ML20151Y649
| ML20151Y649 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/29/1988 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20151Y654 | List: |
| References | |
| TXX-88422, NUDOCS 8805050061 | |
| Download: ML20151Y649 (28) | |
Text
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Log # TXX-88422 File-# 10010 clo 909.5 g=
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April 29, 1988
%inism G counell Execume Vwe President U. S. Nuclear. Regulatory Commission ATIN:
Document Control Desk Washington, D.C.
20555
SUBJECT:
COMAtlCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50-445 AND 50-446 TRANSMITTAL OF FIRE PROTECTION REPORT, REVISION 1 Gentlemen:
Enclosed are 38 copies of the revised Fire Protection Report. A copy of the Fire Protection Report should be retained with each set of FSAR volumes issued.
The attachment to this letter describes the changes made to the Fire Protection Report.
Included in the changes made to the Fire Protection Report i
is the clarification of "safe shutdown" as "fire safe shutdown." Below is a summary of changes made:
l Se.ction 1 Adds additional definitions to support the new Section IV.
Section II Additional description to fire protection features to discuss NFPA code deviations.
Provides additional discussion to clarify fire protection features and the Fire llazards Analysis Evaluation used to demonstrate compliance.
Section III Adds the Control Room HVAC Mechanical Equipment Room as another area that could require alternate shutdown.
Provides a better description of actions taken during a Control Room evacuation.
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4 DCD 400 North Olive Street LBII Dellas. Texas 13:01
1XX-88422 April 29, 1988 Page 2 of 2 Section IV Adds a new Section IV to describe the administrative controls to be used to support the fire protection program.
This section provides the information to support removal of fire protection surveillances from the Technical Specifications.
Section V Replaces previous Appendices with the following:
1.
CPSES Fire Protection Program Separation Criteria Comparison Table, Appendix A.
2.
Fire Hazards Analysis Evaluations Matrix, Appendix B.
3.
Deviations, Appendix C.
4.
Fire Hazards Analysis Figures, Appendix D.
Note: The previous Deviations submitted on the Docket are now included as Appendix C to the Fire Protection Report.
Very truly yours, i
W. G. Counsil JDS/myt Attachment Enclosure c - Mr. R. D. Martin - Region IV (clo)
Resident inspectors, CPSES (3 copies - clo) l
'l
Attachment to TXX-88422 April 29, 1988 Page 1 of 12 FPR SECTION DESCRIPTION General Adds Fire Protection Systems and Equipment Requirements from the Technical Specifications to FPR Section IV. Revises the appendices and includes them asSection V.
1-1.2.5 Provides new definition for Alternate Shutdown Area.
1-1.2.11 Clarifies the types of cable failures.
1-1.2.13 Provides new definition for Compensatory Measure.
I-1.2.17 Provides new definition for FHA Evaluation.
1-1.2.23 Combines definition of safe shutdown with definition of fire safe shutdown.
1-1.2.29 Provides new definition for Functional Test I-1.2.32 Provides new definition for Hot Shutdown Panel (HSP).
1-1.2.36 Clarifies the definition of Local Control.
1-1.2.37 Clarifies the definition of Manual Operation.
1-1.2.40 Provides new definition for Operable.
1-1.2.45 Clarifies the definition of Pre-fire.
1-1.2.57 Includes previously omitted portion of sentence.
)
Attachment to TXX-88422 April 29, 1988 Page 2 of 12 JUSTIFICATION Section Description 11-1.1 Delete background section.
11-1.2.4 Changes FHA drawings to FPR figures to identify the correct reference drawings.
(This change is made throughout).
Remove reference to submittal of deviation, because they are now contained in Appendix C of Section V of the Fire Protection Report.
Adds references to be made in F.P. Features Section for Deviations.
Adds reference to Appendix A of this FPR for identification of areas having no fire safe shutdown equipment and no fire safe shutdown cabling.
Clarifies that this equipment list does not address cabling required for fire safe shutdown.
11-1.2.5 Adds new section to F.P. Features for NFPA Code Compliance Deviations.
11-3.2 Discusses use of representative burning curves for isolated cases in establishing MPfl..
11-3.3 Adds reference to Section IV.
11-3.4 Same as !!-3.3 11-3.7 Adds assumption for separation criteria.
11-4.1 Adds H.E.L.B. discussion for vent areas in general methodology discussion.
11-4.2 References FHA drawings and DBD-ME-001.
