ML20151W141

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Forwards List of Comments Re Fire Protection on SER & Addl Comments on Sser 12
ML20151W141
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/29/1988
From: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88430, NUDOCS 8805030309
Download: ML20151W141 (39)


Text

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F9 Log # TXX-88430

=; = File # 10010 clo r C 909.5 7UELECTRIC Ref.#10CFR50.48(e)

April 29, 1988 William G. Counell Eircutin Ykr Presudent U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445 AND 50-446 FIRE PROTECTION PROGRAM REF: 1) letter logged TXX-6376 f rom W. G. Counsil to the NRC dated April 15, 1987

2) Letter . logged TXX-6582 from W. G. Counsil to the NRC dated August 4, 1987
3) Letter logged TXX-6728 from W. G. Counsil to the NRC dated October 2, 1987
4) Letter logged TXX-6814 from W. G. Counsil to the NRC dated October 22, 1987 Gentlemen:

In the above referenced letters, we have provided you with our revised deviations and comments on SSER 12. The attached list provides comments relating to fire protection cn the SER and additional comments on SSER 12.

The above references along with the attached list identifies areas relating to fire protection of the SER and SSER 12 which may require updating, i Very truly yours, -

W!d4 W. G. Counsil JDS/grr Attachment c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) ,

9 8805030309 800429 5 DR ADOCK 050 dd 400 Nonk Olin Steret LB81 Dekas. Texas 73.'01 l

Attachment to TXX-88430 April 29, 1988 Page 1 of 38 SSER 12 SECTI0ll Page 2-10 DESCRIPTI0tl The control room intakes are equipped with redundant smoke detectors that will isolate the control room in the event of elevated smoke levels.

DISCUSSION Two smoke detectors are located in the control room HVAC intakes, but the detectors are not electrically separated. Additionally, isolation of the Control Room due to elevated smoke levels is accomplished manually.

REFERENCES None

Attachment to TXX-88430 JApril 29, 198E Page 2 of-38 SSER 12 SECTION

-9.5.1,-"Fire Protection", page 9-3 (SSER 12)

DESCRIPTION This section completely supersedes those in previous supplements.

DISCUSSION SSER 12 provides a complete write u) of section 9.5.1 of the SER. However, the statement only -indicates that t1e writeup supersedes writeups in previous supplements to the SER. A clarification of this statement should be provided.

REFERENCES None I

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Attachment to TXX-88430

- April 29, 1988 Page 3 of 38 SSER 12 SECTION 9.5.1.1, page 9-3 and 9-4 DESCRIPTION 9.5.1.1 Fire Protection Program Requirements Fire Protection Program The fire protection program is described in the a)plicant's Fire Protection Evaluation Report and the FSAR. The program esta)lishes policy for the protection of structures, systems, and components important to safety and conforms to the technical requirements in BTP CHEB 9.5-1, Section C.1. The staff finds that the fire protection program meets the guidelines of BTP CMEB 9.5-1, Section C.1, and is,~therefore, acceptable.

Fire Hazards Analysis The applicant's fire hazards analysis enclosed with the letter dated August 15, 1984, identified combustible materials in fire areas, identified safety-related eauipment, determined the consequences of a fire on safe shutdown capability, and summarized available fire protection in accordance with BTP CHEB 9.5-1, Section C.1.b.

DISCUSSION Fire Protection Report and the FSAR discuss the Fire Protection Program.

REFERENCES See letter logged TXX-6814 dated October 22, 1987.

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Attachment to TXX-88430 April 29, 1988 Page 4 of 38 1

SSER 12 SECTION 9.5.1.1, page 9-4 DESCRIPTION General Design Criterion (GDC) 3 requires that fire fighting systems be designed to ensure that rupture or inadvertent operation does not significantly impair the safety capability of structures, systems, and components important to safety. To satisfy this requirement, the applicant I has designed components required for hot shutdown so that rupture or inadvertent operation of fire suppression systems will not adversely affect the operability of these components. Where necessary, appropriate protection is provided to prevent impingement of water spray on components required for hot shutdown. Redundant trains of components that are susceptible to damage from water spray are physically separated so that manual fire suppression activities will not adversely affect the operability of components not involved in the postulated fire.

