ML20199C342
| ML20199C342 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 06/11/1986 |
| From: | Ainger K COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20199C346 | List: |
| References | |
| 1749K, NUDOCS 8606180080 | |
| Download: ML20199C342 (53) | |
Text
{{#Wiki_filter:. Commonwealth Edison 4*, c) 72 West Adams Street, ChicaQo, Illinois s Address Reply to: Post Othce Box 767 A Chicago, Illinois 60690-0767 June 11, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comunission Washington, DC 20555 4 subject: Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 4 Fire Protection Report'- Amendment 8 NRC Docket Mos. 50-454/455 and 50_456/457 Reference (a): August 16, 1982 letter from T. R. Traama j to H. R. Denton j
Dear Mr. Denton:
This letter provides Amendment 8 to the Byron /Braidwood Fire Protection Report (FPR) which was submitted in Reference (a). This amendment updates the FPR to incorporate new information and analyses applicable to Byron Units 1 and 2 and Braidwood Units 1 and 2. These changes do not represent a decrease in the level ot fire protection which require prior NRC approval according to Condition 6 of the Byron Unit 1 Operating License, NPF-37. Amendment 8 includes a new section 2.4 and new Appendix A5.8 providing the Byron Unit 2 safe shutdown analysis, and Appendix R I (Section.III G.2) deviations, respectively. l Amendment 8 also includes miscellaneous changes throughout the FPR. These changes can generally be categorized as either editorial ~in i nature, or as changes to reflect the latest "as-built" condition of the plants. Attachment A to this letter provides an itemized sumunary and ( explanation of all changes included in this amendment. This attachment is i provided as an aid to the NRC in identification of changes. l Attachment B to this letter provides a detailed section-by-section comparison of the new Byron Unit 2 safe shutdown analysis presented in new l section 2.4 against the Byron Unit I safe shutdown analysis. 8606180000 860611 k l PDR ADOCK 05000454 l F PDR N
Mr. H. R. Denton June 11, 1986 Attachment C to this letter provides a detailed comparison of the Byron Unit 2 Appendix R deviations presented in new Appendix A5.8 against the Byron Unit I deviations. These comparisons were requested by the NRC subsequent to the submittal of Amendment 7, which included a new Braidwood Unit I safe shutdown analysis and Appendix R deviations. These comparisons for the Amendment 7 material were submitted to the NRC under a separate cover letter. For Amendment 8, they are included as Attachments B and C to this letter. In summary, none of the changes to the Fire Protection Report included in Amendment 8 require NRC approval for Byron Unit 1. They represent either new information provided for NRC review or updates to reflect the "as-built" condition and editorial corrections, i.e., changes which do not represent a decrease in the level of fire protection. Please direct any questions regarding this matter to this office. One signed original and forty (40) copies of this letter, the attachments, and Amendment 8 are provided for your use. Very truly yours, i K. A. Ainger Nuclear Licensing Administrator I la l Attachments i l l 1749K
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Commonwealth Edison _ ~_ 72 Wott Adams Street, Chicago, Illinois ,) Address Reply to: Post Office Box 767 Q Chicago, Illinois 60690-0767 June 11, 1986 i Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 i
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Fire Protection Report - Amendment 8 Mtc Docket Mos. 50-454/455 and 50-456/457 Reference (a): August 16, 1982 letter from T. R. Trame to H. R. Denton t t
Dear Mr. Denton:
This letter provides Amendment 8 to the Byron /Braidwood Fire Protection Report (FPR) which was submitted in Reference (a). This amendment updates the FPR to incorporate new information and analyses 4 applicable to Byron Units 1 and 2 and Braidwood Units 1 and 2. These changes do not represent a decrease in the level of fire protection which require prior NRC approval according to Condition 6 of the Byron Unit 1 Operating License, NPF-37. I Amendment 8 includes a new section 2.4 and new Appendix A5.8 4 i providing the Byron Unit 2 safe shutdown analysis, and Appendix R j (Section.III G.2) deviations, respectively. Amendment 8 also includes miscellaneous changes throughout the FPR. These changes can generally be categorized as either editorial in nature, or as changes to reflect the latest "as-built" condition of the plants. Attachment A to this letter provides an itemized summary and explanation of all changes included in this amendment. This attachment is provided as an aid to the NRC in identification of changes. Attachment B 'o this letter provides a detailed section-by-section t comparison of the new Byron Unit 2 safe shutdown analysis presented in new i I section 2.4 against the Byron Unit I safe shutdown analysis. I-
l i Mr. H. R. Denton June 11, 1986 Attachment C to this letter provides a detailed comparison of the Byron Unit 2 Appendix R deviations presented in new Appendix A5.8 against the Byron Unit I deviations. These comparisons were requested by the NRC subsequent to the submittal of Amendment 7, which included a new Braidwood Unit I safe shutdown analysis and Appendix R deviations. These comparisons for the Amendment 7 material were submitted to the NRC under a separate cover letter. For Amendment 8, they are included as Attachments B and C to this letter. In summary, none of the changes to the Fire Protection Report included in Amendment 8 require NRC approval for Byron Unit 1. They represent either new information provided for NRC review or updates to reflect the "as-built" condition and editorial corrections, i.e., changes which do not represent a decrease in the level of fire protection. Please direct any questions regarding this matter to this office. One signed original and forty (40) copies of this letter, the attachments, and Amendment 8 are provided for your use. Very truly yours, K. A. Ainger Nuclear Licensing Administrator la Attachments l e 1749K
/ I. N Commonwealth Edison _ / 72 West Adams Street, Chicago, lilinois Address Reply to: Post Othee Box 767 Chicago, Illinois 60690-0767 p June 11, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Fire Protection Report - Amendment 8 NRC Docket Nos. 50-454/455 and 50-456/457 Reference (a): August 16, 1982 letter from T. R. Tramm to H. R. Denton
Dear Mr. Denton:
This letter provides Amendment 8 to the Byron /Braidwood Fire Protection Report (FPR) which was submitted in Reference (a). This amendment updates the FPR to incorporate new information and analyses applicable to Byron Units 1 and 2 and Braidwood Units 1 and 2. These changes do not represent a decrease in the level of fire protection which require prior NRC approval according to Condition 6 of the Byron Ursit 1 Operating License, NPF-37. Amendment 8 includes a new section 2.4 and new Appendix A5.8 providing the Byron Unit 2 safe shutdown analysis, and Appendix R (Section.III G.2) deviations, respectively. Amendment 8 also includes miscellaneous changes throughout the FPR. These changes can generally be categorized as either editorial in nature, or as changes.to reflect the latest "as-built" condition of the plants. Attachment A to this letter provides an itemized summary and explanation of all changes included in this amendment. This attachment is provided as an aid to the NRC in identification of changes. Attachment B to this letter provides a detailed section-by-section comparison of the new Byron Unit 2 safe shutdown analysis presented in new section 2.4 against the Byron Unit I safe shutdown analysis. _A
r Mr. H. R. Denton June 11, 1986 b Attachment C to this letter provides a detailed comparison of the Byron Unit 2 Appendix R deviations presented in new Appendix A5.8 against the Byron Unit I deviations. These comparisons were requested by the NRC subsequent to the submittal of Amendment 7, which included a new Braidwood Unit I safe shutdown analysis and Appendix R deviations. These comparisons for the Amendment 7 material were submitted to the NRC under a separate cover letter. For Amendment 8, they are included as Attachments B and C to this letter. In summary, none of the changes to the Fire Protection Report included in Amendment 8 require NRC approval for Byron Unit 1. They represent either new information provided for NRC review or updates to reflect the "as-built" condition and editorial corrections, i.e., changes which do not represent a decrease in the level of fire protection. Please direct any questions regarding this matter to this office. One signed original and forty (40) copies of this letter, the attachments, and Amendment 8 are provided for your use. Very truly yours, K. A. Ainger Nuclear Licensing Administrator 1m Attachments 1 t 4 1749K L
i I l ATTACHMENT A LO Description of Amendment 8 Changes to Pages Previously Submitted I Page No. Description of Changes i F2.3-0 Addition of a " Byron Only" and "Braidwood Only" symbol for fire detectors and fire hose stations. F2.3-1 Addition of a second fuel oil storage tank. F2.3-2 Addition of a second fuel oil storage tank. F2.3-4 Two stairwells are shown in Zone 11.7-0. This is to be consistent with the as-built i configuration of the zone. F2.3-5 These changes are editorial. Equipment labels were revised for the control panels at Q-15 and Q-21 and their positions corrected, and an elevation label was added in Zone 11.7-0. ) F2.3-6 An "up" stairwell was added at S-17 and the wall at W-13/23 was revised to show that it is i not a 3-hour fire barrier. 4 F2.3-7 The doors at Q-18 are now shown as " Label (A) doors. 4 t F2.3-8 Hose stations have been added, fire detectors have been revised to reflect their as-built i installation, and doors have been denoted as l " Label (A) doors on sheets 1 through 4 of Figure 2.3-8. i l F2.3-9 Fire Zone 3.2C-2 has been labeled, and fire l detection and suppression is revised to reflect i as-built conditions. i i F2.3-10 The boron injection recirculation pumps and surge tank were removed from sheets 1 and 3, and the startup feedwater pumps were added to sheets 2 and 4. For all sheets, hose stations, fire detectors, and fire suppression have been revised to reflect as-built conditions. LO 1 L
r-ATTACHMENT A (Cont'd) Page No._ pescription of Changes F2.3-11 The walls at W-15 and W-21 were revised to show a 3-hour fire barrier. The stairwells at Q-ll and Q-24 were revised to show their construction, and hose station 205 was moved to its correct location. F2.3-12 For all sheets, fire detection and suppression was revised to reflect as-built conditions. A stairwell was added on sheet 3 at R22. Sheet 4 now shows the I.M. shop for Braidwood only. F2.3-13 Wall construction was updated on both sheets, as well as fire detection and suppression. F2.3-14 For all sheets, fire detection and suppression was revised to reflect as-built conditions. F2.3-15 Fire detection and suppression was revised to reflect as-built conditions. F2.3-17 The construction of the third floor storeroom was revised to reflect as-built conditions. F2.3-18 The ground and second floor plan was revised to show Byron only construction differences and ,,f BOP mechanical equipment fire hazards. Fire detection symbols were deleted in the storeroom areas. F2.3-19 Fire detection was added in Zone 12.1-0. F2.3-20 Fire detection was added in Zone 12.1-0. The door at AA-15 was labeled as a Label (A) construction door. F2.3-28 The fire detection in Zone 18.13-0 was labeled " Byron Only." F2.3-34 The Unit-2 Plan was revised to agree with Figure 2.3-9. F2.3-35 For all sheets, the boron injection recirculation pumps and surge tank were deleted. F2.3-41 The Technical Support Center charcoal filter was added at elevation 451'-0" and was shown as a BOP mechanical equipment fire hazard.