11-4.3 Adds discussion for FHA Evaluations for area boundaries which are not rated.
Same as 11-1.2.4.
11-4.4 Adds reference to Section III - 5.0 for Potentially Failed Fire Safe Shutdown Equipment.
Adds reference and clarification of fire safe shutdown cabling.
11-4.5 Adds manual suppression to F.P. Features.
Attachment to TXX-88422 April 29, 1988 Page 3 of 12 Section Revision 11-4.5(2)
Changes "no intervening combustibles" to "negligible intervening combustibles" to correctly identify the existing conditions.
(This change is made throughout).
To account for the use of FHA evaluations.
(This change is made throughout.)
11-4.5(3)
Clarifies the wording to make the section understandable.
Same as 11-4.5(2).
11-4.6 Deletes reference to INDMS software for fixed exposed cabling.
11-5.1.1.1 Same as 11-1.2.4.
11-5.1.1.4 Changes "Engineering evaluations" to "Fire Hazards Analysis Evaluations" to accurately reflect the document use.
(This change is made throughout.)
Changes "partial area wide" to "partial" to avoid confusion.
11-5.1.1.5 Updates MPFL value using "C-Curve" and provides explanation.
1 11-5.1.2.1 Same as 11-1.2.4.
l 11-5.1.2.4 Same as 11-5.1.1.4.
Changes "train" to "set" to clarify wording.
11-5.1.2.5 Same as 11-5.1.1.5.
11-5.1.3.1 Same as 11-1.2.4.
11-5.1.4.1 Same as 11-1.2.4.
11-5.1.4.4 Changes "Engineering evaluations" to "Fire Hazards Analysis Evaluations" to accurately reflect the document use.
(This change is made throughout.)
11-5.1.4.5 Same as 11-5.1.1.5.
11-5.1.5.1 Same as 11-1.2.4.
11-5.1.5.4 Same as 11-5.1.4.4.
l 11-5.1.5.5 Updates MPFL values for fire zones.
Same as !!-5.1.1.5.
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!!-5.1.6.1 Same as 11-1.2.4.
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Attachment to TXX-88422 April 29, 1988 Pa3e 4 of 12 1
Section Revision 11-5.1.7.1 Same as 11-1.2.4.
11-5.1.7.4 Char.ges wording to avoid confusion about type of sprinkler system provided.
11-5.1.8.1 Same as 11-1.2.4.
11-5.1.9.1 Same as 11-1.2.4.
11-5.1.9.4 Same as 11-5.1.7.4.
11-5.1.10.1 Same as 11-1.2.4.
11-5.1.11.2 Same as 11-5.1.1.4.
11-5.1.12.1 Same as 11-1.2.4.
11-5.1.13.1 Same as 11-1.2.4.
l 11-5.1.14.1 Same as 11-1.2.4.
l 11-5.2.1.1 Same as 11-1.2.4.
11-5.2.1.5 Same as 11-5.1.1.5.
11-5.2.2.4 Same as 11-5.1.4.4.
Changes "train" to "set" to clarify wording.
11-5.2.2.1 Same as 11-1.2.4.
11-5.2.3.1 Same as 11-1.2.4.
11-5.2.4.1 Same as 11-1.2.4.
11-5.2.5.1 Same as 11-1.2.4.
11-5.2.6.1 Same as 11-1.2.4.
I 11-5.3.1.1 Same as 11-1.2.4.
11-5.3.1.4 Changes "train" to "set" to clarify wording.
Same as 11-5.1.1.4.
11-5.3.1.5 Same as 11-5.1.1.5.
11-5.3.2.1 Same as 11-1.2.4.
i 11-5.3.2.4 Change description of barrier from "three" to "two" hours to agree with Section 11-5.3.2.2.
i I
Attachment to TXX-88422 April 29, 1988 Page 5 of 17 Section Revision 11-5.3.3.1 Same as 11-1.2.4 11-5.3.3.4 Same as 11-5.1.4.4.
11-5.3.4.1 Same as 11-1.2.4.
11-5.3.4.4 Same as 11-5.1.4.4.
11-5.3.5.1 Same as 11-1.2.4.
11-5.3.5.4 Same as 11-5.3.2.4 to agree with Section 5.3.5.2.
II-5.3.5.5 Updates MPFL values for fire zones.
11-5.3.6.1 Same as 11-1.2.4.