DISCUSSION Hot standby is the design basis for CPSES inadvertent operations evaluation. ,

REFERENCES None  ;

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Attachment to ThX-88430 April 29,1988 Page 5 of 38 SSER 12 SECT 10tl 9.5.1.1, page 9-4 DESCRIPT10ll On the basis of its review, the staff concludes that the fire hazards analysis meets the guidelines of BTP CMEB 9.5-1, Section C.I.b, and is, therefore, acceptable.

DISCUSS 10fl Fire Protection Report meets the guidance of enclosure 2 of flRC letter dated September 30, 1976.

REFEREflCES FPR Section 11-1.2.1.

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[ Attachment to TXX-88430 April 29, 1988 Page 6 of 38 SSER 12 SECTION 9.5.1.4, page 9-5 DESCRIPTION All fire-rated assemblies are tested for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in accordance with American Society for Testing and Materials (ASTM) E 119, are designed in accordance with 3-hour-rated fire barrier designs obtained from the Fire Resistance Directory published by Underwriters Laboratories (UL), or are constructed of 8-inch-thick reinforced concrete in accordance with the "Uniform Building Code" (International Conference of Building Officials) for a minimum fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

OlSCUSSION 4

UBC design calls for 6 inch thick concrete t>.11s, floors and ceilings.

REFERENCES See letter logged TXX-88309 dated March 11, 1988 from W. G. Counsil to the NRC.

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Attachment to TXX-88430 April 29, 1988 Page 7 of 38 SSER 12 SECTION 9.5.1.4, page 9-6 DESCRIPTION The heating, ventilation, and air conditioning (HVAC) penetrations of fire-rated barriers are provided with UL-labeled fire damper assemblies that have ratings commensurate with the fire ratings of the walls in which they are installed. The fire dampers are installed according to the manufacturer's directions, with the exception of 61 heating and ventilation dampers identified in the fire hazards analysis on Drawing FHA 2 through FHA 48.

DISCUSSION Essential fire dampers are being replaced with qualified assemblies including deviated openings.

REFERENCES See letter logged TXX-6728 dated October 2,1987. TXX-6728 supercedes comments in TXX-6376.

Attachment to TXX-88430 April 29, 1988 Page 8 of 38 SSER 12 SECTION 9.5.1.4, page 9-7 DESCRIPTION The staff finds that although the watertight and missiie- thd bullet-resistant doors are not 3-hour-fire-rated doors, because of the low to moderate fuel loading and fire protection provided, they provide an equivalent level of protection for the areas where they are installed. On the basis of the above review, the staff concludes that with the acceptable deviation, the fire door provided meet the guidelines in Section C.5.a of BTP CHEB 9.5-1 and are, therefore, acceptable.

DISCUSSION Additional deviations have been identified for Door and Damper Assemblies.

REFERENCES FSAR 9.5.1.6.2 (D.1.j)

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-Attachment to TXX-88430 April 29, 1988 Page 9 of 38 SSER 12 SECTION 9.5.1.4, page 9-7 DESCRIPTION Thermal insulating materials are noncombustible. Interior walls and structural components, radiation shielding materials, and soundproofing and interior finishes are noncombustible or are listed by a nationally recognized testing laboratory, such as Factory Mutual (FM) or VL, as having a flame spread of 50 or less in their use configuration, with the exception of redwood trim backed with ' fire-retardant-treated pine in the control room. The trim is-a small quantity of wood that constitutes an insignificant contribution to the control room fuel loading. The trim is exposed and visible to personnel continuously manning the control room. Because of the small quantity of wood and its configuration in the control room, the staff finds the installation of

- the redwood trim an acceptable deviation.

DISCUSSION Wood trim has been deleted from the Control Room.

REFERENCES FSAR Amendment 65, Section 9.5.1.6.1 (0.1.d)

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Attachment to TXX-88430 April 29, 1988 Page 10 of 38 SSER 12 SECTION 9.5.1.4, page 9-7 DESCRIPTION The metal deck roof is constructed of material that is either noncombustible or listed as Class 1 by FM.

DISCUSSION There is no metal deck roofing in safety-related areas of the plant.

REFERENCES FSAR section 9.5.1.6.1.

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Attachment to TXX-88430 April 29, 1988 Page 11 of 38 SSER 12 SECTION 9.5.1.4, page 9-8 DESCRIPTION Each oil-filled transformer is protected with a water spray extinguishing system that is automatically actuated by heat detectors. On the basis of its evaluation, the staff concludes that the installation of the transformer meets the guidelines of BIP CMEB 9.5-1, Sections C.5.a(12) and (13), and is, therefore, acceptable.