ATTACHMENT A (Con t ' d ) () Page No. Description of Changes 2.4-15 (Braid-1) This correction is primarily editorial. The intent of the statement was that plant procedures allow for local emergency control of t the diesel generators. 2.4-30, 2.4-30a Discussion of loss of cold leg RTD cables in (Braid-1) Zone 11.6-1 has been revised to discuss additional acceptable means of verifying primary system temperature conditions. 2.4-37 (Braid-1) "Short (s)" changed to "short" since 2 simultaneous hot shorts in valve power cabling are not postulated. 2.4-43 and 2.4-44 Clarification of analysis and results of (Braid-1) failure modes 1 and 2 to state that failures in control room (Zone 2.1-0) are addressed in analysis and results of f ailure mode 3. 2.4-109 (Braid-1) Division 12 cables 1SX296 and 1SX301 deleted since they are not routed in Zone 5.2-1. 2.4-199 and 2.4-201 Editorials revised to delete listing of ESW (Braid-1) makeup pump and ESW cooling tower fan controls O since Braidwood does not have this equipment. 2 A5.8.13-1 (Byron-1) Combustible loading of 17,400 gtu/ft for Zone 11.3-1 changed to 9,900 Btu /ft This is consistent with Table 2.2-3. A5.8.26-1 (Byron-1) Revised to indicate that ionization detection is not provided on El. 475 feet 6 inches. This is consistent with Figure 2.3-4. A5.8.4-1 and Revised to reference correct table number and A5.8.4-2 (Braid-1) also to indicate that floor penetrations in the area between column-rows 14-17/N-P.5 on Elevation 383 feet will be sealed to prevent the vertical spread of fire. AS.8.5-1 (Braid-1) Revised to reference correct table number and also to indicate'that floor penetrations in the area between column-rows 13-15/M-P.5 on Elevation 401 feet will be sealed to prevent the vertical spread of fire. A5.8.6-1 and Revised to reference the correct table A5.8.7-1 (Braid-1) number. 3
..= - ATTACHMENT A (Cont'd) Page No. Description of Changes A5.8.22-1 (Braid-1) Editorials corrected 475 feet 0 inch to 475 1 feet 6 inches. ( A5.8.27-1 (Braid-1) The description of equipment / cables involved was revised to list all 6 NR cables. The other change is editorial. A5.8.31-1 (Braid-1) First change is editorial. The second change was made to discuss additional acceptable means of verifying primary system temperature conditions in the event that all cold leg RTD indication is lost. I t i i ) 9 l0 I I. t 4 i i i 1 4 l i I i
- O I
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ATTACHMENT B l / Comparison of Byron-2 vs. Byron-1 Safe Shutdown Analysis The following comparison is performed on a subsection by subsection basis for Section 2.4, " Safe Shutdown Analysis" of the B/B Fire Protection Report. The new Byron-2 section submitted with Amendment 8 to the FPR is compared with the existing Byron-1 section. Section No. Comparison 2.4.1.1 The Byron-2 section is identical to the Byron-1 section. 2.4.1.2 The Byron-2 section is identical to the Byron-1 section. 2.4.1.3 The Byron-2 section is identical to the Byron-1 section except as noted below. In the second paragraph under "b", the statement is made that the cable data base is updated monthly. For Byron-2, this statement has been changed to indicate that the cable data base is updated periodically, since the level of design activity has dropped to the point that monthly updates are not required. Also, the table O references in the last paragraph under item "b" are different. Refer to the discussion for Table 2.4-4 for a more detailed explanation. 2.4.1.4 The introductory paragraph and the second paragraph through item "a" are identical to Byron-l. Item "b" for Byron-2 is equivalent to items "b" through "e" for Byron-l. In other words, the safe shutdown equipment list is presented in one table for Byron-2, while, four separate tables were involved for Byron-l. Refer to the discussion for Table 2.4-2 for a more detailed explanation of the rationale and the specific differences between the equipment lists for those units. 2.4.1.5 The Byron-2 section is identical to the Byron-1 section except as noted below. Under items "2" and "3", the procedure numbers and titles have been changed to reflect the equivalent Byron-2 procedures. Item "5b" has been modified to indicate that the analysis for Byron-2 will be provided in a future FSAR amendment. A new item "5d" is provided for Byron-2. This does not represent a change in commitments or method [} of analysis. Rather, it represents a more 1
ATTACHMENT B (Cont'd) Section O No. Comparison detailed description of work that was performed for Byron-1, but was not explicitly described It is included here for additional clarity. 2.4.1.6 The Byron-2 section is identical to the Byron-1 section except for the table reference. Refer to the discussion for Table 2.4-3 for a more detailed explanation of specific repair differences. 2.4.2 The introductory paragraphs have been changed to delete reference to Byron-1 Tables 2.4-7, 2.4-8 and 2.4-9. These tables list, respectively, Unit 2 zones not analyzed, Unit 1 and shared zones which do not contain safe shutdown equipment or cables, and Unit 1 zones which contain equipment or cables from only one division. These tables do not contain any information essential to the analysis, and thus equivalent tables for Byron-2 are not provided. This change is editorial. O 2.4.2.1 Containment - For Byron-2, the entire containment was analyzed as one zone, since subdivisions are not relevant for fire protection (safe shutdown) purposes. This section is thus equivalent to Byron-1 Sections 2.4.2.1 through 2.4.2.3. Effects on the RHR system are the same as for Byron-1 (Byron-1 Sections 2.4.2.1 and 2.4.2.2). The credit taken for repair to allow RHR system operation is the same as for Byron-l. As for Byron-1 (Sections 2.4.2.1 through 2.4.2.3) the incore thermocouples and hot and cold leg RTD's are affected. The modification to the hot and cold leg RTD's proposed by Byron-1 has already been installed for Byron-2. Two Appendix R deviations have been identified for Byron-2 which are basically the same as those for Byron-1 (refer to the Appendix AS.8 comparison for details). All source range neutron monitors are affected as fer Byron-1 (Sections 2.4.2.1 and 2.4.2.2). An Appendix R deviation has been 2
ATTACHMENT B (Con t ' d ) O Section No. Comparison identified for Byron-2 that is basically the same as that for Byron-1 (refer to the Appendix A5.8 comparison for details). As for Byron-1, all channels of steam generator level, pressurizer level and pressurizer pressure are affected. In each case, an Appendix R deviation has been identified for Byron-2 that is basically the same as a Byron-1 deviation. (Refer to the Appendix A5.8 comparison for details.) Both PORV'S and block valves are affected as for Byron-l. An Appendix R deviation has been identified for Byron-2 that is basically the same as for Byron-1 (refer to the Appendix AS.8 comparison for details). All four RCFC's are analyzed for Byron-2. This equipment was not analyzed for Byron-l. As a result, a new Appendix R deviation has been identified. Further explanation is provided in O the comparison for Byron-2 Table 2.4-2 and in the comparison of Appendix AS.8. For Byron-1, both channels of wide range RCS pressure were affected inside containment. A subsequent design change, which was unrelated to fire protection, resulted in the relocation of the pressure transmitters to outside containment. Thus these instruments are not affected inside containment at Byron-2. 2.4.2.2 Zone 2.1-0 (Byron-1 Section 2.4.2.4) - For a fire in this zone, credit is taken for reactor. trip and verification of control rod insertion prior to evacuation. This is the same as for Byron-l. Control of the pressurizer PORV'S could be lost following a fire in this zone. Credit is taken for implementing a repair to the control circuit prior to depressurizing the primary system (required to achieve could shutdown). This is the same as for Byron-l. For all other systems affected, alternate shutdown is available from the remote shutdown 3