11-5.3.7.1 Same as 11-1.2.4.
11-5.3.7.5 Updates new MPFL values for the fire zones.
11-5.3.8.1 Same as 11-1.2.4.
11-5.3.8.4 Same as 11-5.1.1.4.
!!-5.3.8.5 Updates new MPFL values for the fire zones.
11-5.3.9.1 Same as 11-1.2.4.
11-5.3.10.1 Same as 11-1.2.4.
11-5.3.11.1 Same as 11-1.2.4.
11-5.4.1.1 Same as 11-1.2.4.
11-5.4.1.4 Changes "partial area wide" to "partial" to avoid confusion.
l 11-5.4.1.5 Updates new MPFL values for fire zones.
11-5.4.2.1 Same as 11-1.2.4.
11-5.4.2.2 Changes wording to avoid generic referencing.
11-5.5.1.1 Same as 11-1.2.4.
11-5.5.1.4 Changes wording to avoid generic referencing.
11-5.6.1.1 Same as 11-1.2.4.
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Attachment to TXX-88422 April 29, 1988 Page 6 of 12 Section Revision 11-5.6.1.5 Delete Lube Oil and Diesel Fuel as types of combustibles.
Updates combustible loading to delete these combustibles.
11-5.6.2.1 Same as 11-1.2.4.
11-5.6.2.4 Same as 11-4.5(2).
11-5.7.1 Same as 11-1.2.4.
Same as 11-4.5(2).
11-5.7.1.4 Same as 11-4.5(2) and 11-1.2.4.
11-5.8.1.1 Same as 11-1.2.4.
11-5.8.1.2 Adds the word "Electrical" to "Duct Banks" to clarify type of ducts.
11-6.1 Adds flFPA Code Compliance Deviations to F.P.
Features Section.
11-6.2.2 Identifies the reference of deviations to BTP APCSB 9.5-1.
Adds a discussion for one hour wraps.
11-6.2.3 Add: reference to Appendix C for deviations for Interior finish.
11-6.2.4 Same as 11-6.2.2.
Adds discussion of high energy line break into air flow requirement discussions.
11-6.2.5 Same as II-6.2.2.
Clarification of internal conduit seals to provide a more accurate description.
11-6.3.1 Adds identification of FHA Evaluations and reference to Appendix B.
Clarifies discussion of supervision of water flow and valves.
1
Attachment to TXX-88422 April 29, 1988 Page 7 of 12 Section Revision 11-6.3.2 Addition of the new water supplies utilized at CPSES.
11-6.3.3 Same as 11-6.3.2.
11-6.3.4 Same as 11-6.1.
11-6.3.5 Same as 11-6.3.1.
Deletes discussion of non-compliance with NFPA 12A.
Provides clarification to descriptions for manually actuated pre-action systems and open head water spray systems.
11-6.5 Adds clarification to discussion of RCPLOCS.
11-6.6 Clarifying the emergency lighting section to provide a more thorough and accurate description.
11-6.8 Adds section 6.8 to identify and justify NFPA Code Deviations.
11-7.1 Deletes NFPA 15, 1985 to correct a typographical error.
' Attachment to TXX-88422 April 29, 1988 Page 8 of 12 i
FPR SECTION/PAGE DESCRIPTION 111-1.1 Deletes reference to "additional requirements" that are not used.
- 111-1.2 Changes "required" to "supporting" information to reflect its usage. Clarifies the event as being coincident with a single fire and loss of off site-power and the database references.
111-3.1.2
- Changes "scram" to "reactor trip".
Deletes transition to cold shutdown because it is addressed in following statements, 111-3.1.4.2 Deletes MHIF study description because.it is available in other site documents.
. j i
References to conservative engineering practices 1
and spare feeder breakers because credit is not taken for them.
Adds another resolution for correcting potential j
common power supplies concerns.
I Updates the basis utilized for common power supply concerns and CPSES position on MHIF and 4
breaker / fuse coordination for clarity.
111-4.2.1.6 Updates the list of systems utilized to provide support services.
111-4.2.2.2 Includes associated circuits of concern.
4 111-4.2.2.4 Adds description as to how CR/CSR cables and circuits are treated.
I 111-4.2.2.5 Adds Fire Safe Shutdown Systems list.
111-4.2.4 Clarifies protection separation and manual operations credited for mitigating potential spurious operations.
111-4.3 Changes "could be used to justify" to "are used to j
assess the significance..." to reflect current usage.
