detection (refer to attached Drawing C-1834 Sheets 1 and 2). Several cable trays with sheet metal covers (top and bottom) and some raceway with Thermo-Lag fire barriers traverse North-South in Fire Zone 1-3A between the redundant CS flow instruments.
The cables in the cable trays and the Thermo-Lag are the only source of combustibles located between the redundant CS flow instruments.
The unwrapped cable trays are entirely encfosed with sheet metal covers .top and bottom north of Column Line 26.5. This constitutes greater than 20 horizontal feet in which the enclosed raceways are protected by automatic fire suppression and detection systems. Additionally, the lowest cable tray has a vertical spatial separation of approximatety 13 feet from the CS trow instruments rocated below (refer to C-1834 Sheet 2). JUSTIFICATION:
To meet the requirements of 10 CFR 50, Appendix R, Section 111.G.2.b, the follow[ng features must exist to ensure that a fire is limited so that only one division of redundant components important to safe shutdown is affected:
: a. fire detection~
: b. automatic fire suppression, c. greater than 20 feet horizontal separation between redundant safe shutdown equipmenUcables, and d. no intervening combustibles.
Fire Detection:
In the local area where Section UI.G.2.b separation is sought, ionizing detectors 11-240, 11-255, 11-256, 11-309 and 11-310 provide the necessary fire detection to arert operators of the onset of a fire in the CS flow instrument tocation.
Hence, the level of fire detection in Fire Zone 1*3A meets the requirements of Section lll.G.2.b (refer to the attached Drawing C-1834 Sheet 1 for approximate fire detector locations).
Automatic Fire Suppression:
The automatic fire suppression system in Fire Zone 1-3A (Ftre Area R-1 A) provides suppression capability to suppress a fire. Fire Zone 1-3A has full automatic fire suppression, i.e. PA-131. Although Appendix R Section m.G.2.b requires automatic fire suppression throughout the fire area, the rnstallation of an area-wide automatic fire suppression system in Fire Area R-1A to meet the requirements of 10 CFR 50 Appendtx R Section 111.G.2 would not significantly augment the level of fire protection for the redundant CS flow instruments.
FPRR Rev. 11 DR25-2 SSES-FPRR Text Rev. 11 Spatial Separation:
The spaUal separation between redundant CS flow instruments (includ[ng their respective instrument tubing) in Fire Zone 1-3A is more than twice that required by Section 111.G.2.b.
The 45 feet separating the redundant CS flow instruments provides a high degree of margin for safety, in the event of a fire, to ensure both divisions of.CS
* flow instruments will not be disabled.
Hence, the spatial separation between redundant CS flow instruments more than meets the requirements of Section 111.G.2.b.
In addition, the 13 feet vertical spatial separation between the CS flow instruments and the cable trays further reduces the possibility of a fire tn the cable trays affecting the CS flow instruments.
There areThermo-Lag wrapped conduits withfn this 13 feet separation.
Thermo-Lag 330-1 is combustible with an ignitron temperature of 1000&deg;F. The automatrc suppression system in this fire zone wiH prevent temperatures from reachrng this tevel. Therefore, there wiU be no effect from the Thermal-Lag on the CS flow rnstruments.
There are additional Division H circuits in this same area that also rely upon spatial separation equivalent to that required by Appendix R Section 111. G.2.b. Refer to Calculation EC-013-1837 for information on circuits in Cable Tray Sections F1KH15 and F1KL 15 in this portion of Fire Zone 1-3A that also rely on spatial separation as a part of their qualification basis. lntervening Combustibles~
Appendix R compliance requires that no intervening combustibres be located between the redundant CS flow instruments.
The only combustibles located in this locar area consist of cables in cable trays and raceway protected with Thenno-Lag fire barriers (note that cables routed in conduits, terminaJ boxes and juncUon boxes do not constitute intervening combustibles).
However, each of the cable trays located in the local area of concern in Fire Zone 1-3A is fully endosed by sheet metal (topl bottom, and sides}. NRC Generic Letter 86-.101 Enclosure 2, Section 3.6.2 states that 11 cables in cable trays having solid sheet metal bottom, sides and top, rf protected by automatic fire detection and suppression systems and if the design is supported by a fire hazards analysis.
have been found acceptable under the exemption process." Based on the above discussion, the cables trays routed between the redundant CS f~ow instruments can be considered to not constitute intervening combustibles.
However, the Thermo-Lag fire barriers on the raceway must be considered as intervening combustibles and this deviation request constitutes the documentation of the fire hazards analysis that supports the adequacy of the existing fire protection features in the tocai area of concern. In the area located between the redundant CS flow instruments, Thermo-Lag fire barriers on raceway are the only intervenin~
combustibles.
Thermo-Lag 330-1 has an ignition temperature of approximately 1000 F. Due to the presence of automatic suppression and detection in this fire zone, temperatures in this range wm never be reached and a fire wm neither initiate nor propagate along the Thermo-Lag on the I raceway to either redundant CS component. . FPRR Rev. 11 SSES .. FPRR
* Text Rev. 11 Also note that the introduction of transient combustibles is highly unlikely due to the narrow passageway (approximately three feet wide) in the location under revrew. Moreover, NRC Generic Letter 86-10 specifically states that transient materials are not considered inteivening combustibles.
 
==
Conclusion:==
 
Based on: 1) the greater than 45 feet spatial separation between redundant safe shutdown equipment in Fire Zone 1-3A, 2) the existence of fire detection and automatic suppression coverage in the area of concern, and 3) the acceptabte combustible loading analysis, the current configuration provides an equivalent degree of safety as that required by Section 111.G.2.b of Appendix R. The future addition of intesvening combustibles in the local area of interest is controlled by program commitments that require all modifications be evaluated to ensure that combustible loading fire durations remain below the Fire Zone fire resistance rating and conclusions made here-in are reviewed for applicability.
Therefore, the following Division It components and raceway contafning circuits for these components in this fire zone do not need to be protected.
* F1S-E21-1 N006B
* FT-E21-1N003B
* Junction box and flex conduit to F1S-E21-1 N0068
* Junction box and flex conduit to FT-E21-1 N003B. The addition of automatic fire suppression throughout Fire Area R-1A is not required.
The full automatic fire suppression capabrlity in Fire Zone 1-3A is sufficient.
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'ti;5 u c i\!\f*Ji!WA RE V! 0E SCR[PTI*::JpR]CHJ j RPP R OVEOPR T~ N o~-Q UA L IT Y RELA TED sOsoU E HA N N A S.E.S. U N IT"_J REACTOR BUILD I NG. APPENDIX R-DEVIA. RE0..~5 .Fl RE ZONE.1:-3 A. E L.68 3'.Q'' A REA 1s,~, !ELEV .~&3*o lsC A LE:tlo t ('.() PlNNSYL VANIA POWER & L JGHT C&deg;""ANY ALLENTOWN PA. l'l'.I. 11 ,i~II N U NO. ,11u: r "&deg;* (2 13420 2 C-1834 l'Xl)lrf'S Ol1:\7 r SSES-FPRR Text Rev. n APPENDIX R DEVIATION REQUEST NO. 26 SEPARATION OF REDUNDANT SAFE SHUTDOWN CAPABILITY IN FIRE ZONE 2-38-N DEVIATION REQUEST: The current location of the Core Spray (CS) flow instruments and Residual Heat Removal (RHR) isolation valve control circurts and components relative to the combustible loading configuration in Fire Zone 2-38-N provides a degree of safety equivalent to that required by Appendix R, Section 111.G.2.b and their enclosure with fire rated barriers is not required.
The affected instruments/circuits for CS include F1S-E21-2N006A, FT-E21-2N003A, F1S-E21-2N006B, FT-E21-2N003B and circuits.
The affected components/circuits tor RHR include HV-E11-2F008 and HV-Ei 1-2F009 circuits, Pressure Instrument B31-N018A and Control Relay K33. FIRE AREAS/ZONES AFFECTED:
This deviation request applies only to Fire Zone 2-3B*N {Unit 2 Reactor Building Elevation 683t which is in Fire Area R-28. REASON FOR DEVIATION:
1 OCFR50t Appendix A, Section HI.G.2.b requires the absence of intervening combustibles between redundant safe shutdown equipment, in those fire areas where separation of redundant safe shutdown cables and equipment is greater than 20 feet with automatic suppression and detection.
The redundant Core Spray (CS) flow instruments in Fire Zone 2*38-N (in Fire Area R-2B) are separated by greater than 20 feet (approximately 41 feet) with automatic fire suppression and detection coverage in the focal area of concern. However, automatic fire suppression and detection does not completely cover Fire Zone 2-38-N; and intervening combustibles (conduits with Thermo-Lag fire barriers and cable trays) are located between the redundant CS flow instruments.
The redundant Residua, Heat Removal (AHR) isolation valve control circuits and components in Fire Zone 2-3B-N {in Fire Area R-2B) are separated by greater than 20 feet (approximately 36 feet) with automatic fire suppression and detection coverage in the local area of concern. However, automatic fire suppression and detec1ion does not completely cover Fire Zone 2-3B-N; and intervening combustibles (conduits wi1h Thermo-Lag fire barriers and cable trays) are tocated between the redundant AHR isolation valve control circuits and components.
FPRR Rev. 11 DR26-1 SSES-FPRR Text Rev. 1 i EXISTING ARRANGEMENT
: Core Spray (CS}: In Fire Zone 2-38-N, Division r of safe shutdown equipment is assured available for plant shutdown.
CS flow instruments F1S-E21-2N006A and FT-E21-2N003A are located in Fire Zone 2-38-N and are required operable for proper functioning of the Division I CS System. The Division I CS now instruments are separated by approximately 41 feet from Division fl CS flow instruments F1S-E21-2N006B and FT-E21-2N003B, including instrument tubing for the respective flow instruments.
Additionally, aU other unprotected Division II safe shutdown components in Fire Zone 2-38-N have greater spatial separation from Division I CS flow instruments than that mentioned above. Thus the 41 feet horizontal spatial separation between redundant CS flow instruments is the limiting case requiring evaluation (refer to attached Drawing C-1835). Automatic fire suppression and detection exist in Fire Zone 2-3B*N from Column Line P to Q. The 41 feet separating the redundant CS flow instruments is fully covered by automatic fire suppression and detection (refer to attached Drawing C-1835! Sheets 1 and 2). Several cable trays with sheet metal covers (top and bottom) and some conduits with Thermo-Lag fire barriers traverse North-South in Fire Zone 2-3B*N between the redundant CS flow instruments.
The cable in the cable trays and the Thermo-Lag on the conduits are the only source of combustibles located between the redundant CS flow instruments.
The cable trays are entirely enclosed by sheet metal covers between Column Lines 31.5 and 33, which constitutes greater than 25 horizontal feet in which fully enclosed raceways are protected by automaUc fire suppression and detection systems. The lowest cable tray has a vertical spatial separation of approximately 12 feet from the CS flow instruments located below (refer to attached Drawing C-1835, Sheet 2). The lowest conduit with a Thermo-Lag fire barrier has a vertical spatial separation of greater than 12 feet from the CS flow instruments located below (refer to attached Drawing C-1835, Sheet 2). Adequate separation exists between CS flow instruments F1S-E21 *2N006A and FIS-E21-2N006B such that F1S-E21-2N006A and raceway Uunction box and flex conduit to F1S-E21-2N006A do not require fire barriers.
Adequate separation exists between CS flow instruments FT-E21-2N003A and FT-E21-2N003B such that FT-E21-2N003A and raceway Ounction box and flex conduit to FT-E21-2N003A) do not require fire barriers.
FPRR Rev. 11 DR26-2 SSES-FPRR Text Rev. 11 Residual Heat Removal (RHR): As stated above, in Fire Zone 2-38-N, Division I of safe shutdown equipment is assured available.for plant shutdown.
Redundant AHR isolation valves, HV-E11-2F008 and HV-E11-2F009 (2F009), have control circuit cables and components tocated in Fire Zone 2-38-N.
* HV-E11-2F009 control circuit location is limited to the south end of 2-38-N, south of Instrument Rack, 2C006. Pressure Instrument B31-N018A and Control Relay K33 are located on Instrument Rack 2C006 and provide an open permissive to Valve HV-E11-2F009.
Relay K33 is mounted in Terminal Box TB2C006-B3 located on south end of lnstrument Rack 2C006. Pressure Instrument B31-N018A is located about 1 foot above Terminal Box TB2C006-B3 and 2 feet below Terminal Box TB2C006-B2.
These are the only Valve HV-E11-2F009 components outside of scheduled cable located in Fire Zone 2~3B-N. Flex conduit is used to connect wiring to these components at Instrument Rack 2C006. Rigid steel conduits E2K454 and E2K121 route control circuit cables from TB2C006-B2 to Tray Section E2KH62. Tray Section E2KH62 is located directly above TB2C006-B2 at Elevation 708 1-6 11* Adequate separation exists between AHR redundant components such that Pressure Instrument B31-N018A, Terminal Box TB2C006-B3 with Relay K33 and raceway (E2K454, E2K1Z1 and E2KH62*) do not require fire barriers.
*This section of E2KH62 is protected with Thermo-Lag because it contains circuits for Division I CS flow instruments.
Valve HV-E11-2F009 control circuit cables immediately leave Fire Zone 2-38-N in Tray Section E2KH62 through the south wall of Fire Zone 2-38-N (refer to attached Drawing C-18351 ~heets 1 and 2). RHR Valve HV-E11-2F008 Division II control circuits enter Fire Zone 2-3B-N at tray F2KF61 through a 3-hour fire rated floor penetration X-30-3-61 approximately 36 teet north of Terminal Box TB2C006-B3 1 and 7 feet north of Column Line 33. Division II control circuits are routed verticalty to Elevation 711 '-9 11 and then north towards MCC 2D274. Division II, HV-E11-2F008, redundant components are all located in the northern section of Fire Zone 2-3B*N at MCC 2D274 and Instrument Rack TB2C022. MCC 2D274 is approximatefy 105 feet north of Division, components at Instrument Rack 2C006 and Division If Instrument Rack, 2C022, is approximately 81 feet north and 60 feet east of Division t Instrument Rack 2C006. (refer to C'."" 1730, Sheet 1 }. Automatic fire suppression and detection exist in Fire Zone 2-3B .. N from Column Line P to Q. The 36 feet separating the redundant RHR isolation valve control circuits or components is f~Uy covered by automatic fire suppression and detection (refer to attached Drawing C-1835, Sheet 1 ). FPRR Rev. 11 DR26-3 SSES-FPRR Text Rev. 11 The same cable trays and conduits with Thermo-Lag fire barriers mentioned in the CS flow instruments evaluation above exist between AHR isolation valve controt circuits and components.
The closest spatial distance between redundant RHR Valve HV-E11-2F008 and HV-E11-2F009 control circuits or components is approximately 36 feet between Terminal Box TB2C006-B3 and Division II Tray F2KF61. The lowest* cable tray has a vertical spatial separation of approximately 12 feet from the RH R isolation valve control circuits and components located below (refer to attached Drawing C-1835, Sheet 2). The lowest conduit with a Them10-Lag fire barrier has vertical spatial separation of greater than 12 feet from the AHR isolation valve control circuits and components located below (refer to attached Drawing C-1835, Sheet 2). JUSTIFICATION:
To meet the requirements of 1 OCFR50, Appendix A, Section tll.G.2.b, the following features must exist to ensure that a fire is limited so that onry one division of redundant components important to safe shutdown is affected:
: a. Fire detectionJ
: b. Automatic fire suppression, c. Greater than 20 feet horizontal separation between redundant safe shutdown equipment/cabres, and d. No intervening combustibles.
Fire Detection:
In the local areas where Section 111.G.2.b separation is sought, ionization detectors provide the necessary fire detection to alert operators of the onset of a fire in the locatron of CS flow instruments or redundant RHR isolation valve control circuits and components.
Hence! the level of fire detection rn Fire Zone 2-3B-N meets the requirements of Section 111.G.2.b (refer to attached Drawing C*1835 1 Sheet 1 for approximate fire detector locations}.
Automatic Fire Suppression:
The automatic fire suppression system 1n the local areas of concern in Fire Zone 2-38-N (Fire Area R-2B) provides ample suppression capability to immediately suppress a fire. Fire Zone 2-3B*N has full au1omaUc fire suppression, i.e., Preaction System PA-231, in the areas in which Section UI.G.2.b separation is sought. The portion of Fire Area R-28 without automatic suppression is located between Column Lines 29 and 30.5 from Column Lines Q and S (refer to Drawing C-1730, Sheet 3). The installation of an wide automatic fire suppression system in Fire Area R-28 to meet the requirements of 10CFA50 Appendix R, Section IH.G.2 would not augment the level of fire protection for the redundant CS flow instruments and RHR isolation valve control circuits and components.
