TXX-4518, Forwards Listed Documents,Including Rev 3 to Engineering Justification for Placement of Automatic... by Prof Loss Control,Inc & Table Listing Fire Area NFPA Code Compliance. Encls Should Close Concerns Re Sprinkler Sys
| ML20132B751 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/22/1985 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20132B756 | List: |
| References | |
| TXX-4518, NUDOCS 8507250117 | |
| Download: ML20132B751 (5) | |
Text
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4 Log # TXX-4518 File # 909.5 TEXAS UTILITIES GENERATING COMPANY 10010 clo MKYWAY TOWEN
- 400 NOHTIE OLIVE MTHEET. L.II. MS
- 13ALLAM,TEXAM 75208 WILLIAM G. COUNSIL UM tratuvevs vecs PassionNT
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Director of Nuclear Reactor Regulation
' Attention: Mr. Vincent S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION DOCKET NOS. 50-445 AND 50-446 AUTOMATIC SPRINKLER SUPPRESSION SYSTEMS
Dear Mr. Noonan:
The following documents are provided to complete closure of all remaining concerns associated with automatic sprinkler suppression systems.
1.
Table 1 - provides a complete listing, by fire area / zone, of the existing and planned compliance with NFPA code, and all suppression system deviations.
2.
Deviation 13 - provides technical justification for general area suppression systems in five locations which do not meet all requirements of Appendix A Section IV C3(c) and Appendix R to 10CFR50 Section II.G.2.
3.
Professional Loss Control, Inc. (PLC) Report " Engineering Justification for Automatic Sprinklers, Comanche Peak Steam Electric Plant, Texas Utilities Generating Company" Revision 3, May 27, 1985.
Should you have any questions in this matter, please contact this office.
Sincerely, 8507250117850722[
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ADOCK050%
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W. G. Counsil
-BSD/grr Attachment c - S.-B. Burwell A. L. Vietti L
C. Trammell I
I A islVINDON OF TEXAN t'TELETIEN ELECTREC COMi*ANY L
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l TABLE 1 l
Fire Area /
Suppression. Suppression Upgrade,
l Zone Description of Area / Zone -
Per Code Room #
Deviation Remarks 175, '79, 180
.Ic',2f AA 21a CCW heat exchangers and corridor-1 AA 21b Corridor-NFPA 13 207 (partial)_
2g Portions of area with-(Partial) no interactions l
AA 21d Corridor 226 2h Portions of ares with no interactions AA 21f Corridor 241 (corridor) ~
2a 2e, 21 Portions of area with no interactions
~
AA 153 Safsti Chiller Equipment'- Unit 1 NFPA 13 EA 43 -
Air Compressor Area NFPA 13 113 (partial) 2k Portions of area with (Partial).
no interactions EA 57 Battery Room Corridor-13 i
SB 4 Corridors and Chemical Additive NFPA 13 2c, Rev. 1; Area over renewable Tank Room (Partial) 13 blocks is not f
sprinklered 58 8 Sample Room and Corridors 2n, 13 SB 15 Corridor and Containment Air Lock 13 SB 144 Non-Radioactive Piping Penetration 2m, 13 Area 5F 19 Filter Storage Area NFPA 13 SG 10a Diesel Generator Room - Train A NFPA 13 SH 11 Day Tank Enclosure - Train A NFPA 15 SI 12a Diesel Generator Room - Train 8 NFPA 13 SJ 13 Day Tank Enclosure - Train 8 NFPA 15 e
i SK 17a Feedwater Penetration Area NFPA 13 Sd Room 100a is (Partial) sprinklered in l
accorda9ce with NFPA
- 13. Room 100 is covered by deviation l
Sd.
t j
SK 17b Main Steam Penetration Area NFPA 13 i
SK 17c Platform over Main Steam Penetration NFPA 13 L
Area l
l t
WA 103 Diesel Engine Driven Fire Pump Roon NFPA 15 isB 104 Service Water Intake Structure NFPA 13 4
l
s 1
- o t
t
- DEVIATION
13 1
EXCEPTION:
The general area sprinkler suppression system does not meet.the requirements of Appendix A Section IV l
C 3(c) and Appendix R to 10CFR50 Section IIIG2.
j i
DESCRIPTION A:
s L
BUILDING:
Safeguard ELEVATION:
790' ROOM (S):
70 and 71 FIRE AREA:
SB t
FIRE ZONE:
4 l
BUILDING:
Safeguard i
ELEVATION:
810' ROOM (S):
79 and 82 l
FIRE AREA:
SB FIRE ZONE:
8 i
BUILDING:
Safeguard ELEVATION:
831' ROOM (S):
94 FIRE AREA:
SB TIRE ZONE:
15 These fire zones are corridors which have a low hazard fixed combustible loading with a fire duration of less than ten minutes.