1 111-4.3.1 Clarifies the use of deviations.
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Attachment to TXX-88422 i
April 29, 1988 Page 9 of 12 FPR SECTION/PAGE DESCRIPTION 111-4.3.2 Includes specifics of the operation practices requiring alternate shutdown. Adds CR-ilVAC Mechanical Equipment Room as another area that could require alternate shutdown making it consistent with the FSAR.
r Deletes reference to CPSES emergency guidelines and includes-reference to CPSES abnormal operation procedures.
111-4.3.2.1 Description of Alternative Shutdown Areas.
111-4.3.2.3.1 Indicates that upon the confirmation of a fire requiring the evacuation of the Control Room the reactor is tripped manually from the Control Room.
Indicates control power for the Emergency Diesel Generator operation can be-switched at the EDG engine control panel for CSR fires. Clarifies that credit is not taken for additlocal control room manual actions.
Deletes an example of a spurious ope 54 ion.
i 111-4.3.2.4 Deletes reference to "transition to
- .id shutdown" l
as it is addressed in the ntxt paragrich.
(
111-4.3.2.4.1 Deletes reactor operator actions, as detailed operator actions are available ?n applicable CPSES procedures.
l 111-4.3.2.4.2 Deletes reference to additional operators and fire t
brigade availability as they are not credited for fire safe shutdown.
111-4.3.2.4.3 Deletes reference to additional operators and extinguishment of fire because credit is not taken
-l 4
4 for them for hot standby conditions.
Clarifies when plant cooldown would generally be initiated, and that the cool down phase requires the availability of additional systems and components.
111-5 Updates Fire Safe Shutdown Equipment list.
1 1
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Attachment to TXX-88422 April 29, 1988 Page 10 of 12 FPR SECTION DESCRIPTION Throughout The Fire Protection Technical Specification Section IV Surveillances have been reformatted and placed within the FPR for clarity,' ease of technical application and to provide site specific
~y information.
The section has been divided into categories (i.e., tests / inspections, compensatory measures, operability requirements, etc.).with each respective system's requirements listed within each section.
Additional.information has t
also been incorporated to explain each section which transforms the information into a easily usable and understandable document.
Significant
~
changes from the technical specifications submitted per letter logged TXX-6905, dated October 30, 1987 have been identified and justif' cations provided.
IV-2.1.a Delineates the requirements of each type of i
detector.
Revise the trip actuating device operational test to a functional test to i
accommodate what is the standard of practice for testing of fire protection detectors.
A trip actuating device operational test, as defined, is l
not an attainable test under field conditions for 1
the listed devices.
A functional test as defined
}
is attainable and gives an adequate measure of operability of the system.
IV-2.1.d.1 Changes "tank weight" to read "tank liquid content" so that the statement is in agreement l!
with weight or level measurements being conducted.
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Attachment to TXX-88422 April 29,-1988 L
Page 11 of 12 FPR SECTION DESCRIPTION IV-2.1.g Revises the surveillance criteria for fire rated assemblies.
Fire rated assemblies are of equal or more substantial construction than penetration L
seals and are not subject to degradation that will not be adequately _ detected under this surveillance schedule.
Fire doors, a commodity with substantial usage 'and operability requirements are-
_surveilled on a more frequent schedule tg account for the increased potential degradation.
Section IV' Deletes detection and suppression systems for Tables 1 and 2 atmoseberic clean up units.
These systems are i". stalled per Regulatory Guide 1.52, are not required for fire safe shutdown ano do not present a hazard to fire safe shutdown components.
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Attachment to TXX-88422 April 29, 1988 Page 12 of 12 DEV.'ATIONS CHAtlGE JUSTIFICAT10fl5 Section Description Section V Replace "Comparison to DBD-SY-1" with "CPSES Fire App. A Protection Program Fire Area Comparison Table."
Section V Replace "Comparison to FPPR" with "Fire Hazards App. B Analysis Evaluation Matrix."
Section V Correct Deviation 3a and 3a-1 to reflect current App. C plant design.
Update Deviation 10 to reflect the final plant design of the DC Emergency Lighting provided for the control room.
Section V Include actual Figures instead of referencing FHA App. D Drawings.
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a Log # TXX-88422-File # 10010 clo
==
909.5 rm filELECTRIC April 29, 1988 l
% HHem G. Coenen Enecunvr Vwe Mrsdens O. S. Nuclear Regulatory Commission
[
ATIN: Document Control Desk Washington, D.C.
