ML20214U859
| ML20214U859 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 06/03/1987 |
| From: | Hunsader S COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20214U862 | List: |
| References | |
| 3166K, NUDOCS 8706110365 | |
| Download: ML20214U859 (8) | |
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_ % One First Nelional Plaza Chcogo,IEnois -
/ Address Reph to: Post Omco Box 767
'd Chcogo, luinois 80810 0767_ -
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' June 3,-1987 i:
Mr.' Thomas E. Murley,' Director Office of. Nuclear Reactor Regulation U.S.. Nuclear Regulatory Commission 1 Washington, DC 20555
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Subject:
. Byron Station Units 1 and 2 Braidwood Station Units-1 and 2 4
Fire Protection Report --Amendment-10 NRC Docket Nos. 50-454/455 and 50-456/457 1
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References:
(a) August 116, 1982 letter from T.-R. Tramm
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to H. R. Denton i
(b) May'22, 1986 letter-from A. D.'Miosi to H.~R. Denton (c) June 11, 1986 letter from K. A. Ainger 4
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to H. R. Denton I
Dear Mr. Murley:
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..This letter provides Amendment 10 to the Byron /Braidwood Fire
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Protection Report (FPR) which was submitted in Reference-(a). This amendment up, dates the FPR to incorporate new and revised information
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applicable to the Byron and Braidwood Stations. These changes do not represent a decrease in the level of fire protection which require prior NRC approval according to the following: a) Condition 2.C.6 of the Byron Unit 1 i
Operating License, NPF-37; b) Condition 2.E of the Byron Unit 2 Operating
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License, NPF-66; or c) Condition 2.E of the Braidwood Unit 1 Operating License, NPF-70.
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Amendment 10 includes a new Section 2.4 and Appendix AS.8 providing 1
the Braidwood Unit 2 safe shutdown analysis and Appendix R (Section III.G.2) j deviations, respectively. Other miscellaneous changes are included throughout the FPR. These other changes can generally be categorized as j
either editorial ~in nature, or as changes 'to reflect the latest "as-built"
-condition of the plant. Attachment A to this' letter provides an itemized i
summary and explanation of all changes included in'this amendment.
j-Attachment B to this letter provides a comparison of the new
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Braidwood Unit 2 safe shutdown analysis against the Braidwood Unit 1.and Byron Unit 2 analyses, i
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- Attachment c to this letter provides a comparison of the new
.Braidwood Unit 2 Appendix R deviations against'the Byron Unit 2 deviations.
This comparison was done because the plant configuration of Braidwood Unit 2 more closely matches that of Byron Unit 2 than Braidwood Unit 1.
Please direct any questions regarding this matter to this office.
One signed original and forty (40)' copies of this letter, the attachments, and Amendment 9 are provided for your_use.
Very truly yours,
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- =Y S. C. Hunsader Nuclear Licensing Administrator Attachment I
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3166K l
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ATTACHMENT A Page No.
Description of Changes -
2.3-16, 17 and The changes on these pages provide a clarification of 18 the description of detection and suppression capabili-ties for a portion of the electrical cable tunnels (Fire Zones 3.1-1/3.1-2). This FPR change' involves only a more detailed description, as no changes in plant design are involved.
2.3-21, 25, 27, The reference to Appendix A5.4 has been deleted from 30, 33, 35, 39, the text.
Refer to the discussion of the changes to 42, and 46 Appendix AS.4 for more details.
2.3-78 A brief description of some office structures located within this zone is added for completeness.
2.3-103 The method of sealing the equipment hatch in the slab at elevation 364'-0" is added to the text. This change was requested by the NRC Staff.
2.3-104 A description of the sprinkler system around the stair-well in the slab at elevation 364'-0" is added. This change was requested by the NRC-Staff.
2.3-109a The method of sealing the equipment hatch in the slab at elevation 364'-0" is added to the text. This change was requested by the NRC Staff.
2.3-111a A description of draft stops installed around the stair-well at P/18 is added to the text. This change was requested by the NRC Staff.
2.3-113 The list of equipment provided with Appendix R emergency lighting.s deleted from the " Protection-Criteria and Measures" section. This particular change was inadver-tently left out of Amendment 9, in which similar changes were made throughout Section 2.3 of the FPR.
2.3-125a A description of draft stops installed around the stair-well at P/18 is added to the text. This change was requested by the NRC Staff.
2.3-136 The method of sealing the equipment hatch at Q/12 in the slab at elevation 426'-0" is added to the text.
This change was requested by the NRC Staff.
2.3-137 A description of the draft stops installed around the stairwell at P/18 is added to the text. This change was requested by the NRC Staff.
Attachment A Page 2
.Page No.
Description of Changes 2.3-140 The addition of sealant around the steel plates covering the equipment hatch in the slab at elevation 426'-0" is described by this change. This: change was requested by the NRC Staff.
2.3-141b The method of sealing the equipment hatch at Q/12 in the slab at elevation 426'-0" is added to the text. This change was requested by the NRC Staff.
2.3-143 A description of the draft stops installed around the stairwell at P/18 is added to the text. This change was requested by the NRC Staff.
