TXX-6848, Forwards Advance Submittal of Change to Plant FSAR Sections Re Plant Fire Protection Program.Change Reflects New Computerized Format Per Util & Addresses Fire Safe Shutdown & Hazards Analyses,Organization & Design Mods

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Forwards Advance Submittal of Change to Plant FSAR Sections Re Plant Fire Protection Program.Change Reflects New Computerized Format Per Util & Addresses Fire Safe Shutdown & Hazards Analyses,Organization & Design Mods
ML20235V768
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/09/1987
From: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20235U905 List:
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TXX-6848, NUDOCS 8710150310
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Log # TXX-6848

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File # 909.5

= = 10010 clo 7UELECTRIC Ref # 10CFR50.34(b) i wmun c. couna October 9, 1987 i Emutive Vnt Presiderrt V. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

D0CKET NOS. 50-445 AND 50-446 FIRE PROTECTION PROGRAM ADVANCE SUBMITTAL OF FSAR UPDATE

REFERENCE:

1) Letter logged TXX-6365 from W. G. Counsil to the NRC dated April 1, 1987 Gentlemen:

In preparation for an NRC review of the CPSES Fire Protection Program, we have enclosed an advance copy of a change to the CPSES FSAR sections relative to the CPSES Fire Protection Program. This change reflects the new computerized format described in reference 1. In order to adopt the new computerized format for the table in subsection 9.5.1.6.2 of the FSAR, (comparing the CPSES Fire Protection Program with APCSB 9.5-1, Appendix A), we no longer have the applicable sections of APCSB 9.5-1, Appendix A in the left column of the page with the corresponding description of the CPSES Fire Protection Program in the right column. Instead, we have moved the applicable sections of APCSB 9.5-1, Appendix A in front of the corresponding descriptions of the CPSES Fire Protection Program. This format change also provides clearer, easier reading of the CPSES Fire Protection Program.

This FSAR update includes changes addressing the following general topics:

(1) revised fire safe shutdown analyses, (2) revised fire hazards analysis, (3) organizational changes, and (4) design modifications to CPSES.

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During our review of the new computerized format of the fire protection sections of the FSAR, we noted and corrected several errors in our reproduction of APCSB 9.5-1, Appendix A.

l We plan to submit these changes in'a future Amendment to the FSAR.

Very truly yours, V/VX W. G. Counsil JDS/mih -

Enclosure-Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l l

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Attachment to.TXX-6848 October 9, 1987 Page 1 of 13 FSAR Page Description 1.2-23 Correction: Removes description of fire protection system separation in relation to seismic category 1 equipment. i

.Section 3.2.2 contains the technical description of how I the fire protection system meets the Class 5 criteria, j l

1.2-24 Correction: Changed description of fire detectors to  !

reflect the fact that ionization detectors are the only I devices with indicating lamps in the base of the unit.

This is not'a requirement and other detectors are annunciated by zone at the local and main fire detection l- panels.

1.2-24 Clarification: Clarifies the type of automatic fixed extinguishing systems that are actuated by the fire detection system. Other automatic suppression systems have been added that actuate upon detection of heat by fusible link mechanisms integral with sprinkler heads.

l 1.2-24, 25 Correction: Deleted description of plant paging system in relation to detection system. Plant paging system is operated manually per procedures.

1,2-25 Correction: Changes the description of thermal detector types used at CPSES. This change reflects plant conditions.

1.2-25 Correction: Changes the description of the use of strip  !

thermistor heat detectors to reflect the as-built plant condition. Spot type thermal detectors are used for transformers not strip thermistors.

1.'2-25 Update: Adds a technical description of flame detectors used in the plant.

1.2-25 Editorial: Deletes description of detection systems which actuate suppression systems. This eliminates redundancy J with description on Page 1.2-24. )

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Attach nt t'o TXX-6848

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FSAR'page. ' Description

'1.2-26 Clarification: Deletes specific statements made regarding "c

alarm system trouble indication to eliminate redundancy.

Alarm system trouble indication is discussed on FSAR Page.

9.5-11.

1.2-26 Clarification: Clarifies the technical descri) tion of i Class A detection that has been provided for tie cable spread room to automatically. actuate the Halon system..

1.2-26 Correction: Changes description of fixed water. spray l- systems to reflect the fact that suppression systems added include water spray,. sprinkler, and Halon systems.  !