20555'
SUBJECT:
COMANCHE PEAK _ STEAM ELECTRIC STATION (CPSES) 4 DOCKET N05. 50-445 AND 50-446 TRANSMITTAL OF FIRE PROTECTION REPORT, REVISION 1 Gentlemen:
Enclosed are 38 copies of the revised Fire Protection Report. A copy of the Fire Protection Report should be retained with each set of FSAR volumes i
issued.
l The attachment to this letter describes the changes made to the Fire i
Protection Report.
Included in the changes made to the Fire Protection Report is the clarification of "safe shutdown" as "fire safe shutdown." Belov,is a sunnary of changes made:
4 Section I I
Adds additional definitions to support the new Section IV.
i Section il Additional description to fire protection features to discuss NFPA,.
code deviations.
Provides additional discussion to clarify fire protection features J.
and the Fire Hazards Analysis Evaluation used to demonstrate compliance.
\\
j Section Ill i
Adds the Control Room HVAC Mechanical Equipment Room as another area that could require alternate shutdown.
4 Provides a better description of actions taken during a Control 1
j Room evacuation.
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i 400 North Olsss Sarret LB 81 Dellas. Toses 73.'0I 1
l I
TXX-88422 c.
April 29, 1988
'l Page 2 of 2 Section IV Adds a new Section IV to describe the administrative controls to be used to support the fire protection program..This section provides the information.to support removal of fire protection surveillances from the Technical Specifications.
Section v l
Replaces previous Appendices with the following:
1.
CPSES Fire Protection Program Separation Criteria Comparison Table, Appendix A.
i 2.
Fire Hazards Analysis Evaluations Matrix, Appendix 8.
3.
Deviations, Appendix C.-
4.
Fire Hazards Analysis Figures, Appendix 0.
Note: The previous Deviations submitted on the Docket are now i
included as Appendix C to the Fire Protection Report.
e Very truly yours, l
i W. G. Counsil i
JOS/mgt i
Attachment Enclosure c - Mr. R. D. Martin - Region IV (clo)
Resident Inspectors, CPSES (3 copies - clo)
.I
' Attachment to TXX-88422 April 29, 1988
]
Page 1 of 12 FPR SECTION DESCRIPTION General Adds Fire Protection Systems and Equipment Requirements from the Technical Specifications to FPR Section IV.
Revises the appendices and includes them asSection V.
1-1.2.5 Provides new definition for Alternate Shutdown Area.
i I-1.2.11 Clarifies the types of cable failures.
l 1-1.2.13 Provides new definition for Compensatory Measure.
i 1-1.2.17 Provides new definition for FHA Evaluation.
I-1.2.23 Combines definition of safe shutdown with definition of fire safe shutdown.
1-1.2.29 Provides new definition for Functional Test i
1-1.2.32 Provides new definition for Hot Shutdown Panel (HSP).
j 1-1.2.36 Clarifies the definition of Local Control.
1 1-1.2.37 Clarifies the definition of Manual Operation.
j l-l.2.40 Provides new definition for Operable.
I I-1.2.45 Clarifies the definition of Pre-fire.
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l-1.2.57 includes previously omitted portion of sentence, j
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Attachment to TXX-88422 April 29, 1988 Page 2 of 12 JUSTIFICATION Section Description 11-1.1 Delete background section.
11-1.2.4 Changes FHA drawings to FPR figures to identify the correct reference drawings.
(This change is made throughout).
Remove reference to submittal of deviation, because they are now contained in Appendix C of Section V of the Fire Protection Report.
Adds references to be made in F.P. Features Section for Deviations.
Adds reference to Appendix A of this FPR for identification of areas having no fire safe shutdown equipment and no fire safe shutdown cabling.
Clarifies that this equipment list does not address cabling required for fire safe shutdown.
11-1.2.5 Adds new section to F.P. Features for NFPA Code Compliance Deviations.
11-3.2 Discusses use of representative burning curves for isolated cases in establishing MPFL.
11-3.3 Adds reference to Section IV.
11-3.4 Same as 11-3.3 11-3.7 Adds assumption for separation criteria.
!!-4.1 Adds H.E.L.B. discussion for vent areas in general methodology discussion, 11-4.2 References FHA drawings and DBD-ME-001.
11-4.3 Adds discussion for FHA Evaluations for area boundaries which are not rated.