DISCUSSION A transformer has been added west of the Turbine Building without suppression.

REFERENCES FSAR 9.5.1.4.3, page 9.5-23.

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Attachment to TXX-88430 April 29,1988 Page 12 of 38 SSER 12 SECTION 9.5.1.4, paragraph 5, pages 9-8 and 9-9.

DESCRIPTION The computer program product is used in conjunction with the safe shutdown logics to identify components that provide a safe shutdown path. After identifying fire-safe-shutdown-related components (i.e., equipment, trays, conduits, and cables) by fire area, the applicant performed an interaction study to locate the fire areas where redundant paths are not properly separated. The interaction study was done by field walkdowns.

DISCUSSION Clarification - the methodology of the study is as given in the Fire Protection Report, Revision 1.

REFERENCES FPR Revision 1, Section 111-4.0 l

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Attachment to TXX-88430 April 29, 1988 Page 13 of 38 55En 12 SECTION 9.5.1.4, pages 9-9 and 9-10.

DESCRIPTION (1) Service Water Inttke Structure lhe applicant requested a deviation from Section Ill.G.2 of Appendix R (BTP CMEB 9.5-1, Section C.5.b) because complete 1-hour-fire-rated barriers are not providcd to separate the redundant service water pumps.

DISCVSSION Deviation has been revised to include additional components identified in the Fire Safe Shutdown Analysis.

REFERENCES See letter logged TXX-6728 dated October 2, 1987, Deviation la and FPR Revision 1,Section V, Appendix C.

Attachment on TXX-88430 April 29, i,68 Page 14 of 38 SSER 12 SECTION 9.5.1.4, page 9-11.

DESCRIPTION (3) Boric Acid Transfer Pump Area The applicant requested a deviation from Section llI.G.2 of Appendix R (BTPM CHEB 9.5-1, Section C.5.b) because complete 1-hour-fire-rated barriers are not provided to separate the redundant boric acid transfer pumps and complete areawide automatic fire suppression system coverage is not provided.

DISCUSSION Deviation has been deleted.

REJERENCES See letter logged TXX-6728 dated October 2, 1987.

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Attachment to TXX-88430 April 29, 1988 Page 15 of 38 SSER 12 SECTION 9.5.1.4(4),page9-12 DESCRIPTION The chiller transformer area is located in the auxiliary building on elevation 852 ft. 6 inches. Automatic sprinkler coverage for the area and cable trays, except for the chiller transfonner, is provided. The sprinklers are arranged so that they will not spray directly onto the transformer because the transfonner is sensitive to water. Areawide detection is provided. Cables and associated circuits of one safe shutdown path are enclosed ir. a 1-hour-fire-rated barrier. Manual hose stations and portable fire extinguishers are available.

DISCUSSION Suppression in this area has been upgraded and the deviation has been deleted.

REFERENCES See letter logged TXX-6728 dated October 2,1987.

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Attachment to TXX-88430 April 29, 1988 Page 16 of 38 SSER 12 SECTI0il 9.5.1.4, page 9-13 DESCRIPTION (5) Hot Shutdown Panel Area Electrical Equipment Room

[ Description of Deviation]

DISCUSSI0fl Fire Hazards Analysis evaluations supersede the deviation.

REFERENCES FPR Revision 1,Section V, Appendix B and letter logged TXX-6728 dated October 2, 1987.

Attachment to TXX-88430 April 29, 1988 Page 17 of 38 SSER 12 SECTION 9.5.1.4, page 9-13 DESCRIPTION (6) Corridor on Elevation 790 ft. 6 in, of the Safeguard Building

[ Description of Deviation]

DISCUSSION Fire Hazard Analysis evaluations supersede the deviation.

REFERENCES FPR Revision 1 Section V, Appendix B and letter logged TXX-6728 dated October 2, 1987.

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Attachment to TXX-88430 April 29, 1988 Page 18 of 38 SSER 12 SECTION 9.5.1.4, page 9-14 DESCRIPTION (7) Valve Isolation Tank Room IC

[DescriptionofDeviation]

DISCUSSION Fire Hazard Analysis evaluations supersede the deviation.

REFERENCES FPR Revision 1,Section V, Appendix B and letter logged TXX-6728 dated October 2, 1987.

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Attachment to TXX-88430 April 29, 1988 Page 19 of 38 SSER 12 SECT ION 9.5.1.4, Fire Protection of the Safe Shutdown Capability (8), page 9-14.