ATTACHMENT B (Cont'd) ~ ( )~ Section No. Comparison panels and/or locally. This is the same as for Byron-l. Equivalent Byron-2 procedures are referenced. An Appendix R deviation has been identified that is basically the same as for Byron-1 (refer to the Appendix A5.8 comparison for details). For Byron-1, credit was taken for interim procedures to sample the primary system for boron concentration (in place of neutron monitoring) until the modification to install the fire hazards panel was completed. For Byron-2, this panel, which includes indication of source range neutron flux, has already been installed. Thus, no interim procedures are required. Credit is taken for implementing repairs to the RHR system prior to achieving cold shutdown. This is the same as for Byron-l. .s 2.4.2.3 Zone 2.1-2 (No equivalent Byron-1 section) - No safe shutdown cables were present in the equivalent Unit 1 zone. 2.4.2.4 Zone 3.1-2 (Byron-1 Section 2.4.2.5) This summary is the same as for Byron-l. 2.4.2.5 Zone 3.2-0 (Byron-1 Section 2.4. 2. 6) This summary is the same as for Byron-l. 2.4.2.6 Zone 3.2A-2 (Byron-1 Section 2.4.2.7) Both trains of PORV's and block valves are affected in this zone. The discussion of the effects and the repair for which credit is taken prior to depressurizing the primary system is the same as for Byron-l. For Byron-2, cables for both diesel generators are present in this zone. A one-hour rated fire barrier will be provided around some of the Division 21 cables to ensure operability of the 2A diesel generators. At Byron-1, it was sufficient to take credit for local operation of the 1A diesel generator. In addition, a control cable for the Division 21 switchgear O 4 l' _r,-- ..-w~ew-,m- --=---m-- + - ~., - -. -w.r, ,,,~=.o.---w..,-w-.w-w.~,.---
.. _ _.. ~ ATTACHMENT B (Cont'd) Section O No. Comparison room is present. It will also be protected with a one-hour rated barrier. This was not required at Byron-l. Both divisions of the DC power system are affected in this zone. An Appendix R deviation was identified for the battery charger power i cables (refer to the Appendix AS.8 comparison ) for deviation details). A one-hour rated fire i barrier will be provided for some specific cables. The discussion, deviation and modification are the same as for Byron-l. Control power cables for both trains of switchgear are affected. This is compensated for by local operation of equipment at the switchgear. This is the same as Byron-l. Control cables for some specific Division 21 components are in this zone (ESW pump 2A). The specific components affected differ from Byron-l. However, in each case, the Division 21 components can be locally operated at the O switchgear. The safe shutdown effects are thus the same at both units. Only one train of the RHR system is affected for Unit 2. Both trains were affected for Unit 1. Thus it is not necessary to take credit for any repairs for this zone for Unit 2. 2.4.2.7 Zone 3.2B-2 (Byron-1 Section 2. 4. 2. 8) - For Byron-1, credit was taken for interim procedures to compensate for loss of neutron monitoring and the RCS cold leg RTD's until the modification to install the fire hazards panel was completed. For Byron-2, this panel has already been installed, thus no interim procedures are required. All four steam generator atmospheric relief valves could be affected in this zone. At Byron-1, only one train (two valves) was affected. Both trains of pressurizer PORV's are affected for Byron-2 requiring a repair prior to achieving cold shutdown. This did not occur at 5
ATTACHMENT B (Cont'd) j N Section No. Comparison Byron-l. Only one train of the RHR system is affected at Byron-2, whereas at Byron-1, both trains were affected which required a cold ) shutdown repair. s' 2.4.2.8 Zone 3.2C-2 (Byron-1 Section 2.4.2.9) - As previously stated, the fire hazards panel has <s y already been installed for Byron-2, thus complete loss of neutron monitoring and RC cold leg temperature indicatAon does not occur as it did for Byron-l. Credit is taken for repairing RHR heat ~ exchanger outlet teeperature instrumentation prior to achidving. cold shutdown. This is the same as Byron-l. 2.4.2.9 Zone 3.2D-2 (Byron-1 Section 2.4.2.10) - The summary is the same as for Byron-l. 2.4.2.10 Zone 3.2E-2 (Byron-l.Section 2.4.2.11) - At Byron-1, two Division 12 cables were routed in this zone. At Byron-2, only Division 21 cables s are present. The safe shutdown effects are the same for both units, despite minor differences in equipment affected. 2.4.2.11 sZone 3.3A-2 (Byron-1 Section 2.4.2.12) - The cummary is the same as for Byron-l. Zone 3.3B-1 (Byron-1 Section 2.4.2.13) -A 2.,4.2.12 repair was r6 quired at Dyron-1 for RHR heat , exchanger outlet temperature instrumentation. This is not required for Byron-2. Only Division 21~ cables are present, as was the case for Byron-l. 12.4.2.13 Zone 3.3C-2 (Byron-1 Section 2. 4. 2.14) -A repair to RHR system instrumentation is required for Byron-1, but not for Byron-2. At Byron-2, both trains of neutron monitoring instruments could be affected, which did not occur at Byron-1, Since redundant indication of source. range neutron flux is provided at the fire hazards panel, this is acceptable. Only Jo~ivision 21 cables are present, as at Byron-l. 2.4.2.14 Zone 3.3D-2 (Byron-1 Section 2.4.2.15) - Both 6 w
ATTACHMENT B (Cont'd) Section O No. Comparison trains of neutron monitoring instrumentation are affected in this zone, which did not occur at Byron-l. Since redundant indication of source range neutron flux is provided on the fire hazards panel, this is acceptable. Only Division 21 cables are present, as at Byron-l. 2.4.2.15 Zone 3.4A-2 (Byron-1 Section 2.4. 2.16) - As at Byron-1, only Division 21 cables are present. However, both trains of source range neutron monitoring indication are affected at Byron-2 (not at Byron-1). This is acceptable, however, as redundant indication of source range neutron flux is provided on the fire hazards panel. 2.4.2.16 Zone 5.1-2 (Byron-1 Section 2.4.2.17) - The summary is the same as for Byron-l. 2.4.2.17 Zone 5.2-2 (Byron-1 Section 2.4.2.18) - At Byron-1, only Division 11 cables were present. At Byron-2, a Division 22 cable is present, in addition to the many Division 21 cables. This cable is associated with steam i generator pressure indication. Since redundant indication is provided at the fire hazards panel, this is acceptable. i 2.4.2.18 Zone 5.3-2 (Byron-1 Section 2.4.2.19) Equipment and cables from only one division are present, as at Byron-l. 2.4.2.19 Zone 5.4-2 (Byron-1 Section 2.4.2.20) -A + number of Division 11 control cables are routed through this zone for Byron-l. Only a single Division 21 cable is present for Byron-2. i Credit is taken for repairing the pressurizer PORV cable prior to depressurizing the primary system. This is a different repair than the l one required at Byron-l. 2.4.2.20 Zone 5.5-2 (Byron-1 Section 2.4. 2.21) - The same components and instruments are affected at Byron-2 as at Byron-l.- An Appendix R deviation has been identified for Byron-2. This is basically the same as the Byron-1 deviation (refer to the Appendix AS.8 comparison for details). For Byron-2, credit is taken for local operation of affected components at the 7 l
ATTACHMENT B (Cont'd) O Section No. Comparison switchgear. This is the same as at Byron-l. For instrumentation, a fire hazards panel has been installed at Byron-2 independent of this zone. The instrumentation on the panel is the same as at Byron-l. This panel has already been installed at Byron-2, thus no interim procedures or fire watches are required as was the case for Byron-l. Credit is taken for effecting repairs to the RHR system and to reactor coolant system wide range pressure instrumentation prior to achieving cold shutdown. This is the same as Byron-l. 2.4.2.21 Zone 5.6-2 (Byron-1 Section 2.4.2.22) - The summary is the same as for Byron-l. NA Zone 8.3-1 (Byren-1 Section 2.4.2.23) - No safe shutdown cables are in this zone at Byron-2. NA Zone 8.5-1 (Byron-1 Section 2.4.2.24) - No safe shutdown cables are in this zone at Byror-2. () 2.4.2.22 Zone 9.1-2 (Byron-1 Section 2.4.2.25) - The summary is the same as for Byron-l. 2.4.2.23 Zone 9.2-2 (Byron-1 Section 2.4.2.26) - One Division 22 cable is present, which did not occur at Byron-1. However, there are no safe shutdown consequences. 2.4.2.24 Zone 9.3-2 (Byron-1 Section 2.4.2.27) - The summary is the same as for Byron-l. 2.4.2.25 Zone 9.4-2 (Byron-1 Section 2.4.2.28) - The summary is the same as for Byron-l. 2.4.2.26 Zone 10.1-2 (Byron-1 Section 2.4t 2.29) - The summary is the same as for Byron-l. 2.4.2.27 Zone 10.2-2 (Byron-1 Section 2.4.2.30) - The discussion provided for Byron-1 regarding filling the AFW pump 1B day tank has been deleted, since a review of station procedures indicates that the tank is normally refilled by gravity feed from the outdoor fuel oil storage tank, and not from the 50,000 gallons of fuel oil in the diesel generator storage tanks. ) Only Division 11 equipment and cables are 8 l e e-r 4- ,y,w w-w- --v%--, c, w.--+-tvr-, ,w