Same as 11-1.2.4.
11-4.4 Adds reference to Section Ill - 5.0 for Potentially Failed Fire Safe Shutdown Equipment.
Adds reference and clarification of fire safe shutdown cabling.
11-4.5 Adds manual suppression to F.P. Features.
4 Attachment to TXX-88422 April 29, 1988 l
Page 3 of 12 Section Revision 11-4.5(2)
Changes "no intervening combusti51es" to "negligible intervening combustibles" to correctly J
identify the existing conditions.
(This change is i
made thre9ghout).
To account for the use of FHA evaluations.
(This change is made throughout.)
II-4.5(3)
Clarifies the wording to make the section understandable.
Same as 11-4.5(2).
11-4.6 Deletes reference to INDMS software for fixed exposed cabling.
r 11-5.1.1.1 Same as 11-1.2.4.
l r
11-5.1.1.4 Changes "Engineering evaluations" to "Fire Hazards l
Analysis Evaluations" to accurately reflect the document use.
(This change is made throughout.)
Changes "partial area wide" to "partial' to avoid confusion.
j 11-5.1.1.5 Updates MPFL value using "C-Curve" and provides explanation.
Il-5.1.2.1 Same as !I-1.2.4.
3 j
11-5.1.2.4 Same as !!-5.1.1.4.
i Changes "train" to "set" to clarify wording.
11-5.1.2.5 Same as 11-5.1.1.5.
11-5.1.3.1 Same as 11-1.7.4.
4
^
11-5.1.4.1 Same as !!-1.2.4.
i 11-5.1.4.4 Changes "Engineering evaluations" to "Fire Hazards Analysis Evaluations" to accurately reflect the document use.
(This change is made throughout.)
1 11-5.1.4.5 Same as 11-5.1.1.5.
11-5.1.5.1 Same as !!-1.2.4.
j
!!-5.1.5.4 Same as 11-5.1.4.4.
11-5.1.5.5 Updates MPfl. values for fire zones.
j same as !!-5.1.1.5.
11-5.1.6.1 Same as !!-1.2.4.
i
-. _ _ _ _ _ _.... _. -. _,.. _. _ _ _ _,, _, _.. _. _, ~ _... _ _ _, _ -,,, _.... _, -., _ _ _. _.. _ _. - _. _ _.. _ _ -, _.
Attachment to TXX-88422 April 29, 1988 Page 4 of 12 o
Section Revision 11-5.1.7.1 Same as 11-1.2.4.
11-5.1.7.4 Changes wording to avoid confusion about type of sprinkler system provided.
11-5.1.8.1 S a n.- as !!-1.2.4.
11-5.1.9.1
- ame as 11-1.2.4.
11-5.1.9.4 Same as !!-5.1.7.4.
11-5.1.10.1 Same as 11-1.2.4.
11-5.1.11.2 Same as 11-5.1.1.4.
11-5.1.12.1 Same as 11-1.2.4.
11-5.1.13.1 Same as 11-1.2.4.
11-5.1.14.1 Same as 11-1.2.4.
11-5.2.1.1 Same as 11-1.2.4.
11-5.2.1.5 Same as 11-5.1..l.5.
11-5.2.2.4 Same as 11-5.1.4.4.
Changes "train" to "set" to clarify wording.
11-5.2.2.1 Same as 11-1.2.4.
11-5.2.3.1 Same as 11-1.2.4.
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l 11-5.2.4.1 Same as 11-1.2.4.
\\
11-5.2.5.1 Same as 11-1.2.4.
11-5.2.6.1 Same as 11-1.2.4.
11-5.3.1.1 Same as 11-1.2.4.
11-5.3.1.4 Changes "train" to "set" to clarify wording.
Same as 11-5.1.1.4.
i 11-5.3.1.5 Same as 11-5.1.1.5.
i 11-5.3.2.1 Same as 11-1.2.4.
11-5.3.2.4 Change description of barrier from "three" to "two" hours to agree with Section 11-5.3.2.2.
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Attachment to TXX-88422 April 29, 1988 Pago 5 of 12 t
.Section Revision II-5.3.3.1 Same as Il-1.2.4 Il-5.3.3.4 Same as 11-5.1.4.4.
11-5.3.4.1 Same as !!-1.2.4.
11-5.3.4.4 Same as !!-5.1.4.4.
f 11-5.3.5.1 Same as II-1.2.4.