DESCRIPTION (8) Train A Switchgear Room and Train B Switchgear Room (DescriptionofDeviation]

DISCUSSION Fire Hazards Analysis evaluations supersede the deviation.

REFERENCES See FSAR Section 9.5.1.6.2.F.5, page 9.5-101 See FSAR Section 9.5.1.6.2.D.l.a.2, page 9.5-53 See FPR Section V, Appendix B 6

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Attachment to TXX-88430 April 29, 1988 Page 20 of 38 SSER 12 SECTION 9.5.1.4 (9), page 9-15 DESCRIPTION (9) Auxiliary Building Heat Exchanger Area (DescriptionofDeviation]

DISCUSSION The Fire Safe Shutdown Analysis assumes that a fire will not induce the failure of mechanical equipment. This deviation is no longer necessary.

REFERENCES FPR Section 111-3.1.3.3.

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Attachment to TXX-88430 April 29, 1988 Page 21 of 38 SSER 12 SECTION {

9.5.1.4, Fire Protection of the Safe Shutdown Capability (11)

DESCRIPTION (11) Boric Acid Storage Tank Area, Valve Isolation Tank Room 2C, Valve Room 677 hadioactive Penetration Areas, Fire Zones 3A 142 and SB 143, Boron Injection Surge Tank Room, Safeguard Building Elevation 852 ft. 6 in.,

ahd Control Room HVIC Equipment Rooms 73 and 74

[DescriptionofDeviation]

DISCUSSION Fire Hazards Analysis Evaluations supersede this deviation.

REFERENCES See FPR Section V, Appendix 0. See also FPR Section 111 - 3.1.3.3. See also letter logged TXX-6728 dated October 2,1987.

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Attachment to TXX-88430 April 29, 1988 Page 22 of 38 SSER 12 SECTION 9.5.1, page 9-3 DESCRIPTION The staff has reviewed the fire protection program, as described in the applicant's FSAR through Amendment 55, for confonnance with the Standard Review Plan (SRP, NUREG-0800), Section 9.5.1. This document addresses the applicant's confonnance with Branch Technical Position (BTP) CHER 9.5-1.

DISCUSS 1011 CPSES is committed to Appendix A to APSCB 9.5-1.

REFEREllCES Letter logged TXX-6376 dated April 15, 1987.

Attachment to TXX-88430 April 29, 1988 Page 23 of 38 SSER 12 SECTI0tt 9.5.1.4 (14), page 9-18 DESCRIPT10tl (14) Partial-Sprinkler Protection

[DescriptionofDeviation]

DISCUSS 10fl Fire Hazards Analysis evaluations supersede this deviation.

REFEREllCES See letter logged TXX-6728 dated October 2, 1987. See FPR Section V, Appendix B. See FPR Sections 11-5.1.1.4, 11-5.1.2.4, 11-5.3.1.4, and 11-5.2.1.4.

Attachment to TXX-88430 April 29, 1988 Page 24 of 38 SSE_R 12 SECTIOil 9.5.1.4, page 9-19 1ESCRIPTION (15) Automatic Suppression Systems for Safety Shutdown Capability (Description of Deviation]

DISC _VSSION These systems have been upgraded such that sprinkler head placement is in compliance with NFPA 13. TXX-6728 supersedes these deviations. The Fire Protection Report includes deviations from NFPA codes.

REFEREllCES See letter logged TXX-6728 dated October 2, 1987 and FPR Section 11-6.8.

Attachment to TXX-88430 April 29, 1988 Page 25 of 38 SSER 12 SECTION 9.5.1.4, paragraph 5, page 9-20 DESCRIPTI0fl The applicant's safe shutdown analysis dated May 7, 1982, states that systems needed for hot shutdown and cold shutdown consist of redundant trains and that one of the redundant trains needed for safe shutdown would be free of fire damage by providing separation, fire barriers, and/or alternative shutdown capability.

DISCUSS 10fl The Fire Safe Shutdown Analysis is as given in the Fire Protection Report Revision 1.

REFEREilCES FPR. Revision 1, Section Ill.

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Attachment to TXX-88430 l Apri,1 29, 1988  !