ATTACHMENT B (Cont'd) /~ Section No. Comparison present at Byron-1. One Division 22 cable is present at Byron-2, but there are no safe shutdown consequences. 2.4.2.28 Zone ll.lA-0 (Byron-1 Section 2.4.2.31) - The summary is the same as for Byron-l. 2.4.2.29 Zone ll.lB-0 (Byron-1 Section 2.4.2.32) - The summary is the same as for Byron-l. 2.4.2.30 Zone 11.2-0 (Byron-1 Section 2.4.2.33) Cabling for both trains of the essential service water system are present. At Byron-1, an Appendix R deviation was identified. At Byron-2, a decision was made to protect the Division 21 cables with a 3-hour rated barrier. At Byron-1 cables for both trains of charging pumps were present. At Byron-2, only one train is affected. Both trains of the RHR system are affected in this zone. Credit is taken for effecting repairs to one train prior to achieving cold shutdown. This is the same / 'T as Byron-l. V 2.4.2.31 Zone 11.2A-2 (Byron-1 Section 2.4.2.34) - The summary is the same as for Byron-l. 2.4.2.32 Zone 11.2B-2 (No equivalent Byron-1 section) No safe shutdown cables were present in this zone for Byron-l. 2.4.2.33 Zone ll.2C-2 (Byron-1 Section 2.4.2.35) - The summary is the same as for Byron-l. 2.4.2.34 Zone ll.2D-2 (Byron-1 Section 2.4.2.36) - The l summary is the same as for Byron-l. 2.4.2.35 Zone 11.3-0 (Byron-1 Section 2.4.2.37) Basically the same systems and components are affected at Byron-2 as for Byron-l. At Byron-2, a 3-hour rated barrier will be provided around Division 21 cables associated with the essential service water pump 2A and centrifugal charging pump 2A, to allow local operation of l these pumps at the switchgear. This is the same as Byron-l. A deviation from Appendix R l has been identified at Byron-2 for the component cooling system. This is basically 9
ATTACHMENT B (Cont'd) ( Section No. Comparison the same as the Byron-1 deviation (refer to the Appendix AS.8 comparison for details). Both trains of the RHR system can be affected. Credit is taken for effecting cable repairs to one division prior to achieving cold shutdown. This is basically the same as for Byron-l. 2.4.2.36 Zone 11.3-2 (Byron-1 Section 2.4.2.38) - As at Byron-1, power and control cables for both trains of the essential service water pumps and the centrifugal charging pumps are affected in this zone. A one-hour rated fire barrier will be provided around the Division 22 cables to allow local operation of the 2B charging and ESW pumps at the switchgear. This is still a deviation from Appendix R. Refer to the Appendix AS.8 comparison for details. This is basically the same as for Byron-l. Cables for all four main steam atmospheric relief valves are present. This is acceptable, since the local operation of these valves is unaffected. All of these cables were not present at Byron-1, however. Credit is taken for effecting repairs to one train of the RHR system, the RHR heat exchanger outlet temperature instrumentation, and reactor coolant wide range pressure instrumentation prior to achieving cold shutdown. This is similar to Byron-l. 2.4.2.37 Zone ll.3B-2 (Byron-1 Section 2.4.2.39) - The summary is the same as for Byron-l. 2.4.2.38 Zone ll.3C-2 (No equivalent Byron-1 section) No safe shutdown cables were present in this zone at Byron-l. 2.4.2.39 Zone ll.3D-2 (Byron-1 Section 2.4.2.40) - The summary is the same as for Byron-l. ~2.4.2.40 Zone 11.3E-2 (Byron-1 Section 2.4.2.41) - The summary is the same as for Byron-l. 2.4.2.41 Zone ll.3G-2 (Byron-1 Section 2.4.2.42) - The summary is the same as for Byron-l. 10
ATTACHMENT B (Cont'd) Section O No. Comparison 2.4.2.42 Zone 11.4-0 (Byron-1 Section 2.4.2.43) - Cables for both divisions of component cooling and essential service water pumps are located in this zone. This discussion of the effects of a fire in this zone and the addition of a fire barrier to separate Division 21 and 22 cables is the same as for Byron-l. Power and control cables fcr auxiliary feedwater pumps 2A and 2B are located in this zone, as well as auxiliary feedwater pump 2A. An Appendix R deviation has been identified for the AFW pump 2B cables (see the Appendix AS.8 comparison for details). A remote start switch for AFW pump 2B has been added. The discussion, deviation, and modification are the same as for Byron-l. Due to differences in cable routings, power and control cables for DG 2A fuel oil transfer pump 2A and DG 2B fuel oil transfer pump 2B are (~ routed through this zone for Byron-2. This s does not occur at Byron-l. This does not affect safe shutdown at Byron-2, as transfer j pump 2C is available to serve DG 2A. Cables for all four main steam atmospheric relief valves are present in this zone at Byron-2. At Byron-1, cables for main steam atmospheric relief valves lA, 1B, and ID are routed through this zone. The use of local manually operated hand pumps for the main steam atmospheric relief valves is the same for both units. Instrument cables for redundant channels of neutron monitoring are routed through this l zone. Additional monitoring channels independent of this zone have been provided. This is the same as for Byron-l. Power and control cables for RHR pump 2A and 2B cubicle coolers, power cables for RHR pumps'2A l and 2B, and instrument cables for RHR heat exchanger 2A and 2B outlet temperature indication are present in this zone. This is the same as for Byron-l. The credit taken for O repair is the same as for Byron-l. 11 l .-.)
ATTACHMENT B (Cont'd) Section O No. Comparison 2.4.2.43 Zone ll.4A-2 (Byron-1 Section 2.4.2.44) - This zone contains Division 22 cables except for one Division 21 cable associated with the component cooling pump 1A. For Byron-2, credit is taken for the operation of AFW pump 2A at the 4 switchgear. For Byron-1, loss of the essential service water supply to the AFW pumps lA and 1B will not af fect the ability to safely shut down the plant since the condensate storage tank is the normal source of water. 2.4.2.44 Zone ll.4B-0 (Byron-1 Section 2.4.2.45) - This summary is the same for Byron-l. 4 2.4.2.45 Zone ll.4C-0 (Byron-1 Section 2.4.2.46) - The remote shutdown panels are located in this zone. A fire will cause the panels to become inoperable, as well as the corresponding controls in the control room. Credit is taken for the availability of alternate shutdown for all controls located in this zone. This is the same as for Byron-l. The discussion of remote shutdown panels 2PLO4J, 2PLO5J, and 2PLO6J is the same as for Byron-l. All instrumentation which might be lost as a result of a fire in this zone has either redundant channels or diverse instruments which provide equivalent information to the operators and is available in the control room or elsewhere. All essential equipment controlled from these panels can be controlled from other locations. This is the same as for Byron-l. 2.4.2.46 Zone ll.4C-2 (No equivalent Byron-1 section) No safe shutdown equipment is in this zone at 1 Byron-l. 2.4.2.47 Zone ll.4D-0 (No equivalent Byron-1 section) No safe shutdown equipment is in this zone at Byron-l. 2.4.2.48 Zone 11.5-0 (Byron-1 Section 2. 4. 2. 47) - Cables 4 for both divisions of centrifugal charging pumps, essential service water pumps, and component cooling pumps are routed through this zone. In addition, power and control cables O 12 4 ,-,---,c.- .-..n-.,n -.,n--- ...-.-..-n-,-.