1.2-26 Correction: Changes the technical description of system o)erating pressures from a specific pressure to reflect t1e changes that occurred during construction..A nonspecific set point is described. The set point will be maintained at a pressure adequate to support suppression systems demands within the plant.

1.2-27 Correction: Changed the description of the number of connections to the underground loop to reflect the

, , addition of connections to meet increased system demands.

l The adequacy of the underground loop connections is  !

assured by hydraulic calculations of-system demand. -l 1.2-27 Correction: Deleted description of normally dry l standpipes and deluge valves from the discussion of'  :

standpipe isolation. The plant now utilizes normally wet standpipes except in certain highly sensitive areas. The '

adverse effects of these standpipes has been evaluated by the MEB 3-1 criteria and protective measures implemented-where unacceptable interactions were identified.  !

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, LAttachment to TXX-6848 3 ' October 9, 1987 Page 3 of 13 FSAR Page Description 1.2-27 Correction: Yard post indicator valves located in the branch lines to the maintenance and administration buildings are used in accordance with NFPA 24, not NFPA 13 and 14.

1.2-27 Correction: Deleted description of water supply and suppression system for the QA record storage area. This storage facility is no longer located in the Administration Building. Fire protection for QA record storage areas in the Administration Building Annex and the CP Engineering Building is provided as stated in FSAR Section 1A(B).

1,2-28 Correction: Extinguishers are adequately 3rovided in the maintenance and administration buildings; lowever, they are not all located in hose stations.

1.2-28 Correction: Changed the technical description of the transformer suppression systems to reflect the as-built design. These systems are actuated automatically by the  !

thermal detection system. This improves the response time of the suppression system.

1.2-28 Editorial: Clarifies the description of the type of suppression system, supply independence provided and the description of the water tight door to reflect plant conditions. The technical basis is not affected. )

1.2-28 Correction: Substitutes the hazard that is protected by a deluge system to reflect as-built plant conditions. The diesel generators are protected adequately by an automatic water sprinkler system. 1 i

1.2-28 Correction: Changed the technical description of the l diesel generator day tank suppression systems to reflect )

as-built design. These systems are actuated automatically  !

by the thermal detection system. This improves the l response time of the suppression system.

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. Attachment to.TXX-6848 0ctober 9,1987:

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v y o ,  ;FSAR Page Description -

cl.2-29' Correction: . Changes'the description of the supply system of fire' protection water'for'the atmospheric cleanup units y outside containment. This change ref.lects plant as-built conditions. Adequate water supply is_ assured'through '

hydraulic calculations.

.I'.2-29 Correction: Changed the description of.the components of the atmos)heric cleanup unit water spray systems to reflect t1e plant as-built conditions. The technical basis is not affected.

1.2-29 Correction: . Changed the technical description of the >

atmospheric cleanup unit suppression systems to reflect the as-built design. These systems are actuated automatically-by the thermal detection system. This-improves the response time of the suppression system.

~1.2-29,.30 Clarification: Deleted details of Halon system since information did not accurately reflect the plant design.

Halon system detailed technical description. appears in Section'9.5.1.4.3.

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AttachmeritL to' TXX-6848 R , October 9,:1987 I Page 5 of:13 i I

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.FSAR Page- Description 7.4-28 Addition: Adds reference to WCAP-11311,."CPSES Thermal '!

Hydraulic Analysis of Fire Safe Shutdown Scenario"?, and.

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the fire safe shutdown analysis. i p 'FSAR Table ,

Table 7.4-1 Sheets 1 and 3, Table 7.4-3 Sheets 1 and'2-L- Correction: Added a note'to the tables to clarify the' I operational condition of the Train B RHR valve. Switches

., are available for control, but. during normal operation the .!

  • valve is not available until the breaker is inserted.

e Table 7.4-1 Sheet.2, Table'7.4-3 Sheet 1 Correction: Added alternate shutdown notation for valve 1-HS-4514. This valve is available.at the hot shutdown panel through.the shutdown transfer panel to isolate Train '

A CCW loop from'the Train B and nonsafeguards loop.

Table 7.4-3 Sheet 1 -i I

Correction:

Added note (A)'to the table.

g Table 7.4-3 Sheet 3 Correction:' Eliminates note (A):from the pressurizer heater. The pressurizer heater is not. required for alternate shutdown.