FPRR Rev. 11 DR26-4 SSES-FPRR Text Rev. 11 Spatial Separation:
The spatial separation between redundant CS flow instruments (including the;r respective instrument tubing) in Fire Zone 2*3B-N is more than twice that required by Section 111.G.2.b.
The 41 feet separating the redundant CS flow instruments provides a high degree of margin for safety, in the event of a fire, to ensure both divisions of CS flow instruments will not be disabled.
Due to spaUal separatronl E21-2N003A, F1S-E21-2N006A and raceway uunction boxes and flex conduit to FT-E21-2N003A and F1S-E21-2N006A) do not require fire barriers.
The minimum separation between redundant AHR isolation valve control circuits and components in Fire Zone 2-38-N is sixteen feet greater than that required by Section IH.G.2.b.
The 36 feet separating the redundant control circuits and components provides a high degree of margin for safety, in the event of a fire, to insure both divisions of AHR valve control and components will not be disabled.
Due to spatial separation, Pressure Instrument B31-N018A, Instrument Rack TB2C006 with Relay K33 and raceway (E2K454 1 E2K121 and E2KH62) do not require fire barriers.
The minimum separation between redundant AHR isofation valve control circuits and components in Fire Zone 2*3B-N is sixteen feet greater than that required by Section 111.G.2.b.
The 36 feet separating the redundant control circuits and components provides a high degree of margin for safety! in the event of a fire, to insure both divisions of AHR valve control circuits and components will not be disabled.
Due to spatial separation, Pressure tnstrument B31-N018A, Instrument Rack TB2C006 with Relay K33 and raceway (E2K454, E2K1Z1 and E2KH62) do not require fire barrrers.
The spatial separation between redundant CS flow instruments and AHR valve control circurts and components more than meets the requirements of Section !11.G.2.b.
All necessary raceways are protected with fire rated barriers to ensure adequate protection between redundant divisions of safe shutdown cables in the tocal areas of concern. In addition, the vertical spatial separation between the CS flow instruments and RHR isolation valve control circuits and components to the cable trays and conduits with Thermo-Lag fire barriers further reduces the possibility of a fire affecting the CS flow instruments or AHR isolation valve control circuits and components.
Intervening Combustibles:
Appendix R compliance assures that no Intervening combustibles be located between the redundant CS flow instruments and AHR isolation valve controls and control circuits.
The only combustibles located in this local area consrst of cables in cable trays and conduits with Thermo-Lag fire barriers (note that cables routed in conduits, terminal boxes and junction boxes do not constitute intervening combustibles).
However, each of the cable trays located in the local area of concern in Fire Zone 2-38-N, is fully enclosed by sheet metal (top, bottom, and sides), for greater than 25 feet in whfch automatic suppression and detection exists. NRC Generic Letter 86-10, Enclosure 21 Section 3.6.2 states that 11 cables in cable trays having solid sheet metal bottom, sides . I FPRR Rev. 11 DR26-5 Text Rev. 11 and top, if protected by automatic fire detection and suppression systems and if the design is supported by a fire hazards analysis, have been found acceptable under the exemption process. 11 Based on the above discussion, the cable trays routed between the redundant CS flow instruments and between AHR isolati.on valve control circuits and components do not constitute intervening combustibles.
However, the Thermo-Lag fire barriers on the raceway must be considered as intervening combustibles and *thrs deviation request constitutes the documentation of the fire hazards analysis that supports the adequacy of the existing fire protection features in the local area of concern. Actual tn-situ combustible loading fire durations of the existing arrangement have been detennjned.
These values are based on the initial combustible loading analysis and subsequent modifications.
The governing criteria for the combustible loading analysis is that the Fire Zone fire resistance rating exceeds the combustible loading fire duration.
The addition of Thermo-Lag to Fire Zone 2-38-N as a combustible adds less than 6 minutes to the existing combustible loading fire duration.
The additional fire loading due to the Thermo-Lag fire barriers on the raceway in Fire Zone 2-38-N does not result in exceeding the Fire Zone fire resistance rating. In the local area (located between the redundant CS flow instruments and RHR isolation valve controls and control circuits), the only in-situ combustible to be considered (as per above) is the Thermo-Lag fire barriers on the conduits.
Thenno-Lag 330-1 has an ignition temperature of approximately 1000&deg;F. Due to the presence of automatic suppression and detection in this fire zone, temperatures in this range will never be reached and a fire will not propagate along the Thermo-Lag on the conduits to either redundant CS or AHR components.
Also note that the likelihood of introduction of transient combustibles is highly unlikely due to the narrow passageway (approximately three feet wide} in the location under review. Moreover, NRC Generic Letter 86-10 specifically states that transient materials are not considered intervening combustibles.
 
==
Conclusion:==
 
Based on: 1) the 41 and 36 foot spatial separations between redundant sate shutdown equipment in Fire Zone 2-3B-N, 2) the existence of fire detection and automatic suppression coverage in the local area of concern, and 3) the acceptable combustible loading analysis, the current configuration provides an equivalent degree of safety as that required by Section IIJ.G.2 of Appendix R without the addition of fire rated barriers.
In addition, the installation of automatic fire suppression throughout the remainder of Fire Area R-2B to meet the requirements of 10CFR50 Appendix R, Section 111.G.2 would not significantly augment the level of fire protection for the redundant CS flow instruments or the AHR isolation valve control circuits and components in this specific section of Fire Area A*28. FPRR Rev. 11 DR26-6 SSES-FPRR Text Rev. 11 The future addition of intervening combustibles in the local area of interest is controlled by program commitments that require all modifications be evaluated to ensure that combustible loading fire durations remain below the Fire Zone fire resistance rating and conclusions made here-in are reviewed for applicability.
* Therefore, the following components and raceway containing circuits for these components in this fire zone do not need to be protected.
Core Spray AHR F1S-E21-2N006A FT-E21-2N003A Junction box and flex conduit to F1S-E21-2N006A Junction box and flex conduit to FT-E21-2N003A Pressure Instrument B31-N018A Relay K33 in TB2C006-83 on Instrument Rack TB2C006* Raceway E2K454, E2K1Z1 and E2KH62* *E2KH62 is protected with a qualified. raceway tire barrier for the CS flow instrument circuits, but is not required to be protected for the RHR HV-E11-2F009 circuits.
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* ** SSES-FPRR APPENDIX R DEVIATION REQUEST NO. 27 NUCLEAR BOILER INSTRUMENTATION IN FIRE ZONE 1-SA-S DEVIATION REQUEST: The current arrangement of Nuclear Boiler Instrumentation in Fire Zone 1-SA*S provides an equivalent degree of safety as that required by 1 OCFR50, Appendix R, Section lfl.G.2.b based on the present in-situ combustible loading configuration, horizontal separation of redundant safe shutdown ECCS interlock components of 14 feet, horizontal separation of redundant safe shutdown vessel indication components of 6 feet, plant procedure to control transient combustibles and the existing fire suppression and detection provided in the area. FIRE AREAS/ZONES AFFECTED:
This deviation request applies only to Fire Zone 1-5A-S, which is in Fire Area R-1 A. REASON FOR DEVIATION REQUEST: 10CFR50, Appendix R, Section 111.G.2.b requires the existence of an automatic fire suppression system, in addition to fire detectors, in those fire areas where separation of redundant safe shutdown cables and equipment is greater than 20 feet with no intervening combustibles.
The redundant Nuclear Boiler tnstrumentation in Fire Zone 1-5A-S as identified in Table DR27-1 does not meet the separation
_criteria as required by Appendix R, Section 111.G.2.b.
The horizontal separation of indivjdual redundant ECCS interlock components is 14 feet and horizontal separation of the redundant vessel indication components is 6 feet. Automatic fire suppression and detection is provided in Fire Zone 1-SA*S above the instrument racks. EXISTING ARRANGEMENT Both divisions of required nuclear boiler instruments are located in Fire Zone 1-SA-S. The instruments and tenninal boxes on instrument rack 1 C004 required for Unit 1 safe shutdown are identified in Table DR27-1. The instruments and terminal boxes on instrument rack 1 COOS required for Unit 1 safe shutdown are also identified on Table DR27-1. The arrangement of the instruments was.designed to insure proper RPS input of the n1-out-of-2-taken*twice 11 logic for a single instrument line failure. A fire which damages these instruments or their circuitry could result in either a loss of automatic functions or a spurious signal to the automatic initiation logic. The existing arrangement of the nuclear boiler instrument racks and other related equipment is shown on Drawing C-213437 . Rev. 10 DR27*1 G:\J.ic Docs\FPRR Approved\Deviatlons\fpd_
0700_27 .doc SSES-FPRR The combustible loading in Fire Zone 1-5A-S is low. The area around these racks ;s protected by automatic fire suppression installed using NFPA 13 as a guide and tire detection installed using NFPA 72D and 72E as a guide.
* Several cable trays traverse East-West in front of and above the nucfear boHer instrument racks. Three cable trays are enclosed by sheet metal, while one other is a
* ladder type tray enclosed on the top. The lowest cable tray is 13 feet above the floor and 7 feet above the instrument racks. Cable insulation meets the requirements of IEEE-383 Flame Test. JUSTIFICATION:
To meet the requirements of 10CFR50, Appendix R, Section 111.G.2.b, the following features must exist to ensure that a fire is limited so that one division of redundant components important to safe shutdown is available:
: a. fire detection, b. automatic fire suppression, c. no intervening combustibles, and d. greater than 20 feet horizontal separation between redundant safe shutdown equipment/cables.
* Requirements a and b ar~ met and a fire hazard analyses has demonstrated that the
* existing configuration is acceptable even though requirements c and dare not met. Justification is as foltows: 1. 2. Fire Detection
& Suppression Fire Zone 1-5A-S is protected by an automatic tire suppression and detection system. The automatic fire suppre-ssion system in Fire Zone 1-SA-S provides suppression capability to suppress a fire. This fire zone has full ceiling and* lower level coverage in the area of the reactor building chillers and the instrument racks 1C004 and 10005. ln*Situ Combustible Fire Hazard Analyses
* The only combustibles located in the immediate vicinity of the nuclear boiler instrumentation are fire protected racewayst cable trays, tenninal block~ and the instruments -themselves.
The instruments contain negligible combustibles and are comp1etely encased in metal enclosures which will contain any internal fire . within the housing. Terminal blocks for external cable connections are also completely enclosed in metallic boxes. Therefore, even with very little horizontal spatial separation, any fire on an instrument rack will not be propagated to other Rev. 10 DR27-2 G:\lic Docs\FPRA Approved'DeviationsVpcL0700_27 .doc * 
* *
* 3. SSES-FPRR racks, equipment, or cable trays. There are four cable trays in the area; three are completely enclosed by sheet metal and one is a ladder type enclosed on top but open on the bottom. The trays completely enclosed are not consider~d to constitute intervening combustibles, while the open tray does constitute an intervening combustible.
The cable tray that is not enclosed is equipped with fire resistant cables that have passed the IEEE-383 flame test. Due to the type of materials used, the cables have a low probability for spreading fire. Any fire in the cable trays will not propagate downward to impact the nuclear boiler instruments.
All Division II safe shutdown cables in this fire zone have been addressed as a part of the Appendix R Safe Shutdown Analysis and have been
* protected if necessary.
The fire protective barrier on the raceways in the vicinity of the racks is Thermo-Lag which is considered to be an intervening combustible.
Due to the high ignition temperature and distance from the racks, the protective barrier has no impact on the ~equired nuclear boiler instrumentation. . . Other combustibles within the fire zone are various control panels and lube oil from the reactor buifding chillers and fueJ poof cooling pumps. The control panels contain very little combustible materials within enclosed metallic housing, have spatial separation greater than 8 feet, and therefore, have no impact on the required nuclear boiler instrumentation.
The lube oil equipment is located in areas where the floor is sloped to local floor drains. The drainage areas a*re of sufficient size to contain any oil spill. The areas are equipped with full suppression over the chillers and pumps to mitigate the spread of a fire . Horizontal spatial separation between pumps/chiller and the instruments rack ,s greater than 20 feet. In addition, the fuel pool cooling pumps are located within the fuel pool cooling room which is surrounded by concrete waifs. Transient Combustible Fire Hazard Analysis Based on limited quantities of transient combustibles and fire suppression systems, any fire caused by transients will be limited in size. The resultant fire is defined to be a cylindrical area of influence with a radius of 5 feet and a height of 10 feet. Therefore,*
a transient combustible fire can onfy disable 3 of the 4 nuclear boiler instrument racks, 1CD04t 1C224, and 1C225 or 1COOS, 1C225, and 1C224. This will insure that either Rack 1C004 or 1C005 will always be unaffected by the postulated fire. A faifure of this instrumentation which results in a loss of automatic functions will have no impact to Appendix R Safe Shutdown, since the manual operation*
of ttiese systems is unaffected.
Inadvertent operation of the safety systems is not a concern, because for this to occur, as a minimum, an instrument on each rack must provide a spurious signal. This evaluation has demonstrated that fire impact to both racks as a result of the same fire is not feasible.
* Both oivisions of nuclear boiler vessel wide range pressure and level transmitters, however, are located within the cylinder of influence and may be lost. Although avail.ability of this instrumentation is highly desirable, its loss is Rev. 10 DR27-3 G:\Uc Oocs\FPRA Approved\Deviations\fpd_0700_27.doc 
: 4. SSES-FPRR acceptable because safe shutdown can be achieved and maintained without it.
* Due to the number of alternative instruments available to mpnitor RPV level and
* pressure, the complete loss of RPV level and pressure indication due to this localized fire is high1y unlikely.
Should RPV level indication be lost and no alternate level indication be available, however, the operator would enter E0-100-114, RPV Flooding.
E0-100-114 requires the operator to verity a minimum 62 psid between the RPV pressure and the suppression chamber . pressure to assure adequate core cooling: Should the RPV pressure indication also be lost and no alternate pressure indication be available, the operator would enter E0-100-115, Primary Containment Flooding.
In any case, safe shutdown conditions would be able to be established either by the use of alternative indication instrumentation or through implementation of the required steps in the Emergency Operating Procedures.
The main concern is a fire that results in a sufficient number of spurious signals to cause an inadvertent system actuation.which results in an adverse impact to Appendix R Safe Shutdown.
Based on the Spurious Operations Criteria provided to the NRC in Attachment A to PLA-4505 dated December 6, 1996 and accepted by the NRC in a SER dated October 21, 1997, the number of spurious operations required for inadvertent system actuation to occur is beyond the number required to be assumed. As an additional precaution, however, the following approach wifl be used to assess the impacts of fires on Appendix A Safe Shutdown in this fire zone. Since all required Division 11 safe shutdown raceways will be protected
* in Fire Zone 1-5A-S, loss of Division I components and Division II cables is not probable.
However, it is possible for a fire to disable Division II components and Division I cables. Therefore*, all Division I safe shutdown raceways in the area around Rack 1 COOS, which contains the Division II components, defined by: . ' Height of 1 0 feet
* On the South by the fuel pool cooling room wall, On the East by a line 14 feet from the East end of Rack 1 COOS, On the North by the containment wall, and On the West by a line 10 feet from the West end of Rack 1C005, have been evaluated for impact on achieving Appendix R Safe Shutdown.
Those raceways identified as impacting Appendix R Safe Shutdown have been protected with 1-hour fire rated wrap. Effects of Sprinklers The actuation of the sprinkler system will not disable any safe shutdown nuclear
* boiler instrumentation.
Rev. 10 G:\J..ic Oocs\FPRR Approvec.t\De'liations\tpd_
0700_27 .doc 
---***-*--~~--------
SSES-FPRR
* The analysis provided above has demonstrated the following conclusions:
*
* 1. The in-situ combustible loading arrangement will not support a design basis fire that will disable both divisions of .nuclear boiler instrumentation.
: 2. A transient combustible fire will not be of sufficient magnitude to disable both divisions of safe shutdown ECCS interlock components.
: 3. The necessary safe shutdown cables will be protected to insure that a fire will not , disable one division*s components and the opposite division 1 s cables where fire damage to such cables can have an adverse impact on the ability to achieve and maintain safe shutdown.
: 4. . Initiation of the fire suppression system wiH not disable any .required nuclear boiler syste~.
* Therefore, the existing arrangement, along with protecting any critical Division I cables in the vicinity of Division II components, provides an equivalent degree of safety to that required by Appendix A, Section 111.G.2.b.
