TXX-6376, Forwards Comments on NUREG-0797,SSER 12,Section 9.5.1, Fire Protection. Technical Basis for Fire Protection Program Remains App a to Apcsb 9.5-1 & 10CFR50.48(a),Footnote 3

Forwards Comments on NUREG-0797,SSER 12,Section 9.5.1, Fire Protection. Technical Basis for Fire Protection Program Remains App a to Apcsb 9.5-1 & 10CFR50.48(a),Footnote 3

ML20215H560
Person / Time
Site:	Comanche Peak
Issue date:	04/15/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-NUREG-0797, RTR-NUREG-797 TXX-6376, NUDOCS 8704200404
Download: ML20215H560 (11)

Text

, -

m

---

r.-- Log # TXX-0376

- " ' = File # 10010

$ 909.5

= = Ref: 10CFR50.48(e) 1UELECTRIC April 15, 1987 William G. Counsil Decutive Vice Premient U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-445 FIRE PROTECTION PROGRAM

REFERENCE:

1. NUREG-0797 Supplement No.12 CPSES Safety Evaluation Report

2. NRC Inspection Report 50-445/84-44 dated January 11, 1985.

Gentlemen:

We have reviewed SER Supplement 12, Section 9.5.1, " Fire Protection," and are providing the attached comments. These comments contain clarifications of the CPSES Fire Protection Program as they relate to the NRC's SER discussion, as well as updates of the CPSES program that have occurred since the completion of the Staff's review. Other less significant issues are not detailed in these comments.

In addition to the attached comments, we note that the Staff has used our May 7, 1982, Alternate Shutdown Study for the evaluation of the CPSES fire safe shutdown capability. The May.7 submittal has been amended by the CPSES Fire Protection Program Review (FPPR) Revision 3. The FPPR Revision 0 was provided for review in draft form during the NRC's 1984 5 1re Protection Audit and was subsequently transmitted to the Staff as an attachment to our letter logged TXX-4358 dated December 20, 1984. It has since been incorporated into CPSES Design Basis Documents (DBD) which will be available for closure of the related Fire Protection Audit open item (see Reference (2)) during the follow-up inspection.

Please note that although the Staff has chosen to review the CPSES Fire Protection Program to the guidelines of Branch Technical Position CMEB 9.5-1 of NUREG-0800, CPSES is committed to Appendix "A" to APCSB 9.5-1 as documented in the FSAR (and supplemented by formal correspondence) and in accordance with 10CFR50.48(a),

footnote 3. These commitments continue to be the technical basis for the CPSES Fire Protection Program.

In Reference (1) the Staff concludes that the CPSES Fire Protection Program is acceptable. Although subsequent modifications have been performed, (due in part to closure of open items identified in Reference (2) ) the technical basis of the fire protection program remains substantially unchanged.

8704200404 870415 O O

PDR ADOCK 05000445 E PDR g 400 North Olise Street LB 81 Dallas, Texas 75201

TXX-6376 1 April 15,~1987 Page 2 of 2 A follow-up inspection to close all remaining Fire Protection Audit open items,- as identified in Reference (2), is being scheduled.

Should you have questions relating to the attached comments or require additional information in support of the follow-up inspection, please contact Jimmy Seawright at (214) 979-4375.

Very truly yours,

$? fi W. G. Counsil JDS/amb Attachment c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV i

j, .-

) Attachment to TXX-6376 i April 15,-1987 Page 1 of 9 j

i SSER 12 DESCRIPTION DISCUSSION CLARIFICATION / COP 9iENTS

SECTION

) SSER Section (3) A fire at the hot (3) A fire at the hot Typo:

I 7.4.2, shutdown panel area shutdown panel area-1 Paragraph I damages train B; safe damages train B; safe Technical' basis

] (Item #3), shutdown can be per- shutdown can be per- remains the same.

4 Page 7-6 formed from the con- formed from the con-

! trol room using train trol room using train i B equipment. A equipment.

?

t

SSER Section ... The hot shutdown The' train B control cir- Clarification

I 7.4.2, panel has both train A cuits'are not energized Paragraph 2, and B safe shutdown until the local transfer Technical basis remains Page 7-6 instrumentation. The switch is set to the the same.

j indicators and the local position and the 4 train B control circuits control function has

are energized all the been transferred from j time...." the control room to the I hot shutdown panel.

, SSER Section "

....All the control Only required train A control Clarification:

l 8.4.6, functions are transferred functions are transferred at the l Paragraph 3 to the hot shutdown panel shutdown transfer panei. For Alternate Shutdown j Page 8-1 by placing the transfer / only one train of safe

! isolation switches, which ".... transfer / isolation shutdown systems are

! are located in standby switches, which are- required at the HSP.

j transfer panel, to the located in the shutdown

local position... ." transfer panel . . . ." Typo

i Technical basis remains j the same.