Page 26 of 38 )

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SSER 12 SECTION 9.5.1.4, paragraph'2, page 9-21 j DESCRIPTION Reactor decay heat removal for hot shutdown is provided through the steam

. generator by the auxiliary feedwater system and the atmospheric dump valves, and for cold shutdown, by natural circulation, the auxiliary feedwater system, the residual-heat removal system, and the chemical and volume control system charging pumps. These functions can be controlled at the remote shutdown panel.

DISCUSSION For cold shutdown, decay heat removal does not require the Chemical and Volume Control system charging pumps.

REFERENCES FPR,- Revision 1, Section !!I-4.2.

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April 29, 1988 Page 27 of 38 SSER 12 SECT!0!i 9.5.1.4, Control of Combustibles DESCRIPT10fl The turbine building does not contain any circuits or eouipment of safe shutdown systems and is separated from such areas by 3-hour-rated fire walls.

DISCUSS 10!i The turbine building contains some fire safe shutdown equipment as identified in the Fire Protection Report.

REFEREflCES See FPR, Section 111-5.0. Also see TXX-6894 and TXX-6376.

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Attachment to TXX-88430 April 29, 1988 Page 20 of 38 SSER 12 SECTION 9.5.1.4 Electrical Cable Construction, Cable Trays and Cable Penetrations, page 9-23.

0ESCRIPT10N Small amounts of cable not qualified according to IEEE 383-1974 associated with radiation monitors and security systems are located throughout the )lant.

These cables are all routed in conduit, except for short connectors at t1e detectors. They are low power service cabling.

DISCUSSION Negligible amounts of non-lEEE 383 qualified telephone and radio cable are located throughout the plant as well.

REFERFHCES None 1

Attachment to TXX-88430 April 29, 1988 Page 29 of 38 SSE_R 12 SECTION 9.5.1.4, Lighting and Communications, page 9-24.

DESCRIPTION The applicant has provided a fixed emergency communication system that is independent of the normal plant communication system at preselection stations.

A portable radio communication system has been provided for use by the fire brigade. The portable radio communication system includes hand-held portable radios which are powered by rechargeable batteries. A preoperational test will be conducted to ensure that the frequencies used for portable connunication systems will not affect the actuation of protective relays.

Fixed repeaters are used and they are protected from exposure to fire damage.

The staff concludes that two-way voice communication meets the guidelines of BTP CMEB 9.5-1, Section C.5.g(4), and is, therefore, acceptable.

DISCUSSION Communication is provided via intra plant portable radio, radio talk around capability or page-party /public address system.

REFERENCES See FSAR Section 9.5.1.6.1 0.5.

Attachment to TXX-88430 April 29, 1988 Page 30 of 38 SSER 12 SECTI0li 9.5.1.5, Fire Protection Water Supply System, page 9-25.

DESCRIPTI0ft Fire Protection Water Supply System

[ Description of Fire Water Supply System]

DISCUSS 10tl The fire protection water supply has been modified and has a new water service and pumping system.

REFEREllCES See FSAR Section 9.5.1.4.2.20, 9.5.1.4.3, 9.5.1.6.1 (E.2.c, d, e, and f) and FPR Section 11-6.3.2 and 6.3.3.

- Attachment to TXX-88430 April 29, 1988 Page 31 of 38 SSER 12 SECTION 9.5.1.5, Sprinkler and Standpipe Systems, page 9-27 DESCRIPTION Sprinkler and Standpipe Systems (Description of Deviation]

DISCUSSION Differences from NFPA codes are given in the Fire Protection Report.

REFERENCES See FPR Section 11-6.8.

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Attachment to TXX-88430 April 29, 1988 Page 32 of 38 SSER 12 SECTION 9.5.1.6, Diesel Fuel Oil Day Tank Rooms OESCRIPTION The day tanks can hold 2,300 gallons of diesel fuel instead of the maximum of 1,100 gallons recommended by the guidelines. Because each 2,300-gal...

DISCUSSION Diesel Day tanks hold 2160 gallons of diesel fuel.

REFERENCES See FSAR Section 9.5.1.6.1 and 9.5.1.6.2 (F.9) m am

Attachment to TXX-88430 April 29, 1988 Page 33 of 38 SSER 12 SECTION ,

9.5.1.7, Summary of Deviations from BTP APCSB 9.5-1 DESCRIPT10ft (3) no dampers installed in HVAC penetrations of 3-hour-fire-rated barriers (Section 9.4.1.4)

DISCUSSION Qualified fire dampers have been installed. Deviation has been deleted.