From the justification above, it can be concluded that there is no fire (in-situ or transient) in Fire Zone 1-5A-S that will prevent achieving and maintaining cold shutdown . Therefore, it is concluded that the current configuration provides an equivalent degree of safety to that required by Section 111.G.2.b of Appendix A. Rev. 10 DR27-5 G:\Uc Docs\FPRR Approved\Deviati~\lpd_0700_27 .doc Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Security-Related Information Figure Withheld Under 10 CFR 2.390
 
SSES-FPRR
* TABLE DA27
* 1 UNIT 1 SAFE SHUTDOWN NUCLEAR BOILER INSTRUMENTS Safe Fire Required Instrument
# Description Area Elev. Shutdown Zone Path Rack Path LIS-621-1 N024A Level Indicating Switch for 29 749 1 1-SA*S 3 1C004 *LIS-821-1 N-024C RPS & RCIC (High Water 27 749 3 1-SA-S 3 1C005 Level Trio) LIS-B2H N024B Level Indicating Switch for 29 749 1 1-SA-S 3 1C004 *us-021-1 N024D RPS & HPCI (High Water 27 749 1-SA-S 3 1C005 Level Trio) LIS-B21-1N031A Level Indicating Switch CS, 29 749 1 1*5A-S 3 1C004 *LIS-B21-1 N031 B ADS & RHR (Level 1 27 749 3 t-5A*S 3 ,coos LIS-B21-1 N-031C Initiation Signal) 29 749 1 1-SA-S 3 1C004 *us-021-1 N031 o 27 749 3 1-5A-S 3 1C005 LIS-821-1 N042A Level Indicating Switch for 29 749 1 ,2 1-SA-S 3 1C004 *LIS-B21-1 N042B ADS (Confirmatory Level 3) 27 749 2,3 1-SA-S 3 1C005 LT-14201A Wide Range Reactor Level 27 749 1 1-SA-S 3 1C225 * *LT-14201 B Indication 27 749 3 1-SA*S 3 1C224 PS-B21-1N021A Pressure Indicating Sw~ch 29 749 , 1-5A-S 3 1C004 *p1S-S21-1N021B for CS & AHR (High Orywell 27 749 3 1-SA-S 3 ,coos Pennissive)
PS*B21
* 1 N023A Pressure Switch for RPS 29 749 1 1-SA-S 3 1C004 PS-B21-1 N023B (High Pressure Trip) 29 749 1 1*5A-S 3 1C004 *PS-B21-1 N023C 27 749 3 1-5A-S 3 1C005 1 PS-B21-1N023D 27 749 3 1-SA-S 3 1C005 PT-14201A Wide Range Reactor 27 749 1 1-SA-S 3 1C225 1 PT-14201B Pressure Indication 27 749 3 1-SA-S 3 1C224 TB1C004-A1 Terminal Box 29 749 1 1-SA-S 3 1C004 TB1C004-A2 Terminal Box 29 749 1 1-SA-S 3 1C004 TB1C004-B1 Terminal Box 29 749 1 1-5A-S 3 1C004 . TB1 C0()4..B2 Terminal Box 29 749 1 . 1-5A-S 3 1C004 TB1C005-A1 Terminal Box 27 749 3 1-SA-S 3 1C005 TB1C005-A3 Terminal Box 27 749 3 1-5A-S 3 1C005 TB1C005-B1 Terminal Box 27 749 3 1-SA-S 3 1C005 TB1C005-B2 Terminal Box 27 749 3. 1-5A-S 3 1C005 *Denotes the Reouired Safe Shutdown Comoonents for This Fire Zone
* Rev. 10 Page 1 of 1 G:\Lic Docs\FPRR Approved\Tables\Devtables\Devtables\tpdt_0700_27
_ 1.doc SSES~FPRR Text Rev. 11 APPENDIX R DEVIATION REQUEST NO. 28 NUCLEAR BOILER INSTRUMENTATION IN FIRE ZONE 2-SA*N DEVIATION REQUEST:*
The current arrangement of nuclear boiler instrumentation in Fire Zone 2-SA-N provides an equivalent degree of safety as that required by 1 OCFRSO, Appendix R, Section 111.G.2.b, based on the present in-situ combustible loading contiguratron, horizontal separation of redundant safe shutdown ECCS interlock components of 14 feet and plant procedure to control transient combustibles.
FIRE AREAS/ZONES AFFECTED:
This deviation request applies only to Fire Zone 2-SA-N, whrch is in Fire Area R-2A. REASON FOR DEVIATION REQUEST: 1 OCFR50, Appendix R, Section 111.G.2.b requires the existence.of an automatic fire suppression system, in addition to fire detectors, in those fire areas where separation of redundant safe shutdown cables and equipment is greater than 20 feet with no intervening combustibles.
The redundant nuclear boiler instrumentation in Fire Zone 2-SA-N as identified in Table 28-1 does not meet the separation criteria as required by Appendix R, Section HI.G.2.b.
The horizontal separation of fndividual redundant ECCS interlock components is 14 feet. Automatic fire suppression and detection is provided throughout Fire Zone 2-SA-N. An analysis has demonstrated the following conclusions:
: 1. The in~situ combustible loading arrangement will not support a fire that will disable both divisions of nuclear boHer instrumentation.
: 2. A transient combustible fire will not be of sufficient magnitude to disable both divisions of safe shutdown ECCS interlock components.
: 3. The necessary safe shutdown cables will be protected to insure that a fire will not disable one division*s components and the opposite division*s cables where fire damage to such cables can have an adverse impact on the ability to achieve and maintain safe shutdown.
: 4. Initiation of the fire suppression system wiH not disable any required nuclear boiter system. Thereforet the existing arrangement, along with protecting any critical Division II cables in the vicinity of rnvision I components, provides an equivalent degree of safety to that required by Appendtx R, Section 111.G.2.b.
FPRR Rev. 11 DR28-1
* SSES -FPRR Text Rev. 11 EXISTING ARRANGEMENT:
In Fire Zone 2-5A-N, Division I of safe shutdown equipment is assured available for plant shutdown.
Both divisions of required nuclear boiler instruments are located in Fire Zone 2-SA-N. The instruments and terminal boxes on instrument rack 2C004 required for Unit 2 safe shutdown are identified on Table DR28-1. The instruments and terminal boxes on instrument rack 2C005 required for Unit 2 safe shutdown are also identified on Table DR28-1. The arrangement of the instruments was designed to insure proper RPS input of the 11 1-out-of-2-taken-twice" logic for a single instrument line failure. A fire which damages these instruments or their circuitry could result in either a
* loss of automatic functions or a spurious signal to the automatic initiation logic. The existing arrangement of the nuclear boiler instrument racks and other related equipment is shown on Drawing C-213438.
The combustible loading in the entire Fire Zone 2-5A-N was conseivatively calculated to be low. Automatic fire suppression is installed using the guidelines of NFPA 13 and fire detection is provided throughout Fire Zone 2-SA-N. Three cable trays traverse east-west in front of and above the nuclear boiler instrument racks 1n Fire Zone 2-5A-N. Two cable trays are enclosed by sheet metal, while the other is enclosed with fireproof insulation.
The lowest cable tray is 14 feet above the troor and 8 feet above the instrument racks. All cable insulation meets all requirements of IEEE-383 Flame Test. JUSTIFICATION:
To meet the requirements of 10CFR50, Appendix R, SecUon rn.G.2.b, the following features must exist to ensure that a iire is limited so that one division of redundant components important to safe shutdown ts available:
: a. Fire detection.
: b. Automattc fire suppression.
: c. No intervening combustibles.
: d. Greater than 20 feet horlzontal separation between redundant safe shutdown equipment/cables.
Requirements a and bare met and a ftre hazard analyses has demonstrated that the existing configuration is acceptabte even though requirements c and dare not met. FPRR Rev. 11 DR28-2 SSES -FPRR Text Rev. 1 Justification is as follows: 1. 2. 3. Fire Detection and Suppression
_Fire Zone 2-5A-N is fully covered*by an automatic fire detection system. The automatic fire suppression system in Fire Zone 2-5A-N provides suppression capability to suppress a fire. This fire zone has full ceiling and lower level coverage in the area of the Reactor Buitding chillers using the guidelines of NFPA 13. In-Situ Combustible Fire Hazard Analyses The only combustibles located in the immediate vicinity of the nuclear boiler instrumentation are the cable trays, terminal blocks, and the instruments themselves.
The instruments contain negligible combustibles and are completely encased in metal enclosures which will contain any internal fire wfthin the housing. Terminal blocks for external cable connections are also completely enclosed in metallic boxes. Therefore, even with very little horizontal spatial separation, any fire on an instrument rack will not be propagated to other racks, equipment, or cable trays. There are three cable trays in the area; two are completely enclosed by sheet metal while the third is wrapped with fireproof insufation.
The trays completety enclosed are not considered to constitute intervening combustrbles, while the wrapped tray does constitute an intervening combustible.
Due to the type of material used, the wrap has a low probability for spreading the fire or propagating downward to impact the Nuclear Boiler Instruments.
All Division I safe shutdown cables in this fire zone have been addressed and protected i1 required.
Other combustibles within the fire zone are various control panels and lube oH from the Reactor Building chiHers and fuel pool cooling pumps. The control panels contain very little combustible materials wi1hin enclosed metallic housing, have spatial separation greater than 8 feet, and therefore.
have no impact on the required nuclear boiler instrumentation.
The lube oil equipment is tocated in areas where the floor is sloped to rocal floor drains. The drainage areas are of sufficient size to contain any oil spill. The areas are equipped with fuH suppression over the chilrers and pumps to mitigate the spread of a resultant fire. Horizontal spatial separation between pumps/chiller and the instruments rack is greater than 20 feet. In addition, the fuel poof cooling pumps are located within the fuet pool cooling room which is surrounded by concrete waUs. Transient Combustible Fi~e Hazard Analysis Based on limited quantities of transient combustibles and fire suppression systems, any fire caused by transfents will be limited in size. The resultant fire is FPRR Rev. 11 DR28-3 SSES -FPRA Text Rev. 11 4. defined to be a cylindrical area of influence with a radius of 5 feet and a height of 10 feet. Therefore, a transient combustible fire will only disable two of the four nuclear boiler instrument racks, 2C004 and 2C224, or 2C225 and 2C005, or 2C225 and 2C004. This wilJ insure that either Rack 2C004 or 2C005 will always be unaffected by the postulated fire. A failure of this instrumentation which results in a loss of automatic functions will have no impact to Appendix R Safe Shutdownt since the manual operation of these systems is unaffected.
Inadvertent operation of the safety systems is not a concern, because for this to occur, as a minimum, an instrument on each rack must provide a spurious signal. This evaluation has demonstrated that fire impact to both racks as a result of the same fire is not feasible.
Also, one division of nuclear boiler vessel wide range pressure and level instrumentation will be available to achieve safe shutdown.
The main concern is a fire that results in a sufficient number of spurious signals to cause an ;nadvertent system actuation which results in an adverse impact to Appendix A Safe Shutdown.
Based on the Spurious Operations Criteria provided to the NRC in Attachment A to PLA-4505 dated December 6, 1996 and accepted by the NRC in a SER dated October 21, 1997, the number of spurious operations required for inadvertent system actuation 10 occur is beyond the number required to be assumed. As an additional precaution, however, the following approach has been used to assess the impacts of fires on Appendix R Safe Shutdown in this fire zone. Since required Division I safe shutdown raceways will be protected in Fire Zone 2-SA-N, loss of Division II components and Division I cables is not probable.
However, it is possible for a fire to disable Division I components and Division II cables. Therefore, a[I Division II safe shutdown raceways rn the area around Rack 2C004, which contains the Division I components, defined by: Height of 1 O feet, On the north by the fuel pool cooling room ~all, On the east by a line 10 feet from the east end of Rack 2C004, On the south by the containment wall, and On the west by a line 14 feet from the west end of Rack 2C004, will be evaluated for impact on achieving Appendix R Safe Shutdown.
Effects of Sprinklers The actuation of the sprinkler system will not disable any safe shutdown nuclear boiler instrumentation.
From the Justification above, it can be concluded that there is no fire On-situ or transient) in Fire Zone 2-SA-N that will prevent achieving and maintaining cold shutdown.
FPRR Rev. 11 DR28-4 ----------------------
*-*-*-*-**-----****-*** ----
SSES-FPRR Text Rev. 11 Therefore~
it is concluded that the current configuration provides an equivalent degree of safety as that required by Section 111.G.2.b of Appendix R. FPRR Rev. 11 DR28-5 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Security-Related Information Figure Withheld Under 10 CFR 2.390
 
SSES -FPRR Table Rev. 11 TABLE DR28-1 UNIT 2 SAFE SHUTDOWN NUCLEAR BOILER INSTRUMENTS Safe Fire Required Shutdown Instrument
# Description Area Elev. Path Zone Path Rack "US-B21-2N024A Level Indicating Switch 33 749' 1 2-5A-N 1 2C004* for RPS and RCtC {High Water Level Trip) l1S-B21-2N024C Level Indicating Switch 30 749' 3 2-5A-N 1 2C005 for RPS and RCIC {High Water Level Trip) ..-LIS-B21-2N024B Level Indicating Switch 33 749' 1 2-5A-N 1 2C004 tor RPS and HPCI (High Water Level Trip} LIS-B21-2N024D Level Indicating Switch 30 749' 3 2-5A-N 1 2C005 for RPS and HPCI (High Water Level Trip) ""LIS-B21-2N031 A Level Indicating Switch 33 749 1 1 2-SA-N 1 2C004 CS, ADS and RHR (Level 1 Initiation Signal) L1S-B21-2N031 B Level Indicating Switch 30 749' 3 2-SA-N 1 2C005 CS.ADS& RHR (Level 1 Initiation Signal) "'LlS-B21-2N031 C Level Indicating Switch 33 749' 1 2-SA-N 1 2C004 CS, ADS& RHR (Level 1 Initiation Signal) US-821-2N031 D Level Indicating Switch 30 749' 3 2-5A-N 1 2C005 CS, ADS& RHA (Level 1 Initiation Signal) Level Indicating Switch . l1S-B21*2N042A for ADS (Confirmatory 33 749' 1, 2 2-SA-N 1 2C004 Level 3} l1S-B21-2N042B Level Indicating Switch 30 749' 2,3 2-SA-N 1 2C005 for ADS (Confirmatory
* Level 3) '*LT-24201A Wide Range Reactor 30 749 1 1 2-SA*N 1 2C225 Level Indication LT-24201B Wide Range Reactor 33 749' 3 2-SA-N 2C224 Level Indication FPRR Rev. 11 Page 1 of 2 Table Rev. 11 TABLE OR28-1 UNIT 2 SAFE SHUTDOWN NUCLEAR BOILER INSTRUMENTS Safe Fire Required Shutdown Instrument
# Description Area Elev. Path Zone Path Rack . i,.PIS-B21-2N021A Pressure lndicating Switch 33 749' 1 2-5A-N , 2C004 for CS and AHR (High Drywell Permissive)
PIS-B21-2N021 B Pressure Indicating Switch 30 749' 3 2-SA*N 1 2C005 for CS and AHR (High Drywell Permissive)
'*PS-B21-2N023A Pressure Switch for RPS 33 749' 1 2-5A-N , 2C004 (High Pressure Trip) ... PS-B21-2N023B Pressure Switch for RPS 33 749* 1 2-SA-N 1 2C004 (High Pressure Trip) PS-B21-2N023C Pressure Switch for RPS 30 749' 3 2-5A-N 1 2C005 (High Pressure Trip} PS-821-2N023D Pressure Switch for RPS 30 749' 3 2-SA-N 1 2COOS (High Pressure Trip} .. PT-24201A Wide Range Reactor 30 749' 1 2-SA-N 1 2C225 Pressure Indication PT-242018 Wide Range Reactor-33 749' 3 2-5A-N 1 -2C224 Pressure Indication TB2C004-A1 Terminal box 33 749' 1 2-SA-N 1 2C004 TB2C004-A2 Terminal box 33 749' 1 2-5A-N 1 2C004 TB2C004-B1 Terminal box 33 749' l 2-5A-N 1 2C004 TB2C004-B2 Terminal box 33 749' 1 2-5A-N 1 2C004 TB2C005-A1 Tenninal box 30 749' 3 2-SA-N 1 2C005 TB2C005-A3 Terminal box 30 749' 3 2-5A-N 1 2C005 TB2C005-B1 Terminal box 30 749' 3 2-SA-N 1 2C005 TB2C005-B2 Terminal box 30 749' 3 2-5A-N 1 2C005
* Denotes the. Required Safe Shutdown Components for this Fire Zone.,
* ___ . --..--------*-------FPRR Rev. 11
* Page 2 of 2 
* *
* SSES-FPRR APPENDIX R DEVIATION REQUEST NO. 29 CATEGORY I COMPONENTS AND SAFE SHUTDOWN RACEWAY IN FIRE ZONES 1-3C-W AND 2 .. 3c-w DEVIATION REQUEST: Automatic fire suppression is not required for the protection of redundant safe shutdown components in Fire Zones 1-3C-W and 2-3C-W. Additionally, the 13 feet spatial separation between the two redundant temperature elements in each of these fire zones is adequate to assure that an redundant safe shutdown equipment (i.e. components, cables and raceway) separated by more than 13 feet is free of fire damage for all . postulated fires in these zones. FIRE AREAS/ZONES AFFECTED:
This deviation request applies to Fire Areas R-1 A and R-1 B (Fire Zone 1-3C-W) and R-2A and R-28 (Fire Zone 2-3C-W). These are Wraparound Zones as defined in Deviation Request No. 4. REASON FOR DEVIATION REQUEST: 10CFR50 Appendix A, Section 111.G.2.b, requ;res separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibte or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area. . Fire Zones 1-3C-W (Unit 1 Reactor Building Elevation 683'w0) and 2-3C-W (Unit 2 Reactor Building Elevation 683'-0) do not have automatic suppression and the redundant trains of safe shutdown equipment and cables in these fire zones are separated by less than ?O feet. Fire detection does not extend completely throughout the fire areas of which these fire zones are a part. This deviation justifies that, even though these aspects of Appendix R Section 111.G.2.b are not f uUy satisfied, there are additional compensating factors which demonstrate
*that the existing configuration provides an equivalent level of assurance to that provided by Appendix R Section 111.G.2.b that safe shutdown can be achieved and maintained.