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, ' Attachment to TXX-6848 October 9, 1987 Page.6 of 13-J' FSAR Page Description

'9.5-3 Clarification: Substitutes a description.of base cur've.

used in determination of. fire protection. Previous reference'was to table derived from the base curve.

Deletts reference to flashover, .a term not descriptive of assumption used.

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i 9.5-4, 5, 6,:22 Clarification: The fire safe shutdown analysis establishes separation'of fire safe shutdown systems or components which may be safety related or non-safety related. 'This change clarifies this= fact.

9.5-4 ' Correction: Added a definition of-Maximum Permissible Fire Loca. The combustible loading calculations have been as-built and this represents'an as-built design limit based on installed. fire' protection features.  !

9.5-5 Correction: Changed the assumptions for combustible

-. loading calculations. As-built combustible loading '

calculations have replaced design calculations' originally  !

provided. The as-built calculation results have been-reviewed against the Maximum Permissible Fire Load to verify design margin maintenance. The cable loading values are based on cable counts and BTU values'for each cable located in a Fire Area / Zone.

9.5-5 Editorial: Corrects section number for Methodology'to 9.5.1.2.3.

9.5-6 Correction: Changes methodology for calculation of combustible loading. The as-built combustible loading calculations have accounted for the insitu combustibles.

= Transient combustibles are envelnped by the design margin maintained between the as-built coinbustibles and the Maximum Permissible Fire Load.

9.5-7 Clarification: This amendment clarifies in Section 8.b.

that automatic area wide suppression will be installed to protect redundant safe shutdown equipment within'the same fire area when spatial separation is greater than 20 feet when no intervening combustibles of fire hazards exist.

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'F,SAR Page' Description.

9.5-7m . Clarification The last paragraph on this page states. 1 that~some areas will'be )rovided with suppression when' case (b) exists. This ciange clarifies?that suppression y' will.be.provided unless justification-of deviation to this'<

condition'is.provided.. .

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'9.5-7~ Update:. Automatic sprinkler suppression system densities are based on_ NFPA 13. The densities stipulated by the.-

, Copper Life Safety. Handbook do not adequately reflect fire hazard configuration and anticipated transient e ,

combustibles which are considered in NFPA 13 hazard

occupancies.

p 9.5-7 Clarification: Water s) ray is provided for concentrated:  ;

cables ~in addition to w1ere area wide s)rinklers are .

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' required. This clarification ensures t1at water spray is R not used as an alternative protection scheme for' condition' l

-(b).unless adequately.. justified.

a 9.5-8 Clarification: This clarification to Paragraph .9 clarifies:when one hour barriers are required. '

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9.5 Clarification

Provides additional clarification on the

, . type of events which initiate ~a trouble alarm and Incorporates' limitations for ground fault supervision.

9.5-12 Clarification: Removes the number three:from the l description of the fire pumps. There are only two fire :

pumps installed in the service water intake structure as described in the preceding paragraph.

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.9.5 Correction: Deletes reference to Factory Mutual Approval of the' pumps and controllers. They have been listed by Underwriters Laboratory for fire protection service. l 9.5-12 Clarification: Adds a' description that reflects the fact some three way hydrants have been used at CPSES. This enhances fire fighting capabilities, i

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' Attachment to'-TXX-6848.,

.0ctober:9, 1987.

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FSAR Page , Description 9.5-12, 13. Correction: Removes reference to brackets which were not utilized in the as-built installation. These brackets as-originally procured, are not necessary for storage.or maintenance of accessories in the hose' cabinets. . Hose wrenches are stored and maintained inside cabinets not 1

, hydrants as stated.

9.5-13 Clarification: Clarifies type of suppression systems utilized in.the as-built installation (i.e., both' i sprinkler and water spray ' systems are employed). The i technical basis is not affected. H 9.5-13 Editorial: Adds a reference to the section of the FSAR that provides a complete technical. description of the  !

valve supervision program.

9.5-13 Clarificat ion: Changes the reference for' suppression system spray density criteria to the appropriate FSAR l section. The technical basis is not affected.