4 I

Attachment to TXX-6376 April 15, 1987 Page 2 of 9 SSER 12 DESCRIPTION DISCUSSION CLARIFICATION / COMMENTS SECTION SSER Section "

... Three-hour-fire- The CPSES fire rated pene- CPSES commits to providing 9.5.1.4 rated penetration seals tration seals are provided penetration seals in accordance Paragraph 2 are provided for all in accordance with APCSB with App. A to APCSB 9.5-1, in Page 7-6 penetrations of fire- 9.5-1 Appendix A Section FSAR Sections 9.5.1.6.1-D.3.d rated walls and floors / D.I.j & D.3.d, except for and 9.5.1.6.1-D.I.j.

ceilings tested in spare conduit sleeves.

accordance with BTP CMEB 9.5-1 Section C.5.a(3), except for spare conduit sleeves SSER Sectior "

... The heating, This description applies to Clarification:

9.5.1.4 ventilation, and air both 2 and 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire-rated Paragraph 4, conditioning (HVAC) barriers, unless discussed CPSES has committed to providing Page 9-6 penetration of fire- in an applicable deviation fire dampers in walls having a rated barriers are or justification. fire rating of 2 hrs. or greater provided with UL - in FSAR Section 9.5.1.5.4 except labeled fire dampers as noted in FSAR Reference (20).

assemblies that have Ref. (20) is letter TXX-4265 ratings commensurate with dated 8-16-84.

the fire ratings of the walls in which they are Technical basis remains the same.

installed...."

6

. c.

Attachment to TXX-6376 April 15, 1987 i Page 3 of 9 SSER 12 DESCRIPTION DISCUSSION CLARIFICATION / COMMENTS SECTION SSER Section "....The applicant has Only safe shutdown related Clarification:

Paragraph 6, provided justification cables of redundant divi-Page 9-6 that sufficient protec- sions within 20 ft. of the The Justification provided in tion is provided for penetration are protected FSAR Section 9.5.1.4 reference

, safe shutdown equipment by 1-hour-fire barriers. 20 (TXX-4265 dated 8-16-84) without the presence of states that redundant division the subject fire dampers, raceway within 20 ft. of the The justification has HVAC penetration are protected shown that (1) steel by I hr. rated barriers, i ductwork itself provides protection against fire Technical basis remains the same.

propagation for I hour,

(2) no safe shutdown equipment is located within 20 ft. of any of the subject penetrations, (3) any safe shutdown i related cables of redun-i dant divisions are pro-i tected by 1-hour-rated fire barriers, and (4)

automatic suppression systems are installed in 4

all safety-related areas where combustible loading exceeds 45 minutes...."

i I

3 s

Attachment to TXX-6376 April 15, 1987 Page 4 of 9 SSER 12 DESCRIPTION DISCUSSION CLARIFICATION / COMMENTS SECTION SSER Section .... Fire exit routes Fire exit routes Clarification:

9.5.1.4 will be clearly marked are established by Paragraph 2, and established by design documents. Fire exit routes were established Page 9-8 prefire plans...." and adequate markings were provided to ensure that safe evacuation of personnel is achieved.

SSER Section ....The applicant Information on the Typo:

9.5.1.4 provided information safe shutdown capa-Paragraph 3, on the safe shutdown bility following a fire Technical basis remains the same.

Page 9-8 capability following at Comanche Peak is ap-a fire at Comanche plicable to Unit 1 only.

Peak Units I and 2...."

SSER Section ....For cold shutdown, Pressurizer heater control Update / Revision:

9.5.1.4 the pressurizer heater and auxiliary sprays are Paragraph 4, controls, auxiliary no longer required for This update will allow closure Page 9-8 sprays and... residual safe shutdown. of Item 50-445/8444-08 heat removal system (reference 2) during the l would be available. .. ." follow-up inspection.

l l

t

j .

. Attachment to TXX-6376 I April 15, 1987 l Page 5 of 9 i

l l SSER 12 DESCRIPTION DISCUSSION CLARIFICATION /COMENTS SECTION

! SSER Section ....The applicant Other allowable cor- Clarification:

i 9.5.1.4 reviewed the breaker rective actions (not 1 Paragraph 4, fuses and recalibrated identified by the Staff In addition to methods referred i Page 9-9 or replaced any breaker in the SER) include: removal; in SER, other types of corrective

, fuses that were not reset after fire; protect or actions are allowable. The

properly coordinated reanalyze safe shutdown alternate actions were submitted cr selected...." with impact included for in letter TXX-4527 dated 8-5-85.

any breaker fuses that were not properly coordinated. Technical basis remains the same.

$ Paragraph 5 "....For cooldown/ cold The pressurizer auxiliary Update / Revision:

i' Page 9-20 shutdown, at least one spray system is no longer (Cont'd.) train of the following required for fire shutdown This update will allow closure shutdown systems would analysis. The residual of item 50-445/8444-08 be available: (1) heat removal system is (reference 2) during the l pressurizer auxiliary the low pressure safety follow-up inspection.

spray....(2) residual injection system.

heat....(3) low pressure j safety injection system i

....(4) charging pumps..."

i l

3 i

1 i

i - -

i .