EXISTING ARRANGEMENT:
Drawing C-213431 shows the raceway and Category l component locations in Fire Zone 1-3C-W and Drawing C-213432 shows the raceway and Category I component locations in Fire Zone 2 .. 3c-w . Rev. 10 DR29-1 G:\Uc Oocs\FPRR Approved\Deviations\tpcC0700_29.doc SSES-FPRR The fallowing Category I components located in these fire zones are included in this deviatio~
request: Division I Division II Spatial Component Component Component Separation Description Unit 1 HV-E11-1 F048A HV-E11 *1 F048B 64 ft. AHR Heat Exch. Bypass Valve HV-E11-1 F015A HV-E11-1 F015B 33 ft. AHR Inboard Isolation Valve TE-E11-1N027A TE-E 11-1 N027B 13 ft. RHR Heat Exch. Outlet Temp. Element HV-E11-1 F009 HV-E11-1 FOOS N/A AHR SOC Outboard Isolation
{Not in this Fire Zone) Valve Unit 2 HV-E11-2F048A HV-E11-2F048B 64 ft. AHR Heat Exch. Bvoass Valve HV-E11-2F015A HV-E11-2F015B 35 ft. AHR Inboard Isolation Valve TE-E 11-2N027 A TE-E 11-2N027B 13 ft. AHR Heat Exch. Outlet Temp. Element HV-E11-2F009 HV-E11-2F008 N/A AHR SOC Outboard Isolation
{Not in this Fire Zone) Valve All of the affected components and raceway are located in a controlled radiation area where transient combustibles are minimized due to limited accessibility within the room. The redundant safe shutdown components and raceway contained in these fire zones are shown on drawing C213431 sheet 1 for Fire Zone 1-3c .. w and C213432 sheet 1 for Fire Zone 2-3C-W. The combustible loading for both of these rooms is relatively low and there are no intervening combustibles in the 13 ft. distance between the two redundant temperature elements.
These fire zones have fire detection but do not have an automatic suppression system. POTENTIAL SAFE SHUTDOWN IMPACTS: Tables 1.0 and 2.0 list the non-fire protected safe shutdown raceway in Fire Zones 1-3C-W and 2-3C-W, respectively.*
For each raceway, the safe shutdown components that could be affected should a tire damage the circuits contained fn the raceway are also provided along with an assessment of the worst case impact for each component.
Cable faults are evaluated for the effects of hot shorts, open circuits and shorts to ground. The effects of associated circuits, including spurious operations, breaker coordination and multiple high impedance faults are also evaluated.
The information compiled in these tables is later used in conjunction with the raceway layout information on the attached drawings in the justification section of this deviation request under the heading of "Physical Separation of Redundant Safe Shutdown Functions 11
* Rev .. 10 DR29-2 G:\Uc Oocs\FPRR Approved\Deviations\fpd_0700_29.doc
* * * 
* *
* SSES .. FPRR Circuits which are contained in non-fire protected raceways in Fire Zone 1-3C-W and which provide control or power to components required in support of safe shutdown in this fire zone are identified in Table 1.0 below. Table 1.0 Control and Power Circuits for Safe Shutdown Compon~nts In non-fire protected raceway in Fire Zone 1*3C-W Raceway No. SSD Div. Affected Component Impact Assessment Control & Instrument Circuits E1KH18".'21 Div. I AHR 1 F009 Valve Spurious Valve Opening<1> AHR 1F015A Valve Loss of Valve Control AHR 1 F048A Valve Loss of Valve Control E1K385 Div. I AHR 1 F04SA Valve Loss of Valve Control E1K2L4 Div. I AHR 1 F009 Valve Loss of Valve Contro1<2} E1M209 Div. t TE-E11-1 N027 A Loss of Function CKT1Y11505/1Y21620 No lmpacVSRU Isolates F1KH50-54 Div. JI AHA 1 FOOS Valve Loss of Valve Control AHR 1F015B Valve Loss of Valve Control AHR 1F017B Valve Spurious Valve Operation AHR 1 F048B Valve Loss of Valve Control F1KH61-63 Div. It AHR 1F015B Valve Loss of Valve Control AHR 1 F017B Valve Spurious Valve Operation AHR 1 F048B Valve Loss of Valve Control F1K388 Div. n AHA 1 FOOS Valve Loss of Valve Control F1K395 Div. II AHR 1 F048B Valve Loss of Valve Control F1M068 Div. II TE-E11-1027B Loss of Function CKT1Y12505/1 Y22623 No lmpacVSRU Isolates 111 Cable EK103016M is in cable tray E1KH18and a hot short on this cable could spuriously open the 1F009 valve. cable Tray E1KH18, however, is outside of ttae 50 foot distance defined to be part of the wraparound area . a> A hot short could cause the spurious opening of this valve. except that the cable is routed In a dedicated conduit with no other energized circuits.
Rev. 10 DR29-3 _ G :\Lie Oocs\FPRR ApprO\fed\DeViations\fpd_0700_29.doc SSES-FPRR
* Table .1.0 Control and Power Circuits for Safe Shutdown Components in non-fire protected raceway In.Fire Zone 1-3C*W Raceway No. SSD Dfv. Affected Component Impact Assessment Power to RHR Valves & Other Equipment E1PH18 .. 21 Div. r 1B219 (AHR 15A& 7A) Loss of Power to Valves 1 B237 (See Table 1.0a) Loss of Power to Equipment AHA 1F015A Valve Loss of Power to Valve AHR 1F048A Valve Loss of Power to Valve E1P364 . Div. I AHR 1 F048A Valve Loss of Power to Valve 18237 (See Table 1.0a) Loss of Power to Equipment E1P368&. Div. I 1B219 (RHR 15A & 7A) Loss of Power to Valves JB 0446 RHR 1 F015A Valve Loss of Power to Vafve E1P372 Div. I 18219 (AHR 15A & 7A) Loss of Power to Valves AHR 1F015A Valve Loss of Power to Valve
* F1 PHS0-55
* Div. II AHR 1F008 Valve Spurious Valve Opening AHR 1F0178 Valve Loss of Power to Valve AHR 1 F0488 Valve Loss of Power to Valve 1 D274 (See Table 1.0b) Loss of Power to Equipment F1P023 Div. II 16229 (AHR 78 & 15B} Loss of Power to Valves AHR 1 F015B Valve Loss of Power to Valve F1P364 & Div. n RHR 1F017B Valve Loss of Power to Valve JB 0311 AHR 1 F048B Valve Loss of Power to Valve F1P368 Div. II RHR 1F048B Valve Loss of Power to Valve F1P408 Div. II AHR 1F048B Valve Loss of Power to Valve F1P510 & Div. II AHR FOOS Valve Spurious Valve Opening JB 3946 1 027 4 (See Table 1.0b) Loss of Power to Equipment F1 P511 Div. Ir AHR FOOS Valve Spurious Valve Opening 10274 (See Table 1.0b) Loss of Power to Equipment
* Rev. 10 DR29-4 . G:\Lic Docs\FPRA Approved'peviations\Jpd_0700_29.doc 
* *
* SSES-FPRR The following table provides information related to the impacts to equipment powered from 18237: Tabfe 1.0a -Components Powered from 18237 Comp. ID Comp. Description Comments HV-11210A RHRSW Heat Exch. Inlet Valve normally closed/required open HV. .. 11215A RHRSW Heat Exch. Outlet Valve normally closed/required open HV-15766 Supp. Pool Flow Div. Valve normally closed/required closed HV-E11-1 F103A RHR Heat Exch. A Vent Valve not required for SSD HV-E11-1 F075A RHR/RHRSW Cross Tie lso. VaJve not required for SSD HV-E11-1 F024A RHR SPC Return Valve normally closed/required open HV-E11-1F006C AHR SDC Suction Valve normally closed/required closed HV-E11-1F004C AHR Supp. Pool Pump Suction not required for SSD HV-E11-1 F048A AHR Heat Exch. Bypass Valve nonnally open/required closed . . HV-831-1 F023A Rx. Recirc. Pump Suction Valve not required for SSD in this area 1V208B RCIC Pump *Rm. Unit Cooler B not required for SSD in this area 1V211C CS Pump Rm. Unit Cooler C not required for SSD 1V210C AHR Pump Rm. Unit Cooler C not required for SSD HV-B21-1 F016 MSL Drain lso. Valve nonnally open/required closed HV-E11-1 F022 AHR Head Spray Valve not required for SSD HV-E21~1 F015A. CS Full Flow Test Valve nonnally closed/required closed HV-E41-1 F002 HPC1 Stm Supply Cont. lso. Valve not required for SSD in this area 1P2108 RBCCW PumpB not required for SSD Rev. 10 DR29*5 G:~ Oocs\FPRR Approved\De\llations\tpd_0700_29.doc SSES-FPRR The following table provides infonnation related to the impacts to equipment powered
* from 1 D274: Table 1.0b-Components Powered from 10274 Comp. ID Comp. Description Comments HV-15768 Supp. Pool Flow Div. Valve normally closed/required closed 1P216 HPCI Vac. Tk. Cond. Pump not used for SSD HV-E41-1F066 HPCI Turb. Exh./Supp.
Pool not used for SSD in this area 1P213 HPCI Aux. Oil Pump not used for SSD in this area HV-B21-1 F019 MSL Drain Isa.Valve need to close this or 1 F016 HV-G33-1 F004 RWCU lso. Valve need to close this or 1 F001 1P215 HPCI Bar. Cond. Vac. Pump not used for SSD HV-E11-1F023 RHR Head Spray normally closed/not used for SSD 1
* HV-E11-1 F049 AHR Letdown to LRW/Cond.
nonnally closed/not used for SSD HV-E11-1 FOOS AHR SOC lso. Valve normally closed/required closed
* HV-E41-1 FOOS HPCI Test to CST
* not used for SSD in this area HV-E41 *1 F007 HPCI Pump Disch. Valve not used for SSD in this area
* Rev. 10 DR29-6 " G:\Uc Docs\FPAR Approved\Deviations\fpd_0700_29.doc 
* *
* SSES-FPAR Circuits which are contained in non-fire protected raceways in Fire Zone 2-30-W and which provide control or power to components required in support of safe shutdown in this fire zone are identified in Table 2.0 below. Table 2.0 Control a~d Power Circuits for Safe Shutdown Components in non-fire protected raceway in Fire Zone 2 .. 3c.w Raceway No. SSD Div. Affected Component Impact Assessment . Control & Instrumentation Circuits E2KH22-25 Div. I ESWS Pump OP504C Loss of Pump Control RWCU 2F001 Valve. Spurious Valve Opening AHR 2F009 Valve Spurious Valve Opening AHR 2F015A Valve Loss of Valve Control AHR 2F017A Valve Loss of Valve Control AHR 2F048A Valve Loss of Valve Control E2M125 Div. I TE*E11-2N027 A Loss of Function CKT2Y11505/2Y21620 No Impact/SAU Isolates E2M098 Orv. I Div. I SPOTMOS Loss of Function F2KH32-37 Div. II RHR 2F0488 Valve Loss of Valve Control Div. 11 ADS Logic Loss of Div. II Control AHR 2F008 Valve Loss of Valve Control AHR 2F015B Valve Loss of Valve Control AHR 2F017B Valve Loss of Valve Control F2KH61 .. 62 Div. II RHR 2F0488 Valve Loss of Valve Control RHR 2F0158 Valve Loss of Valve Control RHR 2F017B Valve Loss of Valve Control F2K096 Div. II RHR 2F008 Valve Loss of Valve Control F2K111 Div. II AHR 2F048B Valve Loss of Valve Control F2K622 Div. II RHR2F048B Valve Loss of Valve Control F2M077 Div. II TE*E11 .. 2N027B Loss of Function CKT2Y12505/2Y22623 No Impact/SAU Isolates Rev. 10 DR29-7 G:\Uc Docs\FPRR Approved\Deviaticns\fpcC0700_29.doc SSES-FPAR
* Table 2.0 Control and Power Circuits for Safe Shutdown Components in non-fire protected raceway in Fire Zone 2-3C-W Ra~eway No. SSD Div. Affected Component
* Impact Assessment I Power to RHR Valves & Other Equipment E2PH22-25 Div. I RHR 2F048A Valve Loss of Power to Valve AHR 2F01 SA Valve Loss of Power to Valve AHR 2F017 A Valve Loss of Power to Valve 28219 (AHR 7A & 15A) Loss of Power to Valves 28237 {See Table 2.0a) Loss of Power to Equipment E2P181/182
& Div. I RHR 2F015A Valve Loss of Power to Valve JB 1957 28219 (RHR 7A & 15A) Loss of Power to Valves F2PH32-37 Div. ti AHR 2F008 Valve Spurious Valve Opening AHR 2F0158 Valve Loss of Power to Valve RHR 2F017B Valve Loss of Power to Valve
* RHR 2F0488 Valve Loss of Power to Valve 28229 (AHR 158 & 7B) Loss of Po'!"er to Valves 2D274 (See Table 2.0b) Loss of Power to Equipment F2P086 Div. fl AHR 2F008 Valve Spurious Valve Opening 2D274 (See Table 2.0b) Loss of Power to Equipment F2P087 & Div. IJ AHR 2F0178 Valve Loss of Power to Valve JB 1978 AHR 2F0488 Valve Loss of Power to Valve F2P089 Dtv. II AHR 2F048B Valve Loss of Power to Valve F2P092. Div. II AHR 2F048B Valve Loss of Power to Valve F2P094 Div. U AHR 2F015B Valve Loss of Power to Valve 28229 (RHR 159 & 78) Loss of Power to Vatves
* Rev. 10 DR29-8 G;\Uc Docs\FPRR Approved\DeViations\fpd_0700_29.doc 
* *
* SSES-FPRR The following table provides information related to the impacts to equipment powered from 28237: Table 2.0a -Components Powered from 28237 Comp. ID Comp. Description Comments HV-21210A RHRSW Heat Exch. Inlet Valve normally closed/required open HV-21215A RHRSW Heat Exch. Outlet Valve normally closed/required open HV-25766 Supp. Pool Flow Div. Valve nonnally closed/required closed HV-E11-2F103A AHR Heat Exch. A Vent Valve not required for SSD HV-E11-2F075A AHR/AHASW pross Tie lso. Valve not required for SSD HV-E11-2F024A AHR SPC Return Valve normally closed/required open. HV-E11-2F006C AHR SOC Suction Valve nonnally dosed/required closed HV-E11-2F004C AHR Supp. Pool Pump Suction not required for SSD HV-E11-2F048A AHR Heat Exch. Bypass Valve normally open/required closed HV-B31-2F023A Rx. Recirc. Pump Suction Valve not required for SSD in this area 2V2088 RCIC Pump Rm. Unit Cooler B not required for SSD in this area 2V211C CS Pump Rm. Unit Cooler C not required for SSD 2V210C RHR Pump Rm. Unit Cooler C not required for SSD HV-821-2F016 MSL Drain lso. Valve nomially open/required closed HV-E11-2F022 AHR Head Spray Valve not required for SSD HV-E21 *2F015A CS Full Flow Test Valve normally closed/required closed HV-E41-2F002 HPCI Stm Supply Cont. lso. Valve not required for SSD in this area 2F116A/8 Instrument Air Dryer Towers not required for SSD Rev. 10 DR29*9 G :\Uc Oocs\FPRR Approved\Deviations\tpd_0700_29 .doc SSES-FPRR The fallowing table provides information related to the impacts to equipment powered from 2D274: ** Table 2.0b -Components Powered from 2D274 I Comp. ID Comp. Description Comments HV-25768 Supp. Pool Flow Div. Valve normally closed/required closed 2P216 HPCI Vac. Tk. Cond. Pump not used for SSD HV-E41-2F066 HPCI Turb. Exh./Supp.