Passive and active fire protection is provided in these fire zones.
The fire area containing the fire zone is separated from other plant areas by a three-hour rated t
Essential cables and associated non-safety circuits of one redundant safe shutdown train are enclosed in a one-hour fire rated envelope system.
An area-wide early warning. smoke detection system is installed throughout the fire zone.
A partial area automatic sprinkler system mounted below cable trays and obstructions provided with reduced area per sprinkler coverage is installed.
I
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DESCRIPTION B:
BUILDING:
Safeguard ELEVATION:
831' ROOM (S) 88 FIRE AREA:
SB FIRE ZONE:
144 This fire zone is the non-radioactive piping penetration area which has a low hazard fixed combustible' loading with a fire duration of less than ten minutes.
Passive and active fire protection is provided in fire zone SB144.
The fire area containing this fire zone is separated from other plant areas by a three-hour rated fire barrier.
Essential cables and associated non-safety circuits of one redundant safe shutdown train are enclosed in a one-hour fire rated envelope system.
An area-wide early warning smoke detection system is installed throughout the fire zone.
Water spray is also provided for two or more vertical adjacent cable tray runs.
A full area automatic sprinkler system mounted below cable trays and obstructions provided with reduced area per sprinkler coverage is installed.
DESCRIPTION C:
BUILDING:
Electrical & Control ELEVATION:
792' ROOM (S):
125 FIRE AREA:
EA FIRE ZONE:
57 This fire zone is a corridor which has a low hazard fixed combustible loading with a fire duration of less than ten minutes.
Passive and active fire protection is provided in fire zone EA57.
The fire area containing this fire zone is separated from other plant areas by a three-hour rated fire barrier.
Essential cables and associated non-safety circuits of one redundant safe shutdown train are enclosed in a one-hour fire rated envelope system.
An area-wide early warning smoke detection system is installed throughout the fire zone.
A full area automatic sprinkler system mounted below cable trays and obstructions provided with reduced area per sprinkler coverage is installed.
EVALUATION; An equivalent level of protection to that of BTP CMEB 9.5-1 is provided as follows:
Passive fire protection features in each zone are provided consisting of:
1.
Low effective combustible loadings (less than 10 minutes).
2.
Fire areas containing the fire zones of interest are separated from other plant areas by three hour fire barriers.
3.
One train of redundant essential raceways in each fire zone is enclosed in a one-hour rated fire barrier or separated by 20 feet.
The less than 10 minute effective combustible loading does not present a significant hazard to the integrity of these of these barriers and thus safe shutdown as assured.
The combination of these passive features reduces the probability of propagation of an exposure fire thus limiting its severity and enabling rapid control.
Active fire protection is also provided in each fire zone.
Where there are significant concentrations of combustibles (i.e. 4 or more stacked horizontal raceways or two or more adjacent vertical raceways), specific raceway suppression is provided for each cable tray.
The installed area-wide early warning smoke detection system assures a rapid response by the plant fire brigade to extinguish the fire using available manual hose station and portable extinguishers.
An automatic sprinkler system mounted below cable trays and obstructions is provided with reduced area per sprinkler coverage to effectively control floor level exposure fires.
An analysis of postulated worst case floor level exposure fires demonstrates that these sprinklers will actuate prior tg l
ignition of any exposed IEEE qualified cables in trays.'
l The above described passive and multi-level active fire protection features satisfy the NRC " protection-in-depth" l
concept.
The installation of a full area, ceiling level, automatic suppression system would not significantly enhance the fire protection provided by the current configuration.
1.
Effective Combustible Loading = Calculated fixed combustibles less the combustibles associated with exposed cable trays that are protected by water spray suppression.
2.
Professional Loss Control, Inc. (PLC) Report " Engineering Justification for Automatic Sprinklers, Comanche Peak Steam Electric Plant, Texas Utilities Generating Company", Revision 3, May 27, 1985.
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