9.5-14 Correction: Revises description of deluge valves utilized in water spra units (ACUS)toy reflect systems protecting that atmospheric no provision for manual cleanup operation exists in the as-built installation. The deluge valves provided are for a specialized HVAC application and meet Reg. Guide 1.52 requirements. The valve design precludes inadvertent operation by being seismically qualified. The technical' basis is not affected.

9.5-14 Addition: Add ' reference to plant areas or c >mponents protected by automatic water spray systems to clearly identify where such systems are provided in the as-built installation and to be consistent with other FSAR

' sections. This clarifies'what type of suppression systems are utilized to protect respective plant hazards. The  !

technical basis is not affected.

9.5-16 Clarification: Deletes the reference for system spray  ;

density criteria. The appropriate FSAR section containing '

this information has been previously identified. The technical basis is not affected, i

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JAttachment$toTXX-684'8

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'Page'9/of,13-FSAR Paget Description

,-9.5-17 Addition: Add' reference'to plant areas protected by manual preaction sprinkler systems to clearly identify where such systems are provided in the as-built' installation and to be consistent with other FSAR sections. This clarifies what type of_ suppression systems are utilized to. protect respective plant hazards. The technica1' basis is not affected.

9.5-17. Clarification: . Deletes the reference to system spray density criteria. The appropriate FSAR.section containing this information has been previously identified. The technical basis is not affected..

9.5-18' Correction: Removes description of Halon local control  !

panel locations to reflect as-built plant installation.-

The location described does not' reflect.a code requirement and.may not provide the best design location for all Halon system installations at'CPSES. The technical basis is not' affected.

9.5-18 Addition: Adds reference to the control room and containment building standpipe and hose system being of the normally dry type. design with manual charging required. The normally dry type' design is required to preclude ~the effects of moderate energy line cracks. The technical basis is not affected.

9.5-20 Clarification: Deletes reference to specific suppression systems supplied by yard loop. Specific reference is provided to these. systems in Section 9.5.1.4.2. The technical basis is not affected.

9.5-20 Correction: Changes description'of water tight doors for the diesel generator compartment to reflect the fact that only one doorway requires protection in each compartment.

9.5-21 Clarification: Changes description of water supply for ACU spray systems actuation to a description of water supplies for all suppression systems in plant-safety-related areas. This maintains the consistency of'this section in describing water supplies to all plant and auxiliary buildings. The technical basis is not affected.

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i Attachment to TXX-6848 October 9,'1987 Page 10 of 13 t

FSAR Page Description o 9.5-21 Clarification: Clarifies the technical description of the Halon system. LAdditional detail is added and the system function is restated. The technical basis is not affected.

L' 9.5-22 -Clarification: Clarifies the description-of the detection system to reflect the fact that indicating lamps are not provided for all detectors. This is.not a requirement, l and detection zones affected are thermal type devices I covering smaller areas or of continuous strip type 9.5-23 Correction: Removes description of steel decking since

.this. type of construction is not used at CPSES.

9.5-25' Update: Eliminates exception to provide approved fire dampers with a rating equivalent to that designated for a fire barrier of two hours or greater resistance. Dampers which meet this requirement are being installed.

9.5-26 Revision: Deletes reference to service air powered smoke-ejectors. Adequate smoke removal capacity is available without the services of this type of unit.

~9.5-27 Clarification: Clarifies that steel covers used to i protect vertical cable trays are. installed as a general I construction practice and only extend four (4) feet from the floor where utilized.

9 5-31, 32, Correction: Revises organizational responsibilities to i 33, 34 reflect Nuclear Operations division reorganization. j i

9.5-34 Correction: Revises description _of Engineer to reflect  !

the involvement of other Architect Engineers and l consultants in the CPSES project.

  • 9.5-37 Clarification: Clarifies the technical description of the fire protectic~ program for the fuel building 3rovided j prior to complete program implementation for t1e plant. I 1

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! #. . Attachment to TXX-6848 October'9, 1987:.

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[ ' FSAR'Page. _ Description

' 9.5 Correction: Revises' description of personnel responsible for. notification'of'off site fire department assistance.-

Change reflects responsibilities as assigned.at CPSES.

9.5-51; Clarification: Incorporates a technical ' description 'of.  ;

fire protection provided for; redundant fire safe shutdown systems within each fire area located inside and outside.

of containment 9.5-54: Correction:. Deletes' technical description o.f metal roof.

deck construction. Roof structures for power. block and~

other safety related ' structures 'are concrete slab.

construction.