11-5.3.5.4 Same as !!-5.3.2.4 to agree with Section 5.3.5.2.
11-5.3.5.5 Updates MPFL values for fire zones.
!!-5.3.6.1 Same as 11-1.2.4.
a II-5 3.7.1 Same as 11-1.2.4.
11-5.3.7.5 Updates new MPFL values for the fire zones.
11-5.3.8.1 Same as 11-1.2.4.
11-5.3.8.4 Same as 11-5.1.1.4.
11-5.3.8.5 Updates new MPFL values for the fire zones.
II-5.3.9.1 Same as 11-1.2.4.
1 11-5.3.10.1 Same as !!-1.2.4.
11-5.3.11.1 Same as 11-1.2.4.
11-5.4.1.1 Same as !!-1.2.4.
!!-5.4.1.4 Changes "partial area wide" to "partial" to avoid 1
confusion.
II-5.4.1.5 Updates new MPFL values for fire zones.
11-5.4.2.1 Same as !!-1.2.4.
11-5.4.2.2 Changes wording to avoid generic referencing.
11-5.5.1.1 Same as 11-1.2.4.
I 11-5.5.1.4 Changes wording to avoid generic referencing, j
11-5.6.1.1 Same as !!-1.2.4.
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Attachment to TXX-88422 i
April 29, 1988 l
Page 6 of 12
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Section Revision 11-5.6.1.5 Delete Lube Oil and Diesel fuel as types of l
combustibles.
Updates combustible loading to delete these combustibles.
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11-5.6.2.1 Same as !!-1.2.4.
11-5.6.2.4 Same as 11-4.5(2).
11-5.7.1 Same as 11-1.2.4.
l Same as 11-4.5(2),
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11-5.7.1.4 Same as 11-4.5(2) and 11-1.2.4.
11-5.8.1.1 Same as 11-1.2.4.
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11-5.8.1.2 Adds the word "Electrical" to "Duct Banks" to i
clarify type of ducts.
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!!-6.1 Adds NFPA Code Compliance Deviations to F.P.
Features Section.
!!-6.2.2 Identifies the reference of deviations to BTP i
APCSB 9.5-1.
Adds a discussion for one hour wraps.
l 11-6.2.3 Adds reference to Appendix C for deviations for 4
i Interior finish.
l 11-6.2.4 Same as 11-6.2.2.
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Adds discussion of high energy line break into air i
t flow requirement discussions.
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11-6.2.5 Same as !!-6.2.2.
Clarification of internal conduit seals to provide
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a more accurate description.
11-6.3.1 Adds identification of FHA Evaluations and j
reference to Appendix B.
i Clarifies discussion of supervision of water flow 1
and valves.
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Attachment to TXX-88422 April 29, 1988 Page 7 of 12 Section Revision 11-6.3.2 Addition of the new water supplies utilized at CPSES.
11-6.3.3 Same as 11-6.3.2.
11-6.3.4 Same as !!-6.1, a-L i
11-6.3.5 Same as 11-6.3.1.
a Deletes discussion of non-compliance with NFPA 12A.
Provides clarification to descriptions for manually actuated pre-action systems and open head water spray systems.
11-6.5 Adds clarification to discussion of RCPLOCS.
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11-6.6 Clarifying the emergency lighting section to i
provide a more thorough and accurate description, j
11-6.8 Adds section 6.8 to identify and justify NFPA Code
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Deviations.
11-7.1 Deletes NFPA 15, 1985 to correct a typographical i
error.
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Attachment to TXX-88422-Page 8 of 12
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April 29, 1988.
FPR SECTION/PAGE DESCRIPTION 111-1.1 Deletes reference to "additional requirements" that are not used.
111-1.2 Changes "required" to "supporting" information to reflect its usage. Clarifies the event as being coincident with a single fire and loss of off site power and the database references.
111-3.1.2 Changes "scram" to "reactor trip".
l Deletes transition to cold shutdown because it is addressed in following statements.
111-3.1.4.2 Deletes MHIF study description because it is available in other site documents.
References to conservative engineering practices and spare feeder breakers because credit is not taken for them, i
Adds another resolution for correcting potential common power supplies concerns.
Updates the basis utilized for common power supply concerns and CPSES position on MHIF and
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breaker / fuse coordination for clarity, 111-4.2.1.6 Updates the list of systems utilized to provide support services.