Pool not used for SSD in this area 2P213 HPCI Aux. Oil Pump not used for SSD in this area HV-821-2F019 MSL Drain lso.Valve need to close this or 2F016 HV-G33-2F004 RWCU lso. Valve need to close this or 2F001 2P215 HPCI Bar. Cond. Vac. Pump not used for SSD HV-E11-2F023 R~R rtead Spray nonnally closed/not used for SSD HV-E11-2F049 AHR Letdown to LRW/Cond.
nomiaUy closed/not used for SSD HV-E11-2F008 . AHR SOC lso. Valve nonnally closed/required closed HV-E41-2F00S HPCI Test to CST not used for SSD in this area ..I I ! HV-E41-2F007 HPCI Pump Disch. Valve not used for SSD in this area JUSTIFICATION:
Fire Zones 1-3C-W and 2-3C-W are similar in physical layout including raceway layout and, with the exception of the abandoned in place Thermo*Lag 330-1 material in Fire Zone 2-3C-W, combustible loading. Where the differences are pronounced, the features of each fire zone are described separately.
Otherwise, the description provided is the limiting condition which bounds both fire zones. Fire Zones 1-3C-W and 2-3C-W are 11 wraparound zones 11 which, as described in Deviation Request (DR) No. 4, function to provide separation between Fire Areas A*1A and R-1 Band Fire Areas R-2A and R .. 28, respectively.
Fire Areas R-1A and R-2A rely on Safe Shutdown Path No. 3. Fire Areas R-1 B and R-28 rely on Safe Shutdown Path No. 1. In Deviation Request No. 4, it is stated that both safe shutdown paths are protected in* t~e 11 wraparound area 11 unless a deviation is provided which specif icaUy justifies the existing conditions.
Due to the unique attributes of Fire Zones 1-3C-W aJid 2-3C-W, as described below, this deviation justifies a condition different than that described in Deviation*-
Request No. 4.
* Rev. 10 DR29-10 G:\Uc Docs\FPRA Approved\Devtations\fpcl_0700_29.doc 
* *
* SSES-FPRR Physical Separation of Redundant Safe Shutdown Functions:
Deviation Request No. 29 was previously evaluated in SAIC TAC No. 59647/48 attached to the NRC SER dated August 9, 1989 which accepted and granted the deviation.
In performing the evaluation of the initial issue of DR No. 29, it was concluded that the instaUation of automatic suppression and the separation of the temperature elements by more than 13 feet would not significantly increase the level of plant fire safety. This conclusion was based on the fact that there are no intervening
* combustibles in the 13 foot distance between the temperature elements, the area is a high radiation area with limited access, the combustible loading in the area is low and there is a lack of an ignition source. Finally, the area is protected with fire detection and contains manual fire fighting equipment.
This change to DR No. 29 does not alter any of these conditions of the initial issue of the DR, but only provides additional information
~.m the potential impacts to the redundant safe shutdown trains and additional justification on the acceptability of this condition.
All redundant components and raceway in Fire Zones 1-3C-W and 2*3C .. w are separated by at least 20 feet, except for those associated with the AHR Heat Exchanger Outlet Temperatu*re Elements.
Fire Zone 1-3C-W: As shown on Drawing C21343.1 Sheet 1, all unprotected redundant safe shutdown components and raceway are separated by at least 20 feet except for the AHR Heat Exchanger Outlet Temperature Elements, TE .. E11-1N027A and TE-E1-1N027Bt and raceway E1 M209 which contains the instrument cable for TE-E11
* 1 N027 A, F1 M068, which contains the instrument cable for TE-E11-1 N027B, and E1 P368, E1 P372 and JB0446, which contain power cables affecting the power feeds to the AHR LPCI Injection Inboard Containment Isolation Valve, 1 F015A and the RHR Pump Min. Flow Valve, 1 F007 A. In the unlikely event that a fire were to impact all of these components and raceway, the ~orst case result would be a loss of the t~mperature reading on the AHR Heat Exchanger Outlet Temperature and a loss of power to the certain RHR System Valves with the following result: TE-E11-1 N027 A and B, the AHR Heat Exchanger Outlet Temperature Elements, provide an indication to the Control Room of the temperature of the water leaving the AHR Heat Exchanger.
For safe shutdown in this area, RHR is used in the Suppression Pool Cooling mode of operation.
Therefore, the temperature reading from these temperature elements would be an indication of the temperature of the water returning to the Suppression Pool. When using AHR in the Suppression Pool Cooling mode, these temperature elements are only a back-up to the Suppression Pool Temperature Monitoring System (SPOTMOS).
For a fire in Fire Zone 1-3C-W, there is no impact to either of the redundant trains of SPOTMOS. Therefore, SPOTMOS will be available to provide infonnation on Rev. 10 DR29-11 G:\Uc Oocs\FPRR Approved\Deviations\fpd_0700_29.doC SSES-FPRR the Suppression Pool temperature to the plant Controf Room operator and the reading from TE-E11-1N027A and Bis not required to support safe shutdown.
1 F007 A, the Loop A AHR Pump Minimum Flow Valve, is initially required to be open and then close when the AHR Pump flow increases to an acceptable level. A loss of power would result in the failure of this valve to close. This failure, however, will not impact the ability to achieve and maintain safe shutdown.
The flow capacity of one AHR Pump is approximat~ly 12,000 gpm. The flow diversion through an open minimum flow valve is approximately 1 ,000 gpm. Any flow diversion through the 1 F007A Valve would be returned to the Suppression Pool. The AHR flow through the AHR Heat Exchanger is to be limited to less than. 10,000 gpm. Even with the postulated flow diversion, the AHR flow would need to be throttled back and, therefore, adequate flow through the heat exchanger would still be available.
1 F015A, the AHR LPCI Injection Inboard Containment Isolation Valve, is normally closed and is required to be closed in support of safe shutdown.
A loss of power to this valve would result in it remaining in the closed position.
The assessments provided above use the assumption from Calculation EC-013-0843 that at fire onset, all safe shutdown systems are assumed operable and available for post-fire shutdown.
This assumption requires that all safe shutdown components are initially in their normal position.
Therefore, there is no impact to safe shutdown as a result of fire damage to those components or raceway within Fire Zone 1-3C-W that are separated by less than 20 feet.' Fire Zone 2-3C-W: As shown on Drawing C213432 Sheet 1, au unprotected redundant safe shutdown components and raceway are separated by at least 20 feet except for the AHR Heat Exchanger Outlet Temperature Elements, TE-E11-2N027A and TE-E11-2N027B, and raceway E2M 125, which contains the instrument cable for TE*E11-2N027 A, F2MOn, which contains the instrument cable for TE-E11-2N027B, and E2P181, E2P182 and JB1957, which contain power cables affecting the power feeds to the RHR LPCJ Injection Inboard Containment Isolation Valve, 2F015A, and the RHR Pump Min. Flow Valve, 2F007 A. In the unlikely event that a fire were to* impact all of these components and raceway, the worst case result would be a loss of the temperature reading on *the AHR Heat Exchanger Outlet Temperature and a loss of power to the certain RHR System Valves with the following result TE-E11-2N027A and B, the AHR Heat Exchanger Outlet Temperature Elements, provide an indication to the Control Room of the temperature of the water leaving the AHR Heat Exchanger.
For safe shutdown in this area, RHR is used in the Suppression Pool Cooling mode of operation.
Therefore, the t~mperature
** reading from these temperature elements would be an indication of the
* temperature of the water returning to the Suppression Pool. When using AHR in Rev. 10 DR29-12 G:\L.ic Docs\FPRR ApprQVed\OevlaUons\fpd_0700_29.doc 
* **
* SSES-FPAR the Suppression Pool Cooling mode, these temperature
~lements are only a back-up to the Suppression Pool Temperature Monitoring System (SPOTMOS).
For a fire in Fire Zone 2-3C*W, there is no impact to Division II of SPOTMOS. Therefore, Division 11 of SPOTMOS will be available to provide information on the Suppression Pool temperature to the plant Control Room operator and the reading from TE*E11-2N027A and Bis not required to support safe shutdown.
2F007 A the Loop A RHR Pump Minimum Flow Valve, is initially required to be open and then close when the AHR Pump flow increases to an acceptable level. A loss of power would result in the failure of this valve to close. This failuret however, will not impact the ability to achieve and maintain safe shutdown.
The flow capacity of one AHR Pump is approximately 12,000 gpm. The flow diversion through an open minimum flow valve is approximately 1,000 gpm. Any flow diversion through the 2F007A Valve would be returned to the Suppression Pool. The RHR flow through the AHR Heat Exchanger is to be limited to less than 10,000 gpm. Even with the postulated flow diversion, the AHR flow would need to be throttled back and, therefore, adequate flow through the heat exchanger would still be available.
2F015A, the AHR LPCI Injection Inboard Containment Isolation Valve, is normally closed and is required to be closed in support of safe shutdown.
A loss of power to this valve would result in it remaining in the closed position .
* The assessments provided above use the assumption from Calculation EC-013-0843 that at fire onset, all safe shutdown systems are assumed operable and available for post-fire shutdown.
This assumption requires that all safe shutdown components are initially in their normal position.
Therefore, there is no impact to safe shutdown as a result of fire damage to those components or raceway within Fire Zone 2-3C-W that are separated by less than 20 feet. In-situ and Intervening Combustibles:
The only in~situ combustibles in these fire zones are cables in enclosed cable trays and, in Fire Zone 2-3C-W only, abandoried*in*place Thermo-Lag 330-1 raceway wrap. Due to the low level of in-situ combustibles in Fire Zone 2-3C-W, other than the abandoned Thermo-Lag 330-1 materiat, insufficient combustibles exist to involve the abandoned Thermo-Lag 330* 1 material and, therefore, this abandoned Thermo-Lag does not . represent a fire hazard of concern. Fire Zones 1-3C-W and 2-3C-W are radiation areas and are located in rooms with limited accessibility due to the physical layout and radiological conditions.
Due to the limited accessi~ility of the rooms, the potential for the introduction of transient combustible~
is remote. Additionally, both fire zones are provided with a fire detection system.
* The redundant AHR Heat Exchanger Outlet Temperat~.re Elements are separated by a distance of 13 feet with no intervening combustibles.
All other redundant safe shutdown components are separated by greater distances with most being separated by more Rev. 10 DR29-13 G:\Uc Docs\FPRR Approved\Oeviations\fpd_0700_29.doc SSES-FPRR than 20 feet. Due to the presence of fire detection, the low amount of in-situ combustibles, and the limited potential for the introduction of transient combustibles into this area, this separation distance is considered to be sufficient to preclude damage to redundant safe shutdown components and raceway. Administrative Controls:
The floor area between the redundant safe shutdown raceway is identified to indicate that it is a restricted area for storage of transient combustible materials.
No transient combustible materials will be stored in this area without the review and acceptance of the Site Fire Protection Engineer.
Fire Protection Features:
Both Fire Zones 1-3C-W and 2-3C-W are provid_ed with fire detection.
 
==SUMMARY==
AND CONCLUSION:
The configuration of the redundant safe shutdown components and raceway, the low quantity of combustibles, the limited access to this plant area and the administrative controls on transient combustible storage along with the presence of fire detection ensure that a fire will not damage the redundant safe shutdown components and raceway in these fire zones. Therefore, the separation distance of 13 feet between the redundant temperature elements in these fire zones is adequate to ensure that a fire will not adversely affect the ability to achieve and maintain safe shutdown without any additional fire protection features in the form of qualified raceway fire barriers or automatic fire suppression systems. Rev. 10 DR29-14 G:\Uc: Docs\FPRR Approved\DeviatioRS\fpd_0700_29.doc
-. ----~--i * * **
Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Security-Related Information Figure Withheld Under 10 CFR 2.390
 
SSES-FPRR
* DEVIATION REQUEST NO. 30 HAS BEEN WITHDRAWN
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* Rev. 10 G:\Uc Docs\FPRR Approve:d\Deviations\fpd_0700_31.doc SSES-FPRR Text Rev. 11 APPENDIX R DEVIATJON REQUEST NO. 32 OUTSIDE AREAS LACK OF SEPARATION OF SAFE SHUTDOWN COMPONENTS AND ELECTRICAL CABLES DEVIATION REQUEST: The existing installation (location) of certain safe shutdown electrical cables in underground manholes and duct banks and components located in o~tside areas is considered acceptable.
FIRE AREAS/ZONES AFFECTED:
This deviation request appltes to Fire Area A-1 (Fire Zone 0-00). REASON FOR DEVIATION REQUEST: 1 OCFR50, Appendix Rt Section 111.G.2.b requires that the redundant trains of cables and equipment required for safe shutdown be separated by a minimum distance of 20 feet with no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shaH be installed in the fire area. The fire hazards analysis for the outside areas has identified redundant safe shutdown electrical cables located in underground electrical manholes and safe shutdown components which are not separated by 20 feet and do not have fire detection or automatic suppression.
EXISTING CONDITIONS:
Electrical Manholes Class IE electrical manho!es 16,17,18,19,22,23,27,28,31 and 32 and their connecting duct banks contain safe shutdown cables. These manholes were located and plotted on Drawing C-213439.
Electrical manholes i 6, i 7, 18 and 19 are located east of the underground diesel generator fuel oil tanks at a distance greater than 25 feet. Electrical manholes 22 and 23 are located along the east to west access road adjacent to the Service and Administration Buildfng at a distance of 25 feet or more from either the building or road. Electric manholes 27 and 28 are rocated northeast of the Unit 2 Cooling Tower and southwest of the plant access road to the Emergency Safeguard Service Water pumphouse at a distance in excess of 25 feet. The tops of manholes 27 and 28 extend above a mound of earth that is at leas1 6 feet above the road. Electrical manholes 31 and 32 are located adjacent to the south wall of the ESSW Pumphouse.
FPRR Rev. 11 SSES-FPRR Text Rev. 11 Emergency Diesel Generator Fuel Oil Storage Tank Transfer Pumps The four diesel generator fuel oil storage tank transfer pumps (OP514At OP514B, OP514C and OP514D) which are required for SSD are submerged inside the diesel fuel oil tanks. RHR Service Water Spray Pond Valves Six RHR Service Water Spray Pond Valves are located in the spray pond valve vautt. The Division I valves (HV-01222A, HV-01222A 1, and HV-01222A2) are located in the north compartment of the valve vault structure and the Division II valves (HV-012228, HV-0122281 and HV-0122282}
are located in the south compartment of the structure.
JUSTIFICATION:
A Fire Hazards Analysis was conducted for the electrical manholes and the safe shutdown components located in the Outside Areas and it was concluded that no plausibfe fire hazards exist which affect safe shutdown.
The electrical manholes are seismically designed and constructed to be watertight concrete boxes which would res~st the in-leakage of any combustible oils that might be present. In all cases, the manholes extended twelve (12) inches above grade and are seismically designed and constructed with walls, tops and bottoms of reinforced concrete with a minimum thickness of six (6) inches. The conduit ductbank penetrations are installed prior to pour and are an integrat part of the manholes.
The affected manholes are separated by a distance of 100 ft. from any in situ combustibles (ESS transformers) and greater than 25 ft. from the underground diesel generator fuel oil tanks. The transient combustibles such as transferring fuel oil from tanker trucks to the diesel generator fuel storage tanks and the delivery of the lube oil truck to the Turbine Building were analyzed in the Fire Hazards Analysis.
In each case, a ffre hazard which could jeopardize safe shutdown was found not to exist. Therefore, it is our position that the location and configuration of the subject electrical manholes and their assoc_iated safe shutdown cables provide an equivalent degree of safety as specified in 10CFR50, Appendix R, Section 111.G.2. The fuel oil transfer pumps are submerged inside the fuel oil tanks. The electrical cables are totally enclosed in rigtd steel conduit and located in a vault above the diesel generator tanks. The vault is seismicatly designed and constructed and has a missile protective cover. The operating consrderations, protective cover construction and lack of an ignition source provide acceptable fire protection, equivalent to the technical requirements of Appendix A, Section 111.G.2. The six AHR service water spray pond valves are located in a valve pit. Division I valves are separated from the Division 2 valves by a~ 8 inch thick concrete wall. There FPRR Rev. 11 DR32-2 SSES-FPRR Text Rev. 11 is one, three-hour rated penetration between compartments.