ATTACHMENT B (Con t ' d ) T Section ('j N No. Comparison for DG cooling water valves 2SX169A and 2SX169B are routed through this zone for Byron-2. only. The discussion of a fire in this zone and the addition of a fire barrier to separate Division 21 and Division 22 cables is similar to Byron-l. The major difference is that protection is provided for the Division 22 cables at Byron-2. At Byron-2, this zone also contains auxiliary feedwater pump 2A, 2B, and pump 2A and 2B auxiliaries power and control cables. Credit is taken for the local operation of AFW pump 2B. At Byron-2, power and control cables for Division 21 RCFC and control cables for Division 22 RCFC are routed through this l zone. The Division 22 power cables will be protected to allow operation of Train B fans at the switchgear. O At Byron-2, Division 12. control room ventilation system control and power cables and Division 11 control room ventilation system control cables are located in this zone. The Division 11 supply fan can be operated locally at the switchgear. Although the Division 11 return fan cannot be operated locally, shutdown of the plant from the control room is still possible if the supply fan is operable. Cables serving all four main steam atmospheric relief valves are located in this zone. Credit t is taken for operating the valves using hand pumps in the main steam pipe tunnel. This is the same as for Byron-l. At Byron-2, instrument cables for redundant channels of neutron monitoring are located in this zone. An additional channel has been added which is independent of this zone. At Byron-1, instrumentation cables for all reactor coolant wide range hot leg RTD's and all incore thermocouples are routed through this zone. Dual element RTD's have been provided, and the O 13 -r,..en- + -,----._.,,--.,,,.,---n._
ATTACHMENT B (Cont'd) O-Section No. Comparison 4 cables for these RTD's have been routed such I that a fire in this zone will not result in the loss of all indication. t Power cables. for RHR pumps 2A and 2B, power and control cables for RHR pump 2A and 2B cubicle coolers, and instrument cables for RHR heat exchanger 2A and 2B outlet temperature indication and both channels of reactor coolant wide range pressure indication are routed through this zone. This is the same as for Byron-l. The credit taken for repairs is the j same as for Byron-l. 2.4.2.49 Zone 11.5-2 (No equivalent Byron-1 section) No safe shutdown equipment is located in this zone at Byron-l. ? NA Zone ll.5A-0 (Byron-1 Section 2.4.2.48) - No safe shutdown cables are routed through this zone for Byron 2. 2.4.2.50 Zone 11.5A-2 (Byron-1 Section 2.4.2.49) -A fire in this zone will result in the loss of all four main steam atmospheric relief valves. These valves can be-operated manually c using hand pumps in the main steam tunnel.- At Byron-1, this zone contains only Division 11 equipment and cables. Cables for both channels of reactor coolant wide range pressure instrumentation are present. Credit is taken for effecting repair prior to achieving cold shutdown. This did not occur for Byron-l. 2.4.2.51 Zone ll.5B-2 (Byron-1 Section 2.4.2.50) Cables for both channels of reactor coolant wide range pressure instrumentation are present. Credit is taken for effecting repair prior to achieving cold shutdown. This did not occur for Byron-l. 2.4.2.52 Zone 11.6-0 (Byron-1 Section 2.4.2.51) Control and control power cables for diesel generators 2A and 2B are routed through this zone along with' control cables for their room ventilation fans. The Division 22 cables will J 14
l ATTACHMENT B (Cont'd) O Section No. Comparison be protected, as well as the Division 22 cables for the DG cooling water valves. Deviations from Appendix R are required for Byron-1; however, no corresponding deviations.are necessary for Unit 2 because of the aforementioned modifications. Power and control cables for CV pump 2A and control cables for CV pump 2B are located in this zone. Credit is taken for operating pump 2B at the switchgear. This is the same as for Byron-l. Control. cables for ESW pumps 2A and 2B, and for j component cooling pumps "O", 2A, and 2B are routed through this zone. Credit is taken for operating ESW pump 2B and component cooling pump 2B at the switchgear. This is the same as for Byron-l. At Byron-2, control cables for AFW pump 2A, pump 2B, and the auxiliaries for pump 2A, as well as power cables for pump 2B auxiliaries are located in this zone. Credit is taken for l starting pump 2B locally at the pump. This is l the same as for Byron-l. Cables for all four main steam atmospheric relief valves are routed through this zone. Credit is taken for the local operation of the valves using hand pumps. This is the same as for Byron-l. At Byron-2, power and control cables for the Division 21 RCFC fans, control cables for the Division 22 RCFC fans, and power and control cables for redundant control room supply and return fans are located in this zone. Credit is taken for the local operation of the Division 22 RCFC and control room supply fans at the switchgear. Safe shutdown from the control room can be achieved without using the return fans. At Byron-2, instrument cables for the redundant channels of neutron monitoring are located in this zone. Additional monitoring channels independent of this zone have been added. At 15 i
ATTACHMENT B (Cont'd) / Section No. Comparison Byron-1, cables required for all reactor coolant wide range hot leg RTD's and all incore thermocouples are routed through this zone. Dual element RTD's have been provided, and the cables for these RTD's have been routed such that a fire in this zone will not result in the loss of all indication. Instrument cables for both trains of RHR heat exchanger outlet temperature indication and power and control cables for both RHR pumps are located in this zone. Credit is taken.for repairing one division. This is the same as for Byron-l. t 2.4.2.53 Zone 11.6-2 (Byron-1 Section 2.4.2.52) Division 21 and 22 cables associated with neutron monitoring are routed through this 4 zone. For Byron-2, an additional channel of source range flux indication has been installed i independent of this zone. This is the same as Byron-l. i Instrument cables for reactor coolant loop 2A, 2B, 2C, and 2D cold leg RTD's are routed through this zone. At Byron-1, a commitment i was made to route cables for the new dual element RTD's so that all indication would not be lost after a fire in this zone. This modification has proved to be not feasible. However, loss of all cold leg RTD's is acceptable for the following reasons. These would normally be used in conjunction with the i hot leg RTD's to verify adequate core cooling, i.e., that natural circulation is present. This condition can also be verified by trending the temperatures indicated by the core exit thermocouples. Furthermore, subcooled i conditions in the primary system can be verified by the plant computer, if it is l available, or by manual calculation using instrumentation independent of this zone, if the computer is not available. Furthermore, cold leg temperature can be inferred from steam generator pressure. Plant emergency procedures are written to refer to these alternate methods of verifying primary system conditions. In fact, the core exit thermocouples are the 16 h .m., ,,,----m-w,--.- ,,--.-,,.,r-- .,,e 4 ,, - -,. + - - - - ..,-,,,-ym,..--, ,=~m, -..--o ,--,.-rw-e, ,---.-,----,,.-m,