111-4.2.2.2 Includes associated circuits of ccin ern.
3 111-4.2.2.4 Adds description as to how CR/CSR cables and circuits are treated.
4 111-4.2.2.5 Adds Fire Safe Shutdown Systems List.
111-4.2.4 Clarifies protection separation and manual operations credited for mitigating potential j
spurious operations.
1 111-4.3 Changes "could be used to justify" to "are used to assess the significance..." to reflect current usage.
Ill 4.3.1 Clarifies the use of deviations, i
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April 29, 1988 Page 9 of 12
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FPR SECTION/PAGE DESCRIPTION 111-4.3.2 Includes specifics of the operation practices requiring alternate shutdown.
Adds CR-HVAC Mechanical Equipment Room as another area that could require alternate shutdown making it consistent with the FSAR.
Deletes reference to CPSES emergency guidelines and includes reference to CPSES abnormal operation f
procedures.
111-4.3.2.1 Description of Alternative Shutdown Areas.
111-4.3.2.3.1 Indicates that upon the confirmation of a fire requiring the evacuation of the Control Room the reactor is tripped manually from the Control Room.
Indicates control power for the Emergency Diesel Generator operation can be switched at the EDG engine control panel for CSR fires. Clarifies J
that credit is not taken for additional control room manual actions.
r Deletes an example of a spurious operation.
111-4.3.2.4 Deletes reference to "transition to cold shutdown" as it is addressed in the next paragraph.
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i 111-4.3.2.4.1 Deletes reactor operator actions, as detailed l
operator actions are available in applicable CPSES
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procedures.
4 111-4.3.2.4.2 Deletes reference to additional operators and fire brigade availability as they are not credited for i
fire safe shutdown, i
111-4.3.2.4.3 Deletes reference to additional operators and extinguishment of fire because credit is not taken for them for hot standby conditions.
Clarifies when plant cooldown would generally be initiated, and that the cool down phase requires the availability of additional systems and components.
III-5 Updates Fire Safe Shutdown Equipment list.
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Attachment to TXX-88422 April 29, 1988 Pag @ 10 of 12
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FPR SECTION DESCRIPTION Throughout The Fire Protection Technical Specification Section IV Surveillances have been reformatted and placed within the FPR for clarity, ease of technical application and to provide site specific in formation.
The section has been divided into categories (i.e., tests / inspections, compensatory measures, operability requirements, etc.) with each respective system's requirements listed within each section.
Additional information has also been incorporated to explain each section which transforms the information into a easily i
usable and understandable document.
Significant changes from the technical specifications submitted per letter logged TXX-6905, dated October 30, 1987 have been identified and justifications provided.
IV-2.1.a Delineates the requirements of each type of 1
detector.
Revise the trip actuating device operational test to a functional test to accommodate what is the standard of practice for testing of fite protection detectors. A trip actuating device operational test, as defined, is not an attainable test under field conditions for the listed devices.
A functional test as defined is attainable and gives an adequate measure of operability of the system.
IV-2.1.d.1 Changes "tank weight" to read "tank liquid content" so that the statement is in agreement with weight or level measurements being conducted, s
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Page 11 of 12 l
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l FPR SECTION DESCRIPTION IV-2.1 9 Revises the surveillance criteria for fire rated assemblies.
Fire rated assemblies are of equal or more substantial construction than penetration seals and.are not subject to degradation that will not'be adequately detected under this surveillance schedule.
Fire doors, a commodity with substantial usage and operability requirements are surveilled on a more frequent schedule to account for the increased potential degradation.
A Section IV Deletes detection and suppression systems for Tables 1 and 2 atmospheric clean up units.
These systems are i
installed per Regulatory Guide 1.52, are not required for fire safe shutdown and do not present a hazard to fire safe shutdown components.
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Attachment to TXX-88422 April 29, 1988 Page 12 of 12 DEVIATIONS CHANGE JUSilFICATIONS Section Description Section V Replace "Comparison to DBD-SY-1" with "CPSES Fire App. A Protection Program Fire Area Comparison Table."
Section V Replace "Comparison to FPPR" with "Fire Hazards App. B Analysis Evaluation Matrix."
Section V Correct Deviation 3a and 3a-1 to reflect current App. C plant design.
Update Deviation 10 to reflect the final plant design of the DC Emergency Lighting provided for the control room.
Section V Include actual Figures instead of referencing FHA App. D Drawings.
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