( .l L 9.5-54 Correction: Deletes references to' deviations in a noncombustible construction of Wood used to trim the ceiling as h.the control been removed room. ceiling.

as part of' -

a redesign and reinstallation of the' ceiling.

9.5-56 Correction: Changes'the: description of the drainage system for the~ battery rooms to. reflect the fact.that two-battery rooms depend on floor drains -located in an-adjacent corridor. There are no installed suppression systems in these rooms. Any. suppression' water supplied' j would be manual using hose stations.: The doors to these t rooms lwould then be open and the suppression water would drain to the corridor.

9.5-60' Clarification: Changes the description of the code compliance to reflect'the requirements ~of Appendix A to c Branch Technical Position APCSB 9.5-1.

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9.5-70' Clarification: Provides limitations to ground fault  ;

supervision.  ;

9.5-74 Editorial: Clarifies that pressure maintenance is achieved with one jockey pump.

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' Attachment'to TXX-6848

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FSAR Page-  : Description

'9.5-95 ' Editorial: Deletes reference to Subsection'9.5.1.3.3 which was deleted from the FSAR by a. previous amendment.

t , 9.5-101' . Edi tori al i- Deletes reference to deviation in Section. j l- 9.5.1.6.2 since the FHA and underlying calculations: 1 L demonstrate compliance with this section. I 9.5-101 ' Addition: Adds description of three hour barriers.between fire areas containing safety related pumps and other. fire areas.

9.5-103, 115 Correction: Provides a discussion on an alternate means of manual . suppression provided for Radwaste Areas. CPSES does not use wheeled extinguishers as suggested in the BTP 9.5-1.

p 9.5-103- Revision: Deletes the provision for large wheeled

>ortable extinguisher units in radwaste' areas. . Adequate 1

, landheld portable extinguishers are provided for the-hazard.

-9.5-106 Editorial: Deletes reference to Section 9.5-1.6.2.G.3 since the CPSES design is described in the text on this page.

9.5-108 Correction: Deletes justification for wood trim used for control room suspended ceiling. The wood trim was removed when the ceiling was redesigned and reinstalled.

9.5-109, 110 Addition: Adds a description of the Bullet Resistant'and Penetration Resistant doors used as fire doors.

Assemblies are similar to units that have been listed with UL by the manufacturer.

9.5-111 Editorial: Clarifies that elevator towers outside 3 containment have a two-hour fire resistance rating. Two two-hour fire barriers would have to be breached to have an affect on safe shutdown.

9.5-115 Correction: Changed capacity of the day tank to reflect as-built plant conditions. The technical basis is not affected. j t

9.5-157, 57, 88,. Update: Deletes Reference 20. Updates Reference 19. i 92, 109, 110, 113 Reference 19 in replaced with a reference containing a complete package of all justifications for deviations.

This reference is the Fire Protection Report - Appendix C

- "Deviations". This also eliminates the need for l Reference 20 throughout the FSAR where deviations are .'

discussed.

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October 9, 1987 Page 13 of 13 l FSAR Page Description 9.5-157, 158, 159 Addition: Adds reference to industry standards and applicable editions used for establishing code compliance or as guidance. Change reflects as-built plant-conditions.

Table 9.5-16 Update: Changes made on Page 9.5-8 clearly identify where justification for deviations from area wide suppression and NFPA 13 and 15 are located; therefore, this table is no longer necessary.

Figures 9.5-43,44, 45, 46, 47, and 48 Correction: Replaces existing figures with latest drawing revisions.

010-47 Correction: Updates description of methodology used by CPSES to perform the fire safe shutdown analysis.

010-48 Editorial: Added references to deviations in Section 9.5.1.

010-55 Correction: Changed reference to design documents containing information requested by the NRC. The analysis has been modified to meet current procedural requirements and incorporate plant modifications.

010-63 Clarification: Clarifies that Operator actions are required for fire scenarios other than control room and cable spread room, but the required actions are enveloped i by these scenarios.

010-63 Correction: The Fire Protection Program Review has been revised and is now titled " Fire Safe Shutdown Analysis".

040-144 Correction: Updated response to NRC questions to reflect current analytical techniques used in the analysis for cable separation.

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