The valve pit construction, the routing of all safe shutdown cables in conduit and the lack of in-situ combustibles in the vicinity of the valve pits provides acceptable fire protection and provides protection equivalent to the technical requirements of Appendix RI Section 111.G.2. FPRR Rev. 11 DR32-3 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
SSES-FPRR Text Rev. 11 APPENDIX R DEVIATION REQUEST NO .. 33 REACTOR COOLANT MAKEUP AND DEPRESSUAJZATfON SYSTEMS DEVIATION REQUEST: A deviation from the guidance of Appendix R to 1 OCFA50 is required since reactor coolant process variables may vary from those predicted for a loss of normal ac power when accomplishing safe shutdown at Susquehanna Steam Electric Station. Core Spray/ADS is used to achieve safe shutdown in the event of fires outside of the Control Room. RHR in the alternate shutdown cooling mode accompanied by the SRVs for depressurization is used in the event of a fire in the Control Room that damages certain Motor Operated Valves (MOVs) on the Remote Shutdown Panel. Appendix R Section UI.L.1 that is applicable to Alternative Safe Shutdown contains the requirement related to process variables.
This guidance is afso contained in NRC Generic Letter 84-09 Attachment 1 Section V for Redundant Safe Shutdown and Section VIII for Alternative Safe Shutdown.
FIRE AREAS/ZONES AFFECTED:
This deviation request applies to all plant fire areas. REASON FOR DEVIATION REQUEST: Alternative Safe Shutdown is governed by the requirements of Appendix R Section 111.G.3 and 111.L. Appendix R Section IILL.1 states that the reactor coolant process variables shall be maintained within those predicted for a loss of normal ac power. This deviation addresses the fact that when using ADS SRVs and AHR for Alternative fire safe shutdown, the reactor coolant process variables may vary from those predicted for a loss of normal ac power. For Redundant Safe Shutdown governed by the requirements of Appendix R Sections 111.G.1 and 2, there are no specific requirements relative to safe shutdown methodology.
The Guidance in NRG Generic Letter 84-09, however, does contain words similar to the words contained in Appendix R Section 111.L.1. Therefore, this deviation addresses a
* variance from the guidance contained in NRC Generic Letter 84-09 relative to the use of ADS SRVs and Core Spray. The meaning of the requirement" that process variables be no worse than for a loss of normal ac power is not clearly defined within the body of the regulations.
This deviation requests demonstrates that even with a conservative interpretation of the requirement, the safe shutdown methodology used at the Susquehanna Steam Electric Station is acceptable because it satisfies the performance goals established by the regulations.
FPRR Rev. 11 DR33-1 SSES-FPRR Text Rev. 11 The reason that these systems were chosen is that they are clearly sep~rated on an Electrical Divisional basis. A clear separation of paths ensures that long-term compliance can be maintained with a minimum of complexity.
Still another reason that they were chosen is that the systems are composed of 11 0uality ReJated 11 or 11 0 11 components.
Since these components are closely tracked from design specification 1 through purchase and actual installation, long-term compliance is again ensured.*
EXISTING CONDITIONS:
The reactor depressurization function utilizing ADS with low pressure makeup systems is discussed in FSAR Section 15.2.9. The reactor heat removal process utilizing alternate shutdown cooling with suppression pool cooling is discussed in FSAR Section 15.2.9 and Table 15.E.2.9-1.
More specifically to PPL's Appendix R analysis, reactor coolant makeup is provided by different divisions of core spray while the reactor depressurization function is provided by the ADS valves. Also, the reactor heat removal _process utilizes alternate shutdown cooling with suppression pool cooling. Alternate shutdown cooling utilizes the core spray and ADS systems. To enter alternate shutdown cooling, the reactor head vents, the MSIVs, and main steam line drain lines must all be closed. Six safety relief valves are opened and one core spray pump taking a suction from the suppression pool slowly increases reactor water level. T11e suppression pool cooling mode of RHR is initiated, and the reactor water level is slowly raised to about 131 11 to flood the matn steam lines and establish a flow path through the open SRVs and back to the suppression pool._ Discussion of LOOP and ADS/Core Spray LOOP The toss of offsite power (LOOP) results in a sequence of events similar to that resulting from a toss of feedwater flow. The most severe case occurs during power operation.
The reactor protection system and control rod drive system produce a scram after receiving either a main turbine trip signal or loss of reactor protection system power source signal. The turbine Mp will initia~e a recirculation pump trip. The Main Steam Isolation Valves (MSIVs) close and there is no flow diversion from the reactor vessel. After the MSIVs close, decay heat slowly raises system pressure to the lowest relief valve setting. Core cooling is necessary to restore and maintain water level. HPCI and RCIC initiate at level 2. ADS/Core Spray f n the PPL App~ndix A analysis, water level is maintained using the Core Spray System since RCIC and HPCI are assumed damaged by fire or unavailable.
The Core Spray System is designed to provide cooling to the.reactor core only when the reactor pressure is low. However, when Core Spray is used in conjunction.
* FPRR Rev. 11 DR33":'2
* J, SSES-FPRR Text Rev. 11 with ADS 1 the RPV can be rapidly depressurized by ADS into the pressure range where the Core Spray System can be used for core cooling and RPV water level control. ADS has six manually and. automatically controlled safety relief valves that are installed on the main *steam lines inside the primary containment.
* These six * . valves perform both the ADS and SRV function.
The depressurization by manual or automatic action of the control system is intended to reduce reactor pressure during specific postulated size pipe breaks in which* the HPCI system is not available so that the Core Spray System or AHR LPCI System can inject water into the reactor ves~el. In the Appendix A analysis, no pipe break exists. JUSTIFICATION:
Deviation from LOOP Parameters Manual Actions For the PPL Appendix R analysis, shutdown is achieved utilizing standard, emergency operating procedures where degraded modes can result from any cause incruding a postulated Appendix R fire.
* Although the reactor coolant process variables are not maintained strictly within those predicted tor a loss of off site power (level may go lower than Level 2 and the depressurization rate may be faster), the fission product boundary integrity will not be affected, i.e., there wilt be no fuel cfad damage, rupture of any primary coolant boundary, or rupture of the containment boundary.
The performance goal of the shutdown function will be met, i.e., the reactor coolant makeup function will be capable of rapidly restoring the reactor coolant level and maintaining the reactor coolant level above the top of the core. The other performance goals tor the reactivity control function, the reactor heat removal function, the process monitoring function, and the supporting functions are unaffected.
The acceptability of this shutdown methodology for Appendix R post-fire safe shutdown has been addressed by the Boiling Water Reactor Owner's Group (BWAOG) in GE Nuclear Energy Report No. GE-NE-T43-00002-00-03-R01, BWROG Position on the Use of Safety Relief Va~ves (SRVs) and Low Pressure Systems as Redundant Safe Shutdown Paths. This report was submitted to the NRC for their acceptance in August of 1999. The conclusion of this report is that the use of SRVs and Low Pressure Systems is an acceptable post-fire safe shutdown path meeting the requirements of Appendix R Sections 111.G.1, 111.G.2 and 111.G.3, including 111.L. FPRR Rev. 11 DR33-3 SSES .. FPRR Text Rev. 11 The BWROG.made two additional submittals relative to this issue to address . NRC comments on the initial report. These submittals were included in BWROG Letter Nos. BWROG-00073, dated July 20, 2000, and BWROG-00082, dated September 28, 2000. In a Safety Evaluation Report (SER) dated December 12, 2000, the NRC accepted the position of the BWROG on the use of SRVs and Low Pressure Systems (LPS) for post-fire safe shutdown.
This SER concluded the following:
(1) The use of SRV/LPS meets the requirements of a redundant means of post-fire safe shutdown under Section 111.G.2 of 10 CFR 50 Appendix R. (2) The use of SRV/LPS is also an appropriate means of satisfying Section 111.G.3 of Appendix R. Since the generic evaluations related to this topic in the GE Report are based on the Susquehanna Steam Electric Station plant design and operation!
the conclusions of the NRC in their SER are directly applicable to Susquehanna and constitute an acceptance of this shutdown methodology for Susquehanna.
FPRR Rev. 11 DR33-4 SSES-FPRR
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* DEVIATION REQUEST NO. 36 HAS BEEN WITHDRAWN
*
* Rev. 10 DR36-1 G:\Uc Docs\FPRR Approved\DeviatiOns\fpc:1_0700_36.doc 
* *
* SSES-FPRR APPENDIX R DEVIATION REQUEST NO~ 37 CONTROL ROOM RAISED FLOOR AND CONTROL STRUCTURE CABLE CHASE FIRE PROTECTION DEVIATION REQUEST: Fire protection features for cable routed under the main control room raised floor, in the cable shafts and in the cable chases within the Control Structure are adequate and provide an equivalent degree of safety as that required by Appendix R, Section 111.G.2. FIRE AREAS/ZONES AFFECTED:
The deviation request applies to Fire Areas CS-6 (Fire Zones 0-24J, 0-25B, 0-268, 0-26S, 0-27F and 0-28P), CS-7 {Fire Zones 0-24L, 0-24M, 0*25C, 0-250, 0*26C, 0-260, 0-26T, 0-26V, 0-27G, 0-27H, 0-280 and 0-28R) and CS-9 (Fire Zones 0-26F, Q .. 26G, 0-26H, 0-261, 0-26J, 0-26M and 0-26R) in the Control Structure.
Fire Area CS-6 covers the south cabte chase and CS-7 includes the north and center cable chases. For this Deviation Request, Fire Area cs .. 9 is limited to the area under the main control room, ves1ibules, Operational Support Center and Security Office raised floor and the cable shafts under the control room soffits . REASON FOR DEVIATION REQUEST: 1 OCFR50, Appendix R, Section III.G.2a, band c requires spatial separation or fire barrier-type protection features to separate redundant divisions of systems required for hot shutdown when they are located within the same fire area. Addi1ionally, the specific requirements also include the absence of intervening combustibles and the installation of fire detectors and an automatic fire suppression system in the fire area. Cable routed in raceways under the raised floor of the main control room and adjacent areas include redundant safety-related control and instrumentation circuits.
The underfloor fire area is protected with ionization detectors and a fixed manual spurt fire suppression system. There are no discrete fire barriers between redundant trains and automatic CO2 fire suppression is not provided in this fire area because of safety concerns tor control room personnel.
The cable chases adjacent to the control room in the Control Structure are used for the vertical runs of cable trays, conduits and wireways which route safety-related and non* safety circuits between the control room and the relay rooms and cable spreading areas. Vertical shafts under soffits.within the control room area are similarly used to
* install raceways for conveying cable between the control room and the upper and lower relay rooms. The cable chases are protected with ionization detectors and total flooding CO 2 automatic fire suppression systems. The control room cable shafts are provided Rev. 10 DR37-1 G:\Llc Docs\FPRA Approved\Oeviations\fpc:1_0700_37.doc 
------------
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-**-**--**
-**-*-**-" .. _______ ., ***---* --*----** -SSES-FPRR with ionization detectors and a manual spurt CO 2 fire suppression system. The cable trays and wireways in the cable chases and shafts are not provided with fire barriers to separate redundant divisions within the fire zones. EXISTING CONDITIONS:
The space below the control room raised floor (Fire Zones 0-26F, 0-26G, 0-26H, 0-261 and 0*26J) and above the 13Y2 11 reinforced concrete floor on Elev. 728'-1'' furnishes a convenient means to install raceways for routing cables to various panels, cabinets and equipment in the control room. There are a limited number of cables which pass through but do not terminate in the control room panels. The space is covered by the control room. sectional and flame-retardant carpet access flooring which is supported on -a steel framework independent of the underfloor raceway supports. The raceways consist of cable trays, wireways and conduit containing control instrumentation and small power cables for redundant safety-related and non-safety cables which enter the . bottom of the control room panels. The space u*nder the raised floor covers
* approximately 6,516 square feet, is 12-inches high and is protected by ionization detection and a manual spurt CO 2 fire suppression system activated by pushbutton stations inside and outside the control room. This area is bounded on all sides by rated construction.
Due to the confined space and fire protection features in this area,. fire barriers are not provided between redundant safety-related cables. Automatic CO 2 fire suppression is not provided in this fire area due to the continual presence of control room personnel.*
* The three electrical cable chases in the west wall of the control.room each have approximately 7 feet by 6 feet of open vertical space extending from Elevation 698 1-0 11 to Elevation 783 1-0b in the Control Structure. (See drawings E-205988 through E .. 205993 in Section 8). Each chase is enclosed by fire-rated construction on all sides. The chases contain cable trays, wireways and conduit used for routing redundant safety-related and non-safety circuits from the cable spreading areas to the control room, relay rooms and other areas in the Control Structure.
An automatic total flooding CO 2 fire suppression.
system in conjunction with heat detectors protects the entire length of the cable chase except at the control room floor Elevation 729'* 1 11 (Fire Zones 0-268, 0-26C & 0-26D) where a manual spurt CO2 system with ionization*type combustion detectors is installed. The chases are also provided with barriers and seals at every floor elevation which limit air supply and fire spread and control the concentration of carbon dioxide if the fire protection system is activated.
In addition to the cable chases in the west wallt the control room has two cabfe shafts under the north and south soffits (Fire Zones 0-26M & o .. 26R). The cable shafts are basically 1-foot ~ide open spaces along the north and south walls of the control room and are used for vertical runs of trays and wireways for safety .. related and non-safety circuits from the control room to the relay rooms. The cable shafts are enclosed by 3-hour fire-rated concrete walls at the north and south sides of the control room and by 2*hour gypsum board/metal stud walls on the-inside.
Each cable shaft and soffit is Rev. 10 DR37-2 G:\Uc Docs\FPRR Appraved\Deviations\fpd_0700_37 .doc * 
* **
* SSES .. FPRR protected by four ionization
.. type combustion detectors and manual spurt CO2 fire suppression system. JUSTIFICATION:
Appendix R, Section 111.G .2 requires that fire protection features be provided to ensure that one division of redundant components important to safe shutdown is free of fire damage.* When the redundant divisions of safe shutdown systems are located within a common fire area, one of the following features shall be provid_ed:
: 1. 3 .. hour fire barrier. 2. More than 20-feet spatial separation with no intervening combustibles, plus installation of fire detectors and an automatic fire suppression system. 3. Cable and equipment enclosure with a 1-hour fire rating, plus installation of fire detectors and an automatic fire suppression system. The areas under the control room raised floor are.highly confined spaces. The spaces are not nonnally accessible since the control room sectional flooring must be removed to expose the raceway areas. Although redundant safety-related circuits exist tn this area, the horizontally configured raceways consisting of Division I cable trays and wireways and a few Division II conduits are installed in confonnity with minimum electrical separation req&#xb5;irements.
There are no open raceways containing Division II circuits under the raised floor. Division fl conduits vertically enter the bottom of the control room panels from the lower cable spreading area below, which is a different fire area isolated by a 3-hour fire-rated concrete floor and sealed floor penetrations.
The only potential hazards in this fire area are those due to internal faults in the cable and this is mitigated by the fact that the circuits handle only control, instrument and small power functions.
Cables use non-flame propagating Insulation with fire-retardant jackets and are qualified in accordance with IEEE 383. The use of a manual spurt CO2 fire suppression system in conjunction with ionization detection adequately protects the fire area since immediate operator action from the control room directly above is anticipated in the event of a fire. The cable chases and cable shafts in Fire Area CS*6, CS-7 and CS-9 are limited access areas used mainly for the installation of electrical raceways.
The steel doors provided at certain elevations of the south, center and north cable chases are alarmed to monitor unauthorized entry. Where raceways for redundant safety-*related divisions are instalted
*in a chase, the minimum electrical separation is observed.
The use of combustion detectors and a total *flooding CO 2 automatic fire suppression system in most of the cable chase fire zones meets Appendix R, Section lll.G.2 requirements.
The cable chases and cable shafts at the control room elevation are adequately protected by combustion detectors and a manual spurt CO2 fire suppression system because of proximity to the control room where operators can quickly respond to any contingency.
The only combustibles located in these fire areas consist of control and Rev. 10 DR37-3 G:\Lic Docs\FPRR Approved\Oevlattons\fpcL0700_37.doc 
-------------------------------:---------------, SSES-FPRR instrument cables in open trays, which are subject to fire hazards caused by internal.