REFEREllCES See letter logged TXX-6728 dated October 2, 1987.

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Attachment to TXX-88430 April 29, 1988 Page 34 of 38 SSER 12 SECTION 9.5.1.7, Summary of Deviations from BTP CHEB 9.5-1, page 9-31.

DESCRIPTION (c) boric acid transfer pump area (DescriptionofDeviation]

DISCUSSION Deviation has been deleted.

REFERENCES See letter logged TXX-6728 dated October 2, 1987.

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Attachment to TXX-88430 April 29, 1988 '

Page 35 of 38 i

SSER 12 SECTION 9.5.1.7, Summary of Deviations from BTP CNEB 9.5-1, page 9-31.

DESCRIPTION (6) partial-sprinkler coverage in 20 plant areas (Section 9.5.1.4).

a) chiller transformer area b) hot shutdown panel area c) corridor elevation 790 ft. 6 in. safeguard building room 71a d valve isolation tank room IC ,

fe)) valve isolation tank room fire area SB2C f auxiliary building fire area AA g auxiliary building 790-ft elevation fire zone 21a i h auxiliary building 810-ft elevation fire zone 21b ,

i auxiliary building fire area AA fire zone 21c j) auxiliary building 830-ft elevation fire zone 21d '

k) auxiliary building 852-ft elevation fire zone 21f 1 electrical and control building fire area EA m electrical and control building elevation 778 ft. fire area EA43 n safeguard building fire area SA o) safeguard building fire area SB ,

safeguard building elevation 810 ft. 6 in, fire zone SB8 ,

1 safeguard building elevation 831 ft. 8 in, fire zone 5815 boric acid transformer pump area s) train A switchgear room (t) train B switchgear room  ;

DISCUSSION Fire Hazards Analysis Evaluations have superseded these deviations see comment.

REFERENCES See letter logged TXX-6728 dated October 2, 1987.  ;

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Attachment to TXX-88430 April 29, 1988 Page 36 of 38 SSER 12 SECTION 9.5.1.7, Summary of Deviations from BTP CHED 9.5-1, page 9-31.

DESCRIPil0N (a) auxiliary building heat exchanger area i DISCUSS 10H r

The Fire Safe Shutdown Analysis does not postulate that a fire could disable  ;

mechanical components such as heat exchangers.  !

REFERENCES See FPR Section 111 3.1.3.3.

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Attachment to TXX-88430 April 29, 1988 Page 37 of 38 SSER 12 SECTION 9.5.1.7, Summary of Deviations from B1P CMEB 9.5-1, page 9-31.

DESCRIPTION (9) omission of automatic fire suppression system in eight plant areas (Section 9.5.1.4):

boric acid storage tank area a

b valve isolation tank room 2C c valve room 67 d) radioactive penetration areas fire zones SA 142 and SB 143 e) boron injection surge tank room safeguard building elevation 652 ft.

6 in.

(f) control room HVAC equipment rooms 73 and 74.

DISCUSSION A Fire Hazards Analysis supercedes these deviations.

REFERENCES See letter logged TXX-6728 dated October 2,1987.

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Attachment to TXX-88430 April 29, 1988 Page 38 of 38 SSER 12 SECTION

, 9.5.1.7, Summary of Deviations from BTP CHEB 9.5-1, page 9-32 DESCRIPTION (10) installation of automatic sprinklers not in accordance with NFPA 13 in 10 plant areas (Section 9.5.1.4):

(a) auxiliary building 790-ft. elevation fire area AA fire zone 21e (b) auxiliary building 810-f t. elevation fire area AA fire zone 21b (c) auxiliary building 831-ft elevation fire area AA fire zone 21d d) auxiliary building 854-f t, elevation fire area AA fire zone 21f e) safeguard building 790-ft. elevation fire area 50 fire zone 4 f) safeguard building 810-ft, elevation fire area SB fire zone 8 (g) safeguard building 831-ft. elevation fire area SB fire zone 15 (h) safeguard building 831-ft. elevation fire area SB fire zone 144 (i) electrical and control building 792-ft. elevation fire area EA fire zone 57 (j) electrical and control building 792-ft. elevation fire area EA fire zone 43.

0_1SCUSS10N These systems have been upgraded such that sprinkler head spacing is in compliance with NFPA 13. NFPA code deviations are supersed these deviations. Code deviations are now given in the fire Protection Report.

R_EFERENCES See FPR Section 11-6.8.

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