Attachment to TXX-6376 April 15, 1987 Page 6 of 9 SSER 12 DESCRIPTION DISCUSSION CLARIFICATION /C0fMENTS ,

SECTION SSER Section .... Source Range New accident source Enhancement: .

9.5.1.4 neutron flux will be range neutron flux '

Paragraphs 3 sensed by an existing detectors are being Technical basis remains the same. .

cod 4, source range neutron installed. ,

Page 9-22 flux detector...."

SSER Section ....The turbine The turbina building Update / Revision:  ;

9.5.1.4 building does not cor.tains some circuits I Paragraph 4, contain any circuits and components that provide Protection for the MSIV's i Page 9-23 or equipment of safe alternative shutdown capa- is consistent with the NRC ..

l shutdown systems and bility for a fire in the generic letter 86-10 response v l is separated from such safeguard building effecting to question 3.8.3 Redundant Y::

l areas by 3-hour-rated the MSIV's. Trains / Alternate Shutdown. This  ;

fire walls...." update will allow closure of l item 50-445/8444-08 (reference 2) during the follow-up inspection. -

Technical basis remains the same. l

~

l l I l

l l

l l

l

Attach.sent to III-6376 April 15, 1937 Page 7 of 9 SSER 12 DESCRIPTION DISCUSSION CLARIFICATION /COfMENTS SECTION SSER Section The emergency lighting The control room area Clarification:

9.5.1.4 consists of fixed, is addressed separately Pcragraph 8, individual, 8-hour- in a deviation and for CPSES identified deviation and Page 9-24 lighting, battery- other areas, only areas provided justification to this power supplies. In to be manned for safe requirement in FSAR Sectior.;

Amend =ents 53 to the shutdown operations and 9.5.1.6.1-D.5 & 9.5.3.2.1.

FSAR, the applicant safe shutdown access and This was also identified in coenitted to provide egress routes have been TXX-3499 dated 4-07-82.

illumination to all specifically illuminated.

points of equipment operation needed for shutdown as well as all points cn the floor, including angles and intersections of corridors, passageways and stairways..."

l l

Attachneet to TII-6376 i April 15, 1937 Page 8 of 9 SSER 12 DESCRIPTION DISCUSSION CLARIFICATION /00fMENTS SECTICN SSER Sectica ....Two-way hydrants Two-way hydrants Clarification:

9.5.1.5 are previded at inter- are provided at inter-Pcragra;h 7, vals not exceeding vals of approximately 250 CPSES commiitted to providing Page 9-25 250 ft...." ft. An engineering hydrants as stated in FSAR analysis will justify that, Section 9.5.1.6.1-E.2.g and hydrants exceeding 250', 9.5.1.4.2.

adequately protect safety related buildings.

SSER Sectice ....The applicant has CPSES has provided Clarification:

, 9.5.1.6 provided a fixed water fixed suppression l Pcragra;h 4, suppression systen as systems that meet the CPSES committed to providing Page 9-29 a backup to the Halon intent of the guide- suppression for the C.S.R. as 1331 systen, which lines of BTP APCSB stated in FSAR 9.5.1.6.1-F.3.a.1 ceets the guidelines 9.5-1, Appendix A, of BIP CMEB 9.5-1, Section F.3.a.1 Technical basis remains the same.

Sectica C.7.c...."

1 1

l

i l

Attachent to TIX-6376 April 15,1937 Page 9 of 9 SSER 12 DESCRIPTION DISCUSSION CLARIFICATION /C0ffiENTS SECTICN SSER Section *

....The battery rooms The adjacent Unit I and Clarification:

9.5.1.6 are separated from each Unit 2 battery rooms, which Pcragraph 17 other and from the are the same train, are TXX-4265 dated 8-16-85 submitted Page 9-29 balance of the plant separated by one hour fire the FHA revision 2 showing t,y 3-hour-fire rated- rated ba:riers. the one hour fire level barriers barriers. separating Unit I and Unit 2.

Saw train battery rooms are separated by barriers fire rated commensurate with the hazard and, therefore, maintain the level of safety required by CPSES Fire Protection Program.

SSER Section ....confor=s to the ".. .. conforms to Typo:

9.S.I.8 requirements of GDC3, requirements of GDC3, Paragraph I Appendix R to 10CFR50 Appendix R to 10CFR50, BTP CMEB 9.5.1 does not contain Page 9-32 and Appendix A to BIP and Appendix A to BTP an Appendix A. Letter TXX-1974 CMEB 9.5-1...." APCSB 9.5-1...." dated 10-22-76 discusses how CPSES meets the requirements of Appendix A to BTP APCSB 9.5-I.