2.3-144 The addition of sealant around the steel plates covering the equipment hatch in the slab at elevation 426'-0" is described by this change. This change was requested by the NRC Staff.
2.3-190 The reference to Appendix A5.4 has been deleted from the text.
Note for 2.3 An explanatory note is added before color-coded composite Drawings drawings 2.3-1 through 2.3-41.
The note explains that the drawings are prepared from many different design documents, and that the base design documents should be referred to to ascertain specific design details.
New pages 2.4-1 New Section 2.4 provides the Braidwood Unit 2 safe shutdown through 2.4-225 analysis. Attachment B compares this analysis with the (Braidwood-2)
Braidwood Unit 1/ Byron Unit 2 analyses.
3.5-5 A clarification is added to the BTP conformance section explaining that NFPA92 is no longer an NFPA code, and that the requirements formerly contained in that code are now contained in other codes.
AS.4-4, 5, 7, Tables A5.4-3 through A5.4-7 have been deleted.
References 9, 9a, 12, 12a to these tables have been deleted from the listed pages, and also from the Fire Hazards Analysis (Section 2.3).
The specific data for each system is available at each station on installation drawings.
Furthermore, pre-i operational and surveillance test data for these systems are available at each station.
j A5.4-6 The changes on this page are editorial in nature.
A5.4-8 and 9 Differences between the Halon systems at Byron and Braid-wood are explained by the text changes on these pages.
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Attachment A Page 3 Page No.
Description of Changes AS.4-10 The capacity of the C02 storage tank is clarified.to be 10 tons, not 20 tons as listed. This is not a design change,-but a correction of an error in-the FPR. The remaining changes on this page are editorial in nature.
A5.4-13 The figure references on this page are corrected. This change is editorial.
AS.7-1 Specific station procedure numbers have been deleted from Appendix A5.7.
The changes to the introduction reflect this.
A5.7-3 In the first paragraph, incorrect FPR section references
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Other changes on this page delete refer-ences to specific station procedures.
In the seventh paragraph,-the inspection interval is changed from
" weekly" to " periodic."
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A5.7-4, 7, References to specific station procedures are deleted.
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AS.7-14 Editorial changes are made in the first paragraph, and
- references to specific station procedures are deleted.
i A5.7-16 References to specific station procedures are deleted.
AS.7-19 References to specific station procedures are deleted.
Also, in the last two paragraphs, the inspection intervals are changed from " weekly" to " periodic."
A5.7-20 References to specific station procedures are deleted.
AS.7-21 References to specific station procedures are deleted.
Also, in the first paragraph, the statement that welding and ".ame cutting work is done "with a special permit" is changed to "in accordance with NFPA 51B."
A5.7-22, 23, References to specific station procedures are deleted.
and 24 A5.7-27 References to specific station procedures are deleted.
In the last paragraph, the statement that " security" will walkdown fire doors is changed to " personnel."
A5.7-28 Since the RCP drip pans have already been installed, the statement that they were being fabricated and would be installed prior to fuel load is deleted.
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Attachment A Page 4 Page No.
Description of Changes AS.8.3-1 (BY-1)
The commitment to add draft stops around the stairwell and concrete hatch covers over the equipment hatch is added.
A5.8.3-3(BY-1)
A typographical error is corrected.
A5.8.3-12(BY-1)
A previously unsealed penetration has been sealed, and the table data.is revised to reflect this.
AS.8.4-1 (BY-1)
The commitment to add draft stops around the stairwell 4
and concrete hatch covers over the equipment hatch is added.
A5.8.4-4(BY-1)
A previously unsealed penetration has been sealed, and the table data is revised to reflect this.
A5.8.5-1 (BY-1)
The comitment to add draft stops around the stairwell and A5.8.6-1 (BY-1) and concrete hatch covers over the equipment hatches is
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added.
A5.8.7-1 (BY-1)
The commitment to seal the steel hatch covers in place with caulk is added.
A5.8.8-1 (BY-1)
The commitment to upgrade the wall separating the RHR pump rooms to a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rated barrier is added.
A5.8.15-1 (BY-1)
A description of the partial height masonry walls separating the component cooling pumps is added. At Byron, these walls have been present all along, thus this is not a recent design change.
A5.8.3-1 (BY-2),
The commitment to add draft stops around the stairwell A5.8.4-1 (BY-2) and concrete hatch covers over the equipment hatches is A5.8.5-1 (BY-2),
added.
and A5.8.6-1 (BY-2)
A5.8.7-1 (BY-2)
Correction of an incorrect table reference.
I A5.8.3-1 (BR-1)
The commitment to add draft stops around the stairwell A5.8.4-1(BR-1),
and concrete hatch covers over the equipment hatches is A5.8.5-1 (BR-1),
added.
and A5.8.6-1 (BR-1)
New Appendix New Appendix R deviations A.1 through A.24 and C.1 through A5.8 for C.8 are added for Braidwood Unit 2.
Attachment C pro" ides Braidwood-2 a comparison of the Braidwood Unit 2 Appendix R devi" 'ons against the corresponding Byron Unit 2 deviations.