* faults o~ly. The low probability of inducing fire by sett-ignition is further minimized by the use of non-flame propagating cable insulation which conforms to the requirements of IEEE 383. The fire protection f ea tu res provided under the control room raised floor and the cable chases and cable shafts as described above are adequate for the existing cable installation and provide an*equivalent degree of safety as required by Appendix R. The addition of raceway wrapping and fully automatic fire suppression systems in Fire Areas CS-6, CS-7 and CS-9 to meet the requirements of 1 OCFR50 Appendix R, Section 111.G.2 would not significantty increase the level of fire protection in these fire areas. Rev. 10 DR37-4 G:\Uc Docs\FPRR Approved\Deviations\fpd_0700_37.doc
*
* SSES-FPRR
* Text Rev. 13 APPENDIX R DEVIATION REQUEST NO. 38 PROTECTION OF REDUNDANT SAFE SHUTDOWN RACEWAYS IN THE UNIT 2 MAIN STEAM PIPEWAY DEVIATION REQUEST: It is acceptable to protect redundant safe shutdown cables in raceways E2KJ78, E2KJ79,E2KJ80,E2KJ81,F2K024,F2K409,F2K411,F2K412, F2K413,F2K414, JB3018 and JB 1464 in Fire Zone 2-4G by installing them in conduits, junction boxes or metal enclosed trays. FIRE AREAS/ZONES AFFECTED:
This deviation request applies to Fire Zone 2-4G which is in Fire Area R-2A in the Unit 2 Reactor Building.
REASON FOR DEVIATION REQUEST: 1 OCFRSO Appendix R, Section 111.G.2 requires that redundant safe shutdown cables be protected by a fire barrier having a 3-hour rating in areas where there is no automatic fire suppression system and no fire detection.
EXISTING CONDITONS:
Fire Zone 2-4G is the Main Steam Pipeway. It is a high radiation area and is inaccessible during normal plant operation.
It does not contain automatic fire suppression; however, it does contain fire detection.
All cables are routed in conduits or metal enclosed trays. The combustible loading of the fire zone, not including cables, is *1ess than 5 minutes. This combustible loading is comprised of lube oil contained within various valves in the piping systems in the pipeway. The largest single quantity of oil (8.5 gallons) is used in each of the Feedwater Stop Check Valves HV-241-F032A&B.
Actual in-situ combustible loading durations are provided to document existing arrangement and justify the deviation request. These values are based on the initial combustible loading analysis.
Modifications subsequent to this analysis have revised these values with the possibility of future modifications revising them again. The governing criteria for the combustible loading analysis is that the fire resistance rating of the fire area boundaries exceed the combustible loading duration.
The combustible loading durations specified in the deviation request will not be updated in the future since program commitments require that all modifications be evaluated to assure that FPRR Rev. 12 DR38-1 SSES-FPRR Text Rev. 13 additional combustibles are controlled to remain below the fire area fire resistance rating. Additionally, although Fire Zone 2-4G is contained in Fire Area R-2B, it is bounded on two sides and the floor by 3 hour fire rated construction.
One wall is enclosed by primary containment; fire will neither originate in nor mitigate to the containment due to the inerted nitrogen atmosphere during power operation.
The fourth wall to the west is of concrete construction and steel. The concrete construction is considered three hour rated. There are two steel portions in this wall located at 71 T-3 11 and 799'-1". The lower steel panel is the location of Main Steam Lines penetrations into the Turbine Building.
The upper steel panel is the blowout panel in the event of a High Energy Line Break (HELB) in the MSL Tunnel. Both of these locations have been evaluated and would not adversely effect the ability to safely shutdown the plant in the event of a fire in Fire Zone 2-4G or either adjacent fire zone. The fire zone contains safe shutdown cables for Division I and 11 equipment which are routed in separate raceways within the pipeway. These cables include circuits for the four Division II outboard main steam isolation valves (MSIVs) HV-B21-2F028A, B, C & D and for three of the four Division I inboard MSIVs HV-B21-2F022A, B, & C. All MSIV cables are installed in conduit or metal enclosed cable trays. The outboard MSIVs and their valve operators are physically located in the fire zone; the electrical components are located approximately 10 feet above the enclosed tray containing cables for the redundant inboard MSIVs. A fire hazards analysis has shown that other safe shutdown systems with Division I and II cables in this fire zone would be able to perform their safety functions and would not prevent safe shutdown in the event of a fire in the pipeway. JUSTIFICATION:
Electrical raceways E2KJ78, E2KJ79, E2KJ80 and E2KJ81 containing Division I cables for MSIVs HV-B21-F022A, B & Care totally enclosed metal covered trays. Raceways F2K024, JB1464, F2K409, JB3018, F2K411, F2K412, F2K413 and F2K214 containing Division If cables for MSIVs HV-821-F028A, B, C & Dare rigid steel conduits and junction boxes. These raceways are located in a normally inaccessible high radiation area containing very small quantities of combustible materials.
Raceways E2KJ78, E2KJ79, E2KJ80 and E2KJ81 are single cable trays located approximately 18n below another cable tray which is also totally enclosed.
The orientation of these raceways and the location of the outboard MSIVs are shown on attached Drawings C-213952, Shts. 1 and 2. The location of the combustible materials in Fire Zone 2-4G are also shown on the attached drawings.
In the unlikely event of the ignition of any of the combustibles, the resultant heat release would not impact any of the subject raceways.
The ceiling of Fire Zone 2-4G is at Elevation 760'-7 %", approximately 20 to 25 feet above the raceways.
Any heat generated by a fire would rise to the ceiling level. Furthermore, as shown on FPRR Rev. 12 DR38-2 SSES-FPRR Text Rev. 13 Drawing E-213485, Sht. 1 in Section 8.0 of this report, the steam pipeway actually continues further up from Elevation 760'-7 W' to allow air pressure to escape through blowout panels in the event of a pipe rupture in the steam pipeway. The MSIVs must isolate for safe shutdown.
Failure analysis for the cables of concern indicates that fire-induced hot shorts would have to occur on both the Division I {inboard MSIVs) and Division II (outboard MSIVs) cables to maintain the AC or DC solenoids energized and hold open both redundant MS IVs on a main steam line. Similarly, once the MSIVs have closed, multiple hot shorts on each MSIV's solenoids are required to reopen the valves. The limited quantity of combustible materials in the fire zone and the use of separate metal-enclosed raceways for cable routing-would render these occurrences highly unlikely.
The introduction of transient combustibles into this fire zone is highly unlikely since the fire zone is a high radiation area with its entrance door locked and access prohibited during normal plant operation.
During periods of low power operation or plant shutdown, access is restricted and controlled due to radiological concerns.
Fire Zone 2-4G has fire detection which alarms in the main control room. Although there is no automatic fire suppression system in this fire zone, manual hose reels and portable fire extinguishers are located in the immediate vicinity.
Fire Zone 2-4G is bounded by concrete walls and floor and the primary containment wall within the fire area. There are two steel barriers that supplement the boundary of this fire zone. One steel constructed barrier is located at elevation 717'-3" at column line M. This steel barrier contains the four (4) penetrations for the Main Steam Lines. Additionally, this barrier acts as a blowout panel in the event of a HELB. The combustible loading of adjacent fire zone 2-35C is negligible and does not pose a threat to Fire Zone 2-4G. The second steel constructed barrier is located at elevation 799'-1" which solely acts as a blowout panel to the roof of the turbine building in the event of a HELB. The combustible loading for adjacent Fire Zone 0-00, Outside Areas, has been evaluated and does not present a threat to Fire Zone 2-4G. Therefore, based on the negligible quantity of combustible materials in Fire Zone 2-4G, the location of these combustibles with respect to the raceway in question, the use of totally-enclosed metallic raceways, the unlikely addition of transient combustibles to the pipeway and the enclosure of the fire zone with barriers which have been analyzed to ensure protecton from a fire, including the containment wall, raceways E2KJ78, E2KJ79, E2KJ80 and E2KJ81, F2K024, F2K409, F2K411, F2K412, F2K413, F2K414, JB3018 and JB1464 do not require the protection of a 3-hour fire rated barrier material between redundant divisions.
FPRR Rev. 12 DR38-3 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
Security-Related Information Figure Withheld Under 10 CFR 2.390
 
SSES-FPAR Text Rev. 11 DEVIATION REQUEST NO. 39 HAS BEEN WITHDRAWN FPRR Rev. 11 DR39-1 SSES-FPRR
* THIS PAGE INTENTIONALLY LEFT BLANK *
* Rev. 10 DR40-1 G:\Uc Docs\FPRR Approved\Devlations\,fpd_0700_40.doc SSES-FPRR
* DEVIATION REQUEST NO. 41 HAS BEEN WITHDRAWN
*
* Rev. 10 DA41-1 G:\Lic Docs\FPRR Approved\OevialionsVpd_0700_41.doc 
* *
* SSES-FPRR APPENDIX R DEVIATION REQUEST NO. 42 PROTECTION OF SAFE SHUTDOWN RACEWAY IN FIRE ZONES 1-38-W AND 2-38-W DEVIATION REQUEST: Based on the fire protection features, administrative controls, combustible levels and physical separation distances between redundant safe shutdown functions described in this deviation request, the redundant trains of raceway depicted on drawing C240924 sheet 1 for Fire Zone 1-38-W (Unit 1 Reactor Building Elevation 683'-0) and on drawing C240924 sheet 2 for Fire Zone 2*38-W (Unit 2 Reactor Buif d;ng Elevation 683'~0) do not require protection with a raceway fire barrier even though atl aspects of Appendix R Section 111.G.2.b are not satisfied. . . Exceptions include raceways E1 F132, E1 F137, "C1F033, C1F034, C1F055 and JB0008 in Fire Zone 1-38 .. W and C1F040, C1 F045, C2F030 and JB0013 in Fire Zone 2-3B-W. These raceways are protected with a qualified 1-hour fire barrier. FIRE AREAS/ZONES AFFECTED:
This deviation request applies to Fire Areas R-1A and A-1 B (Fire Zone 1-38-W) and A-2A and R-28 (Fire Zone 2-38-W). These are Wraparound Zones as defined in Deviation Request No. 4. REASON FOR DEVIATION REQUEST: 1 OCFR50 Appendix R, Section 111.G.2.b, requires separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustib,e or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be ins\alled in the fire area. Fire Zones 1-3B-W has a minimum separation distance of 17 feet between unprotected raceway containing circuits for the redundant safe shutdown trains. In Fire Zone 1 *38-W there is also a group of raceway protected with Thermo-Lag 330-1 fire barrier material atong the east wall. Thermo*Lag 330* 1 has been determined to be a combustibfe material and, as such, must be considered as an intervening combustible:
Finallyt there are fire detectors and an automatic suppression system throughout this fire zone. Fire Zones 2-38-W has a minir:num separation distance of 22 feet between unprotected raceway containing circuits for the redundant safe shutdown paths. In Fire Zone 2-38-W there is a single repeater cable for the Radiax system (i.e .* portable radio system) along the west wall and a group of raceway protected with Thenno-Lag 330-1 fire barrier material along the east wall. Thermo-Lag 330-1 has been detennined to be a combustible material and, as such, must be considered as an intervening combustible Rev. 10 DR42-1 G:\Uc Docs\FPRA Approved\Devlations\fpd_0700_
42.doc along with the single repeater cable. Finally, there are fire detectors and an automatic suppression system throughout this fire zone. The automatic suppression system and fire detection in each of these fire zones extends throughout each wraparound zone and into the adjacent fire zones on either side of the wraparound zone, but the automatic sprinkler system and fire detection do not extend completely throughout the adjacent fire areas of which these fire zones are a part. This deviation justifies that, even though these aspects of Appendix R Section 111.G.2.b . are not fully satisfied, there are additional compensating factors which demonstrate that the existing configuration provides an equivalent level of assurance to that provided by Appendix R Section.111.G.2.b .such that safe shutdown can be achieved and maintained.
EXISTING ARRANGEMENT:
Drawing C240924 Sheet 1 shows the layout, equipment and combustible configuration of Fire Zone 1-38-W and drawing C240924 Sheet 2 shows the layout, equipment and combustible configuration (except for the single repeater cable) of Fire Zone 2-38-W.
* In-situ combustibles in these fire zones are limited to the cables rn cable trays, Lag 330-1 on conduits and junction boxes required to be protected, and any abandoned
* in place Thermo-Lag on cable trays, junction boxes and conduits not required to be
* protected.
Of these in-situ combustibles, the only intervening combustibles are the Thermo-Lag 330-1 raceway fire barriers along the east wall in each fire zone and the single repeater cable for the Radiax system in Fire Zone 2-38-W. Cable trays are separated by a minimum of 17 feet in Fire Zone 1-38-W and 22 feet in Fire Zone 2-38-W. Both fire zones are provided with fire detection and automatic sprinkler protection.
The cable trays and conduits containing redundant safe shutdown circuits are approximately 28 feet above the floor in both fire zones. The embedded junction boxes along the east wall containing redundant safe shutdown circuits are separated from each other by a minimum distance of approximately 43 feet. POTENTIAL SAFE SHUTDOWN IMPACTS: In the attached.
tables, the safe shutdown raceway in these Fire Zones 1-38 .. w and 2-38-W are tabulated.
For each raceway, the safe shutdown components that could be affected should a fire damage the circuits contained in the _raceway are also provided.
In addition, an assessment of the worst case impact for each component is also provided.
The cable faults are evaluated for the effects of hot shorts, open circuits and shorts to ground along with the effects of associated circuits, including spurious operations, breaker coordination and multiple high impedance faults. The information
* compiled in these tables is later used in conjunction with the raceway layout infonnation Rev. 10 DR42-2 . G:\Uc Docs\FPRR Approved\Oeviations\fpd_0700_
42.doe 
* *
* SSES-FPRR on the attached drawings in the justification section of this deviation request under the heading of "Physical Separation of Redundant Safe Shutdown Functions".
-Circuits which are contained in non-fire protected raceways in Fire Zone 1-38-W and which provide control or power to components required in support of safe shutdown in this fire zone are identified in Table 1.0 below. Table 1.0 Control and Power Circuits for Safe Shutdown Components in non-fire protected-raceway in Fire Zone 1-3B*W Raceway No. SSD Div. Affected Component Impact Assessment Control Circuits for RHR Valves E1KH21-25 Div. I AHR 1 F009 Valve Loss of Valve Control AHR 1F015A Valve* Loss of Valve Control AHR 1F017A Valve Loss of Valve Control E1K2L4 Div. I AHR 1F009 Valve Loss of Valve Control(1) F1KH47-50 Div.II AHR 1 FOOS Valve Loss of Valve Control AHR 1 F015B Valve Loss of Valve Control RHR 1 F017B Valve Loss of Valve Control AHA 1 F0488 VaJve Loss of Valve Control Power to RHR Valves & Other Equipment E1 PH21-23 Div. I 18219 (AHR 15A & 7A) Loss of Power to Valves E1PJ63 Div. I 18219 (AHR 15A & 7A) Loss of Power to Valves F1PH47-50 Div. II AHR 1 FOOS Valve Spurious Valve Opening AHR 1F017B Valve Loss of Power to Valve RHR 1 F048B Valve Loss of Power to Valve 10274 (See Table 1.0a) Loss of Power to Equipment Power to Switchgear and Pumps JB0009 Div. I 1/2A201 4.16 kv Swgr. Loss of Power to 4.16 kv CS Pump 1 P206A Loss of Power to Pump ESWS Pump OP504A Loss of Power to Pump AHR Pump 1 P202A Loss of Power to Pump JB0007 Div.II 1/2A202 4.16 kv Swgr. Loss of Power to 4.16 kv CS Pump 1 P206B Loss of Power to Pump
* ESWS Pump OP504B Loss of Power to Pump JB0073 Div. H AHR Pump 182028 Loss of Power to Pump (1} A hot short could cause the spurious opening of this valve, except that the cable is routed in a dedicated conduit with no other energized circuits.
Rev. 10 . DR42-3 G:\Uc Docs\FPRR Approved\Oeviations\tpd_0700_
42.doc The following table provides information related to the impacts to equipment powered
* from 10274. I Ta.ble 1 .oa
* Components Powered from 1 D274 Comp. ID Comp. Description Comments HV-15768 Supp. Pool Flow Div. Valve normally closed/required closed I 1P216 HPCI Vac. Tk. Cond. Pump not used for SSD HV-E41-1F066 HPCI Turb. Exh./Supp.
PooJ not used for SSD in this area 1P213 HPCI Aux. Oil Pump not used for SSD in this area I HV-B21-1F019 MSL Drain Isa.Valve need *to close this or 1 F016 I HV-G33-1 F004 RWCU lso.*vatve need to close this or 1 F001 1P215 HPCl Bar. Cond. Vac. Pump not used for SSD HV*E11-1F023 AHR Head Spray normally closed/not used for SSD HV-E11-1 F049 AHR Letdown to LRW/Cond.
normally closed/not used for_ SSD
* HV-E11-1 FOOS AHR SOC lso. Valve .normally closed/required closed HV-E41-1F008.