l ATTACHMENT B (Cont'd) O'. Section-No. Comparison 3 preferred method. The Byron and Braidwood plant procedures are written using guidance from the Westinghouse Owners Group. Thus, loss of all cold leg RTD's in this zone is acceptable. 2.4.2.54 Zone ll.6A-0 (Byron-1 Section 2.4. 2.53) - For Byron-2, no safe shutdown equipment is located in this zone. 2.4.2.55 Zone ll.6A-2 (Byron-1 Section 2.4.2.54) - This summary is the same as for Byron-l. 2.4.2.56 Zone 11.6B-0 (No equivalent Byron-1 section) j No safe shutdown cables were present for Byron-l. NA Zone ll.6C-0 (Byron-1 Section 2.4. 2.55) - No cables are present in this zone at Byron-2. 2.4.2.57 Zone 11.6E-0 (No equivalent Byron-1 section) No safe shutdown cables were present for Byron-l. 2.4.2.58 Zone 11.7-0 (Byron-1 Section 2.4.2.56) - This summary is the same as for Byron-l. An Appendix R deviation has been identified for this zone, relating to redundant power and control cables for the auxiliary building ventilation fans (see the Appendix AS.8 comparison for details). 2.4.2.59 Zone 11.7-2 (No equivalent Byron-1 section) i At Byron-1, no safe shutdown equipment is located in this zone. I j 2.4.2.60 Zone 14.1-0 (No equivalent Byron-1 section) I No safe shutdown cables were present for Byron-l. l: 2.4.2.61 Zone 16.1-2 (Byron-1 Section 2.4.2.57) - The summary is the same as for Byron-l. 2.4.2.62 Zone 17.2-1 (Byron-1 Section 2.4.2. 58) - The j summary is similar to Byron-l. l 2.4.2.63 Zone 17.2-2 (Byron-1 Section 2.4.2.59) - The l summary is similar to Byron-l. 17 i . -. - - -.. -... -... -. -... -. ~ _. - _ - - _,.., - -. -. -. - _ _ _ _, -
~ 4 ATTACHMENT B (Cont'd) Section No. Comparison 2.4.2.64 Zone 18.1-2 (Byron-1 Section 2.4.2. 60) - The summary is the same as for Byron-l. 2.4.2.65 Zone 18.2-2 (Byron-1 Section 2.4.2.61) - The summary is the same as for Byron-l. 2.4.2.66 Zones 18.3-2 and 18.3A-2 (Byron-1 Section 2.4.2.62) - This summary is the same as for Byron-l.. An Appendix R deviation has been identified for this zone, relating to routing cables from the valve enclosures through the pipe tunnel (see the Appendix A5.8 comparison for details). 2.4.2.67 Zone 18.4-2 (No equivalent Byron-1 section) Only Division 12 equi present in this zone,pment and cables are 4 therefore, a fire in this zone would not affect the ability to safely shut down the plant. 2.4.2.68 Zone 18.5-2 (No equivalent Byron-1 section) No safe shutdown equipment is located in this () zone at Byron-l. 2.4.2.69 Zone 18.23-0 (Byron-1 Section 2.4. 2. 66) - This summary is the same as for Byron-l. l 2.4.2.70 Zone 18.11-0 (No equivalent Byron-1 section) This zone contains equipment newly added to the safe shutdown equipment list. Refer to the discussion for Table 2.4-2 for details. 2.4.2.71 Zone 18.11-1 (No equivalent Byron-1 section) This zone contains equipment newly added to the safe shutdown equipment list. Refer to the { discussion for Table 2.4-2 for details. l l 2.4.2.72 Zone 18.11-2 (No equivalent Byron-1 section) l This zone contains equipment newly added to the l safe shutdown equipment list. Refer to the discussion for Table 2.4-2 for details. NA Zone 18.14A-1 (Byron-1 Section 2.4.2. 64) - The cooling tower fans are deleted from the safe shutdown equipment list for Byron-2. Refer to the discussion for Table 2.4-2 for details. l 18 l l
ATTACHMENT B (Cont'd) O' Section No. Comparison NA Zone 18.14B-1 (Byron-1 Section 2.4.2. 65) - The cooling tower fans are deleted from the safe shutdown equipment list for Byron-2. Refer to the discussion for Table 2.4-2 for details. 2.4.2.73 Zone 18.23-0 (Byron-1 Section 2.4.2.66) - This summary is the same as for Byron-l. 2.4.2.74 Many Unit 1 zones (No equivalent Byron-1 section). This section is included to discuss Unit 1 zones containing cables associated with the auxiliary building ventilation system and the control room ventilation system.
2.4.3 General
The high-low pressure interfaces identified for Byron-2 are the same as those identified for Byron-l. Some of the cables and l cable routings are different. The major difference between the Byron-2 and Byron-1 discussions is that the Byron-2 writeup includes assessment of three-phase a-c hot shorts and d-c hot shorts in valve O power / control cabling. This was included per recent NRC guidance _(SECY-85-306, Enclosure 5, i Section 5.3.1, dated 9-17-85). Other i postulated failure modes are the same. Note that Section 2.4.3 for Byron-1 (Amendment 3, June 1984) is not current. Subsequent to Amendment 3, the Auxiliary System Branch of the staff requested that three phase a-c and 2 wire d-c hot shorts be considered outside of containment. As a result, this failure mode was addressed for Byron-1 by a combination of design changes and procedures to mitigate the effects of spurious operation. Although this item was closed on Byron-1, the FPR has not been updated to reflect this fact. 2.4.3.1 Same, except the two sentences referring to Subsections 2.4.3.2.1 and 2.4.3.2.2 have been deleted. 2.4.3.2 Same. 2.4.3.2.1 Same. O 19
ATTACHMENT B (Cont'd) ( Section No. Comparison 2.4.3.2.1.1 For Byron-2 power and control cables for the RH valves are listed in Table 2.4-11 not 2.4-76. Also, references to Tables 2.4-77 and 2.4-78 deleted since cable routing information for RH valves are not included for Byron-2. 2.4.3.2.1.2 For Byron-2 this subsection in entitled " Assumptions and Information." Content of this subsection differs from Byron-1 in that, for Byron-2 a hot short in valve power cabling is considered. Also, discussion is expanded to list postulated control circuit failures for each valve. Additionally, reference to "360 psig" for Byron-1 is given as "approximately 400 psig" for Byron-2. 2.4.3.2.1.3 For Byron-2 this subsection is entitled " Failure Modes." Same types of failure modes are postulated as for Byron-1 with the addition of a three-phase hot short in valve power cabling (failure mode 7). The acceptance criteria have been split into two parts: A) O power cable, and B) control / interlock circuit. This was done because, as discussed previously, a hot short in power cabling is postulated for Byron-2. The acceptance criteria for the control / interlock circuit are the same as for Byron-l. 2.4.3.2.1.4 This Byron-2 subsection, entitled " Method of Analysis," does not appear in the Byron-1 writeup. This new subsection was included to l give additional details on how the analysis was performed, and references a new table (2.4-12) which gives cable combinations considered to cause a spurious valve operation. Note also l that panels were not analyzed explicitly, as in l Byron-1, since the panel locations are included implicitly in cable routing data. Also cables routed only in Fire Zone 5.5-2 are not included in the cable combinations since a fire in this i zone would not cause any of the 4 valves to open. 2.4.3.2.1.5 This Byron-2 subsection, entitled "Results," does not appear in the Byron-1 writeup (for Byron-1 the results are given in , (} 2.4.3.2.1.3). For Byron-2 the results for each 20 l-
ATTACHMENT B (Cont'd) O_, Section No. Comparison s j s pair of valves are presented in two parts: A) power cable, and B) control / interlock circuit. There are some differences in the results relative to the zones in which a given. valve could open due to a fire. This is due to cable routing differences and the assumption of a hot short in the valve power cabling for Byron-2. However, no additional cable protection was required for Byron-2 (for Byron-1, cables associated with valve 1RH8701A were protected in Zone 11.5-0). 2.4.3.2.2 Same 2.4.3.2.2.1 The interface description has minor differences: For Byron-2 the PORV's are described as N -Operated rather than air-2 operated, and the references to contacts PY455EX, PY456EX, PY457EX, and PY458EX have been deleted. Also the power and control cables for the valves are listed in Table 2.4-13 (listed in Table 2.4-79 for Byron-1). O 2.4.3.2.2.2' For Byron-2, this subsection is entitled, l " Assumptions and Information," and was not included in Byron-1 analysis. This subsection states that a hot short in PORV d-c control / power cabling is considered. It also states that control / interlock circuit failures and block valve failures to close are also considered; these were also considered for Byron-l. 2.4.3.2.2.3 This subsection is entitled " Failure Modes" for Byron-2 and is the same as Byron-1 Subsection 2.4.3.2.2.2 on failure modes, except for some minor differences. For Byron-2 the discussion has been clarified to indicate that the block valve fails open (normal position).
- Also, Byron-1 cables RY398 and RY251 are numbered RY486 and RY487 for Byron-2.
2.4.3.2.2.4 This Byron-2 subsection, entitled " Method of Analysis," does not appear in the Byron-1 writeup. This new subsection was included to give additional details on how the analysis was included to give additional details on how the analysis was performed and references a new 21 l
ATTACHMENT B (Cont'd) O Section No. Comparison table (2.4-14) which gives cable combinations considered to cause a spurious valve operation. It also explains that panels were i not analyzed explicitly since the panel locations are included implicitly in the cable routing data. 2.4.3.2.2.5 This subsection, entitled " Evaluation and Results," appears in the Byron-1 writeup under Subsection 2.4.3.2.2.3. For failure modes 1 and 2 there are some differences in the results relative to the zones in which a given failure mode could occur. This is due to different cables and cable routings in the Byron-2 analysis. Also, for failure mode 2, the first paragraph in the Byron-1 discussion is not included in the Byron-2 writeup. This omission does not affect the results. For failure mode 3, th~e Byron-2 writeup references existing procedures used for closing the block valves following a fire in the control room, whereas the Byron-1 writeup states: "a procedure will O-be written..." Note that for failure modes 1, 2, and 3 the methods for mitigating the effects of these failures are the same for both Byron-1 and Byron-2. For failure mode 4, the Byron-2 writeup is completely different from the Byron-I writeup. As mentioned earlier under Section 2.4.3 " General," the Byron-1 section is not l current, and does not reflect a staff request (from the Auxiliary Systems Branch) to address this failure mode outside of containment. The l resolution for Byron-2 is the same as for Byron-1 outside of containment. This failure i mode was also addressed inside containment for Byron-2. Table 2.4-1 For Byron-2, this table is identical to Table 2.4-1 for Byron-l. In other words, the systems used for safe shutdown are the same for both i units. Table 2.4-2 For Byron-2, all safe shutdown equipment and instruments are listed in this table. This format is different from Byr6n-1 in that four i separate tables were presented for Byron-l. Except for specific equipment dif ferences listed below, the same equipment listed in 22 i i I ..,_._.,-m,,.,_._ -, _.. _,. _ _. _, ~, - m
ATTACHMENT B (Cont'd) f Section No. Comparison i Tables 2.4-2 through 2.4-5 for Byron-1 are ) listed in Table 2.4-2 for Byron-2. Some unused and redundant information included in Tables 2.4-2 through 2.4-5 for Byron-1 was deleted from Byron-2 Table 2.4-2. The Byron-1 tables had columns headed " Elevation" and " Column / Row." Since the analysis is performed on a fire zone basis. (and the fire zone in which the equipment is located was included for Byron-1 and is presented for Byron-2) the specific location within the fire zone represents information not utilized in the analysis. Therefore, it is not provided for Byron-2. Byron-1 Tables 2.4-2 through 2.4-5 had a column titled " Function." The information in this column is the same information provided in Table 2.4-1. Therefore, this column was not provided in Byron-2 Table 2.4-2. Thus, all information essential for the analysis is provided in Byron-2 Table 2.4-2. O A detailed comparison of the Byron-2 vs Byron-1 equipment list was performed. Table B-1 is a listing of equipment on the Byron-2 list not on the Byron-1 list, and Table B-2 is a listing of i equipment on the Byron-1 list not on the Byron-2 list. A column is provided which refers to notes that explain the additions and deletions for each piece of equipment. The changes i generally represent a refinement in the analysis, not a change in philosophy or method of analysis. Table 2.4-3 The equivalent Byron-1 table is 2.4-6. A comparison of these two tables will reveal that the affected equipment, repair description and required material are the same for both units. What differs is the specific fire zones for which a given repair may be required. This illustrates that the criteria for taking credit for repair is the same for both units. However, due to differences in cable routings, the specific fire zones where it is necessary to take credit for repairs are different. l O l 23 l 4 _,....... _ _. _,,.,~ ,..,....m _ _. ~. _, -, _. _. _ _ .-,.,.,_,.,,,,...,,_..,_,_-m,._ ..,_...,.,,,,--._.....~r,
l ATTACHMENT B (Cont'd) Section No. Comparison Table 2.4-4 Tables 2.4-10 through 2.4-75 provide the equivalent information for Byron-l. The major difference involves the format. J For Byron-1, a separate table number was utilized for each fire zone. For Byron-2, a new column 1 titled " Zone Number" was added to each page, which identifies the fire zone for which the equipment and cables are listed. Since the zones are listed in numerical order, finding a particular zone is readily i accomplished. For Byron-1, the tables included a column labeled " Safe Shutdown Function" which j indicated for each component, either "H" (hot i standby), "C" (cold shutdown) or "S" (support). This column was deleted in the Byron-2 table since it is redundant to the information in Table 2.4-1. In addition to the format differences, the equipment and cables within a given zone may be different for Byron-2 than for the O corresponding Byron-1 zone. The primary reason for these differences is that the cable routings may not correspond exactly. Equipment locations are generally identical. For Byron-2, the containment is listed and analyzed as one zone. For Byron-1, a separate discussion was provided for each of the three hazard zones identified and discussed in the Fire Hazards Analysis. This does not affect the results of the analysis. l j Tables 2.4-5, These Byron-2 tables correspond to Byron-1 2.4-6, 2.4-7, Tables 2.4-55a through 2.4-55f, respectively. l 2.4-8, 2.4-9, and Generally, the Byron-2 tables list the 2.4-10 equivalent Unit 2 remote shutdown panel r controls and instrumentation as on Byron-l. There are some differences primarily because some common equipment controls are not duplicated on both the Unit 1 and Unit 2 panels. These are discussed below. Byron-2 Tables 2.4-5, 2.4-6, and 2.4-7 are the same as Byron-1 Tables 2.4-55a, 2.4-55b, and 2.4-55c, respectively. Table 2.4-8 differs from Table 2.4-55d as follows: T2.4-8 has a different control number for OCCOlP; does not have controls for OSX02PA and the control room HVAC O 24 _ ~ _ - _ - _
ATTACHMENT B (Cont'd) O_ Section No. Comparison equipment; also lists ESW cooling tower fans C and D rather than A and B. Table 2.4-9 differs from 2.4-55e as follows: T2.4-9 has different control number for CCOlP; has controls for 2CV8104; does not have controls for OSXO2PB and the control room HVAC equipment; also lists cooling tower fans G and H rather than E and F. On Table 2.4-10, 2CV8104 was deleted since it is given on T2.4-9 (panel 2PLO5J), and OPWO2B is listed rather than OPWO2A. O O 25
m... _. ATTACHMENT B (Cont'd) l-l TABLE B-1 EQUIPMENT ON THE BYRON-2 LIST NOT ON THE BYRON-1 LIST i REASON WHY EQUIPMENT NOT ON OTHER NUMBER EQUIPMENT DESCRIPTION LIST
- 2AF01AA Motor Driven AF Oil Cooler 2
2AF01AB Diesel AF Pump Oil Cooler 2 2AF01E AFW Pump 2B Diesel Engine Batteries 2 2AF01BP-K AFW Pump 2B Diesel Engine 2 2AF02A AFW Pump 2B Gear Oil Cooler 2 OCC01A Comp Cooling Hx 3 2CC01A Comp Cooling Hx 3 h 2CC01T Comp Cooling Surge Tank 3 i 2CV02SA Ch'g Pump 2A Gear Cooler 2 j 2CV02SB Ch'g Pump 2B Gear Cooler 2 2CV03SA Ch'g Pump 2A Lube Oil Cooler 2 2CV03SB Ch'g Pump 2B Lube Oil Cooler 2 ODOO8TA. Ess'1 Service Water Makeup Diesel Tank OA 1 ODOO8TB Ess'l Service Water Makeup Diesel Tank OB 1 l 2D010T AF Diesel Day Tank 2 2NRllE Post Accident Neutron Detector 5 2NRllEB Post' Accident Neutron Detector Amplifier 5 2NRllEC Post Accident Neutron Detector Processor 5 2NR13E Post Accident Neutron Detector 5 2NR13EB Post Accident Neutron Detector Amplifier 5 2NR13EC Post Accident Neutron Detector Processor 5 2PL10J Fire Hazards Panel 5 2RC01BA Steam Generator 2A 3 2RC01BB Steam-Generator 2B 3 2RC01BC Steam Generator 2C 3 2RC01BD Steam Generator 2D 3 2RC0lR Reactor Vessel 3 2RY0lS Pressurizer 3 2RY32MA PORV Accumulator Tank 2A 5
- See Notes at the end of Table B-2.
26 [
ATTACHMENT B (Cont'd) TABLE B-1 (Cont'd) .O. REASON WHY EQUIPMENT NOT ON NUMBER EQUIPMENT DESCRIPTION OTHER LIST 2RY32MB PORV Accumulator Tank 2B 5 OSX02AA Ess'l Service Water Cooling Tower A 3 OSX02AB Ess'l Service Water Cooling Tower B 3 OSX02PA Ess'l Service Water Makeup Pump 1 OSX02PB Ess'l Service Water Makeup Pump 1 OSX04AA ESW Makeup Pump Gear Oil Cooler OA 1 OSX04AB ESW Makeup Pump Gear 011~ Cooler OB 1 l OSX162A MO' Valve (ESW Cooling Tower Bypass) 2 l OSX162B MO Valve (ESW Cooling Tower Bypass) 2 OSX162C MO Valve (ESW Cooling Tower Bypass) 2 OSX162D MO Valve -(ESW Cooling Tower Bypass) 2 l 2SX01AA Ess'l Service Water Pump 2A Oil Cooler 2 2SX01AB Ess'l Service Water Pump 2B Oil Cooler 2 2SX0lK Diesel AF Closed Cycle Hx 2 ( 2XS02K AF Gear Drive Lube Oil Cooler 2 OVC01CA Control Room HVAC Supply Fan 1 OVC01CB Control Room HVAC Supply Fan 1 l OVC0lJA Local Control Panel 1 OVC0lJB Local Control Panel 1 OVCO2CA Control Room HVAC Return Fan 1 OVCO2CB Control Room HVAC Return Fan 1 l 2VP01AA Cnmt Ess'l Service Water Coil 2A (RCFC) 1 2VP01AB Cnat Ess'l Service Water Coil 2B (RCFC) 1 2VP01AC Cnmt Ess'l Service Water Coil 2C (RCFC) 1 ( 2VP01AD Cnmt Ess'l Service Water Coil 2D (RCFC) 1 1 - 2VP01CA Prim. Cnat. Vent System RCFC Fan, Motor 1 l 2VP01CB Prim. Cnmt. Vent System RCFC Fan, Motor 1 2VP01CC Prim. Cnat. Vent System RCFC Fan,. Motor 1 l 2VP01CD Prim. Cnmt. Vent System RCFC Fan, Motor 1 h !O
- See Notes at the end of Table B-2.
l L 27 1 ,-,n,-e-.-,- , - -. -. _ - -... - -,. ~. - - - -.. _. - _. _..
ATTACHMENT B (Cont'd) TABLE B-2 EQUIPMENT ON THE BYRON-1 LIST THAT IS NOT ON THE BYRON-2 LIST REASON WHY EQUIPMENT NOT ON OTHER EQUIPMENT DESCRIPTION NUMBER LIST
- Reg. Hx Line Containment Isolation Valve MOV-lCV-8105-2 6
Reg. Hx Line Containment Isolation Valve MOV-lCV-8106-1 6 Centrifugal Charging Pump Mini-flow Valve MOV-lCV-8110-1 6 Centrifugal Charging Putap Mini-flow valve MOV-lCV-8111-2 6 ('T RHR Hx to Charging Pump - (_) Suction Valve MOV-lCV-8804A 6 Emergency Start Switch for AFW Pump 1B lHS-AF157 4 Junction Box Associated with AFW Pump 1B 1AF0lPB-B 4 Junction Boxes Associated lJB388A 4 with Lube Oil Pumps for AFW Pumps lJB389A 4 Limit Switches Associated LS-lSX173 4 with AFW Pump 1B LS-lSX178 4 Hand Switches Associated lHS-AF119 4 with Lube Oil Pumps for lHS-AF120 4 AFW Pumps Junction Box Associated with AFW Pump 1B Gear Box Lube Oil Pump lJB-2093A 4
- See Notes at the end of Table B-2.
28 1 - - - ~ - +
ATTACHMENT B (Cont'd) f) \\s / TABLE B-2 (Cont'd) REASON WHY NOT ON EQUIPMENT DESCRIPTION EQUIPMENT DESRIPTION LIST Hand Switch Associated with AFW 1B Pump Gear Box Lube Oil Pump lHS-AF152 4 480 Volt ESF Switchgear Bus 131Z - Div. 11 LAP 99E 6 480 Volt MCC 131Z1 - Div. 11 LAP 93E 6 480 volt ESF MCC 131X2B 1AP25E-B 4 480 Volt ESF Switchgear Bus 132Z - Div. 12 1AP98E 6 480 Volt Switchgear Bus 134V - Div. 12 1AP73E 6 O 480 Volt MCC 13222 1AP92E 6 480 Volt MCC 134V3 - Div. 12 1AP43E 6 Interlock Switches for Component Cooling Pumps lLSL-CC072 4 1A and 1B ILSL-CC073 4 Junction Box for DC Feed to Switchgear LAP 73E lJB1921A 4 Circuit Breaker Control Panels 1DG04EA 6 Associated with DG Feeds to 1DG04EB 6 Switchgear Transfer Pump Discharge to 1D0055A 6 Diesel Driven Aux. Feed 1D0055B 6 Pump Day Tank Valves 1D0057 6 valves 1C Diesel Fuel Oil Tank 1D00lTC Unit specific difference O
- See Notes at the end of Table B-2.
29
1 ATTACHMENT B (Cont'd) ,m',) ( TABLE B-2 (Cont'd) REASON WHY NOT ON EQUIPMENT DESCRIPTION EQUIPMENT DESRIPTION LIST 1D Diesel Fuel Oil Tank 1D00lTD Unit specific difference Incore Thermocouple Reference Junction Box 1 - Div. 11 LIT 0lJ 4 Incore Thermocouple Reference Junction Box 2-Div. 12 LIT 02J 4 Steam Generator lPT-MSO41 6 Atmospheric Relief 1PT-MSO42 6 Valve Pressure Switches IPT-MSO43 6 1PT-MSO44 6 Neutron Monitoring 1NR07E 4 Junction Boxes 1NR09E 4 Junction Boxes for Pressurizer lJB381R 4 PORV'S lJB600R 4 [) Junction Boxes for RC Hot and lJB200R 4 Cold Leg RTD's lJB204R 4 lJB206R 4 lJB232R 4 lJB237R 4 lJB241R 4 lJB287R 4 lJB377R 4 Solenoid Valves for N2 Supply 1RYO79A 5 for Pressurizer PORV's 1RYO79B 5 ESW Cooling Tower Fan OA OSX03CA 6 ESW Cooling Tower Fan OB OSXO3CB 6 ESW Cooling Tower Fan OE OSXO3CE 6 ESW Cooling Tower Fan OF OSX03DF 6
- See Notes at the end of Table B-2.
30
ATTACHMENT B (Cont'd) TABLE B-2 (Cont'd) REASON WHY NOT ON EQUIPMENT DESCRIPTION EQUIPMENT DESRIPTION LIST Interlock Switches Associated 1PSL-SX023 4 with SX System-1PSL-SX024 4 1PS-SX140 4 1PS-SX143 4 Limit Switches associated with LS-ISX001A 4 SX system LS-ISX001B 4 LS-lSX016A 4 LS-ISXOl6B 4 LS-ISX027A 4 LS-ISX027B 4 LS-ISX163A 6 LS-ISX163B 6 LS-ISX163E 6 LS-ISX163F 6 O l l I l
- See Notes at the end of Table B-2.
l 31 l
ATTACHMENT B (Cont'd) TABLE B-2 (Cont'd) REASON WHY NOT ON EQUIPMENT DESCRIPTION EQUIPMENT DESRIPTION LIST Junction Boxes Associated lJB-058A 4 with SX System lJB-059A 4 Hand Switches Associated lHS-SX136 4 with SX System lHS-SX137 4 Interlock Switches Associated OZS-VA035A 4 with VA System OZS-VA035B 4 OZS-VA036A 4 OZS-VA036B 4 OZS-VA037A 4 OZS-VA037B 4 OZS-VA038A 4 0ZS-VA038B 4 0FZ-VA035 4 0FZ-VA036 4 0s 0FZ-VA037 4 0FZ-VA038 4 1TS-VA001 4 1TS-VA002 4 1TS-VA003 4 l 1TS-VA004 4 1TS-VA010 4 1TS-VA0ll 4 Limit Switches Associated LS-0 val 2EA 4 with VA System LS-0 val 2EB 4 LS-0VA15EA 4 l LS-0VA15EB 4 LS-0VA16EA 4 LS-0VA16EB 4 LS-0VA19EA 4 i LS-0VA19EB 4 Junction Boxes Associated lJB-491A 4 with VA System lJB-581A 4 lJB-583A 4 lJB-565A 4 lJB-567A 4 O
- See Notes at the end of Table B-2.
32 4
ATTACHMENT B (Cont'd) () TABLE B-2 (Cont'd) REASON WHY NOT ON EQUIPMENT DESCRIPTION EQUIPMENT DESRIPTION LIST Interlock Switch for 1XY-VE001 4 VE System Remote Shutdown Control OVI0lc 6 j Room Fans OVIO2C 6 Local Control Panel OVI0lJ 6 ESW Cooling Tower IVX05C 6 Vent Fans IVXO6C 6 Local Control Panels IVX05J 6 lVX06J 6 Interlock Switches for 1XY-VX001 6 VX System IVY-VX002 6 Panels for VX System IVX98J 6 IVX99J 6 Containment Electrical ILV09E (E27) 4 Penetrations lLV10E (E3) 4 1NR01E (E22) 4 1NR02E (E42) 4 ISI0lE (E45) 4 ISIO2E (Ell) 4 ISIO3E (E44) 4 ISIO4E (E12) 4 ISIO5E (E24) 4 ISIO6E (E35) 4 ISIO7E (E51) 4 ISIO8E (E7) 4 0'
- See Notes at the end of Table B-2.
33
.4 ATTACHMENT B (Cont'd) O s Notes to Tables B-1 and B-2 1. New equipment ad$ed to analysis. Both the control room ventilation l system (VC system).and the containment fan coolers (VP system) are included in the Byron-2 list, but were not analyzed for Byron-l. ' 2. Addition of support components to the Byron-2 list which were explicitly included in the Byron-1 list by virtue of the fact that they are located in the same zone with the primary piece of equipment which they support. In many cases, they are mounted on the-same skid. This is a refinement of the analysis and not a significant change in the philosophy or method of performing the analysis. 3. Addition of major passive components such as heat exchangers, tanks and pressure vessels. These components were in some