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ATTACHMENT B Comparison of Braidwood-2 Safe Shutdown Analysis with Previously Submitted Analyses Reference (b) submitted to the NRC Staff a detailed comparison of the Braidwood-l Safe Shutdown Analysis against the Byron-1 Safe Shutdown Analysis.
Reference (c),
Attachment B, provided a detailed comparison of the Byron-2 Safe Shutdown Analysis against the Byron-1 Safe Shutdown Analysis.
Since the Braidwood-2 Safe Shutdown Analysis methodology and format are identical to the Braidwood-1 and Byron-2 analyses, a detailed comparison against Byron-1 is not provided.
Rather, a general comparison with the Braidwood-1/ Byron-2 analyses is provided in the following pages, since this is felt to be more relevant and hence more useful to the Staff reviewers.
Section 2.4.1 is identical to the equivalent Braidwood-1/ Byron-2 sections, with the exception of the specific procedure references in the text.
In particular, the method of analysis and assumptions used in the analysis are identical. The equipment list presented in Table 2.4-2 is identical, with the exception of unit /
site specific differences.
Thus, the detailed description of equipment differences from the Byron-1 list provided in References (b) and (c) are valid also for Braid-wood-2. The list of fire zone repair descriptions in Braidwood-2 Table 2.4-3 are similar to the previous units. The affected equipment, repair description, and required material is the same. Specific zones where a given repair is required differ due to minor differences in cable routings.
This illustrates that the criteria for taking credit for repairs is the same.
Table 2.4-4, the list of equipment and cables in each fire zone, is identical in format to the equivalent Braidwood-1/ Byron-2 tables.
Equipment locations are the same; however, minor i
cable routing differences exist.
The zone by zone safe shutdown analysis for Braidwood-2 in Section 2.4.2 corresponds very closely with the Byron-2 analysis, except for site-related differences. Minor differences in cable routings exist, but equipment locations correspond exactly (except for site unique equipment).
Zones with Appendix R deviations correspond exactly.
In general, where modifications were required to achieve a level of sepa-ration acceptable to the staff, the zones which required modifications and the actual modifications were the same at Braidwood-2 as at Byron-2.
In a small number of cases, different divisions were protected at Braidwood-2 than at Byron-2; however, the same level of protection was achieved in each case.
In other words, if a three hour rated barrier was provided in a given zone at Byron-2, a three hour rated barrier was also provided at Braidwood-2.
i The high-low pressure interface analysis in Section 2.4.3 is essentially identical to the Braidwood-1/ Byron-2 analyses. The same three high-low pressure interfaces have been identified for each unit. The evaluation method and the resolution of zone conflicts are the same in all cases. However, due to minor cable routing differences, the postulated failure modes may not occur in exactly the same zones.
r ATTACHMENT C Comparison of Braidwood Unit 2 Appendix R Deviations Against the Byron Unit 2 Appendix R Deviations The Braidwood-2 Appendix R deviations are compared with the Byron-2 deviations because the plant configuration more closely matches Byron-2 than it does Braidwood-1. This comparison is thus felt to be more meaningful. Note that there is an exact one-to-one correspondence between Braidwood-2 deviations A.1 through A.24 and C.1 through C.8 and the Byron-2 deviations of the same number.
In other words, the same zones and equipment are involved in corresponding deviations.
In all cases except those specifically discussed below, the deviations correspond exactly, including sepa-ration distances and protection provided.
The four deviations discussed below differ in some aspect from the corresponding Byron-2 deviations. These differences are explained.
Deviation A.3 -- At Braidwood-2, Division 22 cables on elevations 346'-0" and 364'-0" were protected with a three hour rated barrier. At Byron-2, the Divi-sion 21 cables were protected.
This difference does not affect the deviation, since the same division of cables is protected on each elevation.
Deviation A.4 -- At Braidwood-2, Division 22 cables are protected on elevation 364'-0" and Division 21 cables are protected on elevation 383'-0".
At Byron-2, Division 21 cables were protected on both elevations. The redundant cables on these elevations are not located above one another, including a 20 foot allowance for horizontal spread of fire. Thus, should a credible fire spread from one elevation to the other, redundant cables from both divisions would not be affected.
Deviation C.1 -- The physical separation of the redundant PORV power and control cases is less at Braidwood-2 than at Byron-2, due to differences in field-routed conduit. Outside of the pressurizer cubicle, the minimum separation for Braid-wood-2 of 2 feet is less than the Byron-2 separation distance of 15 feet. At the penetration area, the minimum vertical separation distance of 13 feet at Braid-wood-2 is marginally less than the 14 foot vertical separation distance at Byron-2.
The PORV power cables are routed individually in conduit (i.e., no other cables are routed in the same conduit) inside containment to prevent fire-induced spurious operations. Also, as stated in the deviation description, loss of control of the PORV's would not prevent safe shutdown, since cooldown and depressurization can be accomplished by alternative means. Thus, the reduced separation distances are not of concern.
Deviation C.5 -- At Braidwood-2, the subject cables have a minimum vertical sepa-ration distance of 20 feet vs. 15 feet at Byron-2. Since the vertical distance is greater, and the horizontal separation is unchanged, this minor difference should not affect the deviation.