HPCI Test to CST not used for SSD in this area HV-E41
* 1 F007 HPCI Pump Disch. Valve not used for SSD in this area
* Rev. 10 DA42-4 _ G:\Uc Docs\FPRR Approved\Deviations\fpd_0700_42.doc SSES-FPRR
* Circuits which are contained in non-fire protected raceways in Fire Zone 2*3B-W and which provide control or power to components required in support of safe shutdown in this fire zone are identified in Table 2.0 below. Table 2.0 Control and Power Circuits for Safe Shutdown Components in non-fire protected raceway in Fire Zone 2-3B-W RacE!way No. SSD Div. Affected Component Impact Assessment Control & Instrumentation Circuits E2KH26-28 Div. I ESWS Pump OPS04C Loss of Pump Control RWCU 2F001 Valve Spurious Valve Opening RHR 2F009 Valve Spurious Valve Opening AHR 2F017A Valve Loss of Valve Controf E1K715 Div. I RHRSW 24A1 Valve Loss of Valve Control RHRSW 24A2 Valve Loss of Valve Control RHRSW 22A Valve Loss of Valve Control E2M098 Div. I Div. I SPOTMOS Loss of function F2KH29-32 Div. II AHR 2F04BB Valve Loss of Valve Control Div. II ADS Logic Loss of Div. n Control
* Power to RHR Valves & Other Equipment F2PH29-32 Div. II AHR 2F008 Valve Spurious Valve Opening AHR 2F015B Valve Loss of Power to Vatve AHR 2F017B Valve Loss of Power to Valve AHR 2F048B Valve Loss of Power to Valve 28229 (AHR 158 & 78) Loss of Power to Valves 20274 (See Table 2.0a) Loss of Power to Equipment Power to Switchgear and Pumps J80012 Div. I 1/2A201 4.16 kv Swgr. Loss of Power to 4.16 kv CS Pump 2P206A Loss of Power to Pump AHR Pump 2P202A Loss of Power to Pump RHRSW Pump 2P506A Loss of Power to Pump JB0014 Div. II 1 /2A202 4.16 kv Swgr. Loss of Power to 4. 16 kv CS Pump 2P206B Loss of Power to Pump RHRSW Pump 2P506B Loss of Power to Pump JB0075 Div. n AHR-Pump 2P2028 Loss of Power to Pump
* Rev. 10 DR42-5 G:\Llc Docs'FPRR Approved\Deviations\fpd_0700_
42.doc 
' 1 I The following table provides information related to the impacts to equipment powered
* from 20274: Table 2.0a .. Components Powered from 20274 Comp. ID Comp. Description Comments HV-25768 Supp. Pool Ftow Div. Valve nomially closed/required closed 2P216 HPCI Vac. Tk~ Cond. Pump not used for SSD HV-E41 .. 2F066 HPCI Turb. Exh./Supp.
Pool not used for SSD in this area 2P213 HPCI Aux. Oil Pump not used for SSD in this area* HV-821-2F019 MSL Drain lso.Valve need to close this or 2F016 HV-G33-2F004 RWCU lso. Valve need to close this or 2F001 2P215 HPCI Bar. Cond. Vac. Pump not used for SSD HV-E11-2F023 AHR Head Spray nomially closed/not used for SSD HV-E11-2F049 AHR Letdown to LRW/Cond.
nonnally closed/not used for SSD HV-E11-2F008 AHR SOC lso. Valve normally closed/required ctosed HV-E41-2F008 HPCI Test to CST not used for SSD in this area HV-E41-2F007 HPCI Pump Disch. Valve not used for SSD in this area JUSTIFICATION:
Fire Zones 1-38-W and 2-3B*W are similar in physical layout including raceway layout and combustible loading. Where the differences are* pronounced, the features of each fire zone are described separately.
Otherwise, the description provided is the limiting condition which bounds both fire zones. Fire Zones 1-3B*W and 2-38-W are "wraparound zof'.les" which, as described in Deviation Request No. 4, function to provide separation between Fire Areas R-1 A and R-1 B and Fire Areas R~2A and R-2B. respectively.
Fire Areas R-1 A and R~2A rely on Safe Shutdown Path No. 3. Fire Areas R-1 B and R-2B rely on Safe Shutdown Path No. 1. In Deviation* Request No. 4 1 it is stated that both safe shutdown paths are protected in the 0 wraparound area" unless a deviation is provided which specifically justifies the existing conditions.
Due to the unique attributes of Fire Zones 1-3B-W and 2-3B-W, as described below, this deviation justifies a condition different than that described in Deviation Request No. 4. Rev. 10 DR42-6 G:\1...ic Docs\FPAR Approvecf\Oevtations\fpd_0700_
42.doc * ** ** 
*
* SSES-FPRR Physical Separation of Redundant Safe Shutdown Functions:
Fire Zone 1-38-W: As shown on Drawing C240924 Sheet 1, all non-fire protected redundant safe shutdown circuits are separated by more than 20 feet except those contained in E1 PH22, E1 PJ63 and F1 KH 49 .. so. In the unlikely event that a fire were to impact all of these raceway, the worst case result would be a loss of power to the fallowing AHR System Valves with the following result: 1 F007 A, Loop A AHR Pump minimum flow valve, is initially required to be open and then to close when the AHR Pump flow increases to an acceptable level. A loss of power would result in the failure of this valve to close. This failure, however, will not impact the ability to achieve and maintain safe shutdown.
The flow capacity of one RHR Pump is approximately 12,000 gpm. The flow diversion through an open minimum flow valve is approximately 1,000 gpm. Any flow diversion through the 1 F007 A Valve would be returned to the Suppression Pool. The AHR flow through the AHR Heat Exchanger is to be limited to less than 10,000 gpm. Even with the postulated flow diversion, the AHR flow would need to be throttled back and, therefore, adequate flow through the heat exchanger would still be available . 1F008, the AHR SOC Outboard Containment Isolation Valve, is normally closed and is required to be closed in support of safe shutdown.
A loss of power to this valve woutd result in this valve remaining in the closed position.
1 F015A and B, the RHR LPCl Injection Inboard Containment Isolation Valves, are normally closed and are required to be closed in support of safe shutdown.
A loss of power to these valves would result in these valves remaining in the closed position.
1 F0178, Loop B AHR LPCI Injection Outboard Containment Isolation Valve, is not required to be operated in support of safe shutdown in this area. Loss of valve control due to loss of power, therefore.
is of no concern. 1 F048B, Loop B AHR Heat Exchanger bypass valve, is normally open, but is required tp be closed in support of safe shutdown.
Failure of this valve to close would cause a flow diversion around the AHR Heat Exchanger.
This could impact the efficiency and, therefore, the availability of the AHR System the Suppression Pool Cooling*mode of operation.
The assessments provided above use the assumption from Calculation EC-013-0843 that at fire onset, an safe shutdown systems are assumed operable and available for post-fire shutdown.
This assumption requires that all safe shutdown components are initially in their normal position.
Rev. 10 DR42 .. 7 G:\Lic Docs\FPRR Approved\Oeviations\tpd_0700_
42.doc The net result of the impacts described above would be a potential loss of AHR Loop B Suppression Pool Cooling. Loop A of AHR, however, would still be available to operate in the Suppression Pool Cooling mode. The only potential impact to Loop A of AHR is to the 1 F007 A Valve. The failure of the 1 F007 A Valve to close would have no impact on the ability of AHR to operate efficiently in the Suppression Pool Cooling mode. All other raceway and redundant safe shutdown functions are separated by greater than 20 feet with insignificant intervening combustibles and, as such, there will be no other impacts to safe shutdown functions.
* -Fire Zone 2-38-W: As shown on Drawing C240924 Sheet 2 all non-fire protected redundant safe shutdown circuits are separated by more than 20 feet with insignificant inte1Vening combustibles.
Therefore, *there will be* no impacts to safe shutdown functions.
In-situ and Intervening Combustibles:
The only in-situ combustibles in these fire zones consist of cabtes in enclosed raceway (e.g., conduits, cable trays and junction boxes), Thermo-Lag 330-1 installed on raceway required to b~ protected, abandoned in place Thermo-Lag 330-1 on raceway not e required to be protected, and a single repeater cable for the Radiax system (Fire
* Zone 2-38-W only). The Thermo-Lag 330-1 on the protected raceway along the east wall, which represent intervening combustibles, are shielded to a great extent from the redundant raceway on the west wall by structural steel floor framing for Elevation 719'-1. The non-protected redundant raceway themselves are separated by a minimum of 17 feet and, in most cases, by greater than 20 feet. Due to the presence of fire detection and automatic sprinkler protection in this fire zone, this 17 foot distance is considered to be sufficient to preclude damage to redundant raceway due to in-situ combustibles.
Since the combustible material contribution from the single repeater cable for the Radiax System is insignificant, it is not considered to be a fire hazard. A transient fire, such as a trash can fire, would not affect the safe shutdown raceway which are in close proximity to each other since the safe shutdown raceways are located approximately 28 feet above the Elevation 683' -0 floor. Ad min istratlve Controls:
The floor area between the redundant safe shutdown cable trays are identified to indicate that it is a restricted area for storage of transient combustible materials.
No transient combustible materials will be stored in this area without the review and acceptance of the Site Fire Protection Engineer.
Rev. 10 DR42 .. 8 G:\Lic Docs\FPR~
Approved\Deviations\tpcj_0700_
42.doc ** 
* *
* SSES-FPRR Fire Protection Features:
Both Fire Zones 1 *38-W and 2-38-W are provided with fire detection and automatic sprinkler protection.
Due to the limited amount of in .. situ combustibles in this area and the administrative controls descri~ed above tor controlling the introduction of transient combustibles.
the.automatic suppression system and fire detection installed in these fire zones are adequate to ensure that both redundant trains wiU not be damaged. Therefore, an automatic suppression system and fire detection do not need to be installed throughout the fire areas of which these fire zones are a part.
 
==SUMMARY==
AND CONCLUSION:
The configuration of the redundant raceway, the use of qualified raceway fire barriers where shown on Drawing C240924 Sheets 1 and 2 and the low quantity of combustibles ensure that the fire detection and fire suppression installed in Fire Zones 1-38-W and 2-3B*W will prevent damage to redundant safe shutdown raceway. Therefore, protection of the redundant raceway with a quaUfied 1-hour fire barrier is not required in Fire Zone 1*3B-W, other than E1F132, E1F137, C1F033, C1F034, C1F055 and JBOOOB which are protected with a qualified 1-hour fire barrier, and in Fire Zone 2-38-W, other than C1F040, C1F045, C2F030 and JB0013 which are protected with a qualified 1-hour fire barrier . Rev. 10 DR42-9 G:\Uc Docs\FPRR ApproVed\Oeviations\Jpd_0700_
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SSES-FPRR Text Rev. 13 8.0 DRAWINGS The drawings listed below contain the key information for the design and control of fire protection features at the plant. DRAWING# TITLE SHEETS E-105002 General Site Arrangement 1 E-105176 Yard Main Arrangement 1 and 2 E-106227 P&I D -Fire Protection 1 thru 7 and 9 E-205949 SSES Unit 1 Reactor BuHding Fire Zone Plan of Elevation 645'-0" 1,2 E-205950 SSES Unit 1 Reactor BuildinQ Fire Zone Plan of Elevation 670'-0" 1,2 E-205951 SSES Unit 1 Reactor Buildinq Fire Zone Plan of Elevation 683'-0" 1,2 E-205952 SSES Unit 1 Reactor BuildinQ Fire Zone Plan of Elevation 719'-1" 1,2 E-205953 SSES Unit 1 Reactor Building Fire Zone Plan of Elevation 749 1-f' 1,2 E-205954 SSES Unit 1 Reactor Buildinq Fire Zone Ptan of Elevation 779'-1" 1,2 E-205955 SSES Unit 1 Reactor Building Fire Zone Plan of Elevation 799'-1" 1,2 E-205956 SSES Unit 1 Reactor BuHdin~ Fire Zone Plan of Elevation 818'-1" 1 ,2 E-205957 SSES Unit 2 Reactor Building Fire Zone Plan of Elevation 645'-0" 1,2 E-205958 SSES Unit 2 Reactor BuildinQ Fire Zone Plan of Elevation 670'-0'' 1,2 E-205959 SSES Unit 2 Reactor Building Fire Zone Plan of Elevation 683'-0" 1,2 E-205960 SSES Unit 2 Reactor Buildinq Fire Zone Plan of Elevation 719'-1" 1,2 E-205961 SSES-Unit 2 Reactor Buildinq Fire Zone Plan of Etevation 749'-1" 1 E-205962 SSES Unit 2 Reactor Buildinq Fire Zone Plan of Elevation 779'-1 '' 1,2 E-205963 SSES Unit 2 Reactor BuHdinQ Fire Zone Plan of Elevation 799'-1" 1,2 FPRR Rev. 13 8.0-1 SSES~FPRR Text Rev. 13 DRAWING# TITLE SHEETS . E-205964 SSES Unit 2 Reactor Buildinq Fire Zone Ptan of Elevation 818'-1" 1,2 E-205965 SSES Units 1 & 2 Reactor Buildino Fire Zone Section A-A 1 E-205966 SSES Units 1 & 2 Reactor Building Fire Zone Section B-B 1 E-205967 SSES Unrts 1 & 2 Reactor Buildinq Fire Zone Section C-C 1 E-205968 SSES Units 1 & 2 Reactor Reactor Buitdinq Fire Zone Section 0-D 1 E-213485 SSES Units *1 & 2 Reactor Reactor Buildinq Fire Zone Sections G-G and H-H 1 E-205985 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 656' -0" 1,2 E-205986 SSES Units 1 & 2 Control Structure Fire Zone Plan of ElevaUon 676'*0'' 1 E-205987 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 686'-0" 1,2 E-205988 SSES Units 1 & 2 ControJ Structure Fire Zone Plan of Elevation 698'-0" 1,2 E-205989 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 714'-0" 1,2 E-205990 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 729'-f' 1,2 E-205991 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 741'-1'' 1,2 E-205992 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 754'-0" 1 ,2 E-205993 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 771 '-0" 1,2 E-205994 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 783'-0" 1,2 E-205995 SSES Units 1 & 2 Control Structure Fire Zone Plan of Elevation 806'*0'' 112 E-205996 SSES Units 1 & 2 Control Structure Fire Zone Section A-A 1 E-205997 SSES Units 1 & 2 ESSW Pumphouse Frre Zone Plan of Elevation 660'-0" 1,2 E-205998 SSES Units 1 & 2 ESSW Pumphouse Fire Zone Plan of Elevation 686'-6" 1.2 E-205999 SSES Units 1 & 2 ESSW Pumphouse Fire Zone Section A-A 1 FPRR Rev. 13 8.0-2 SSES-FPRR Text Rev. 13 DRAWING# TrTLE SHEETS E-206000 SSES Units 1 & 2 Diesel Generator 1,2 BuitdinQ Fire Zone Plan of Efevation 660'-0" E-206001 SSES Units 1 & 2 Dfesel Generator
 
===1.2 Buildinq===
Ffre Zone Ptan of Elevation 677'-0" E-206002 SSES Units 1 & 2 " Diesel Generator 1,2 Building Fire Zone Plan of Elevation 710'-9 11 E-206003 SSES Units 1 & 2 Diesel Generator 1 Buildinq Fire Zone Section A-A E--213410 SSES Units 1 & 2 Diesel G~nerator E 1,2 Building Fire Zone Plan of Elevation 656'-6 11 E-213411 SSES Units 1 & 2 Diesel Generator E 1,2 BuildinQ Fire Zone Plan of Elevation 675'-6" E-213412 SSES Unlts 1 & 2 Diesel Generator E 1,2 Bujlding Fire Zone PJan of Elevation 708' -OH E-213413 SSES Units 1 & 2 Diesel Generator E 1,2 Buildinq Fire Zone Plan of Elevation 726'-0" and 741'*6'' E-213414 SSES Unit 1 & 2 Diesel Generator E 1 BuildinQ Fire Zone Section A-A FPRR Rev. 13 8.0-3 Security-Related Information Figure Withheld Under 10 CFR 2.390
 
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Latest revision as of 23:24, 5 January 2025

Redacted - Susquehanna Steam Electric Station, Units 1 & 2, Revision 22 to Fire Protection Review Report (Fprr), Summary Table of Contents
ML18116A085
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 10/16/2017
From:
Talen Energy, Susquehanna
To:
Office of Nuclear Reactor Regulation
Shared Package
ML17331A584 List:
References
PLA-7636
Download: ML18116A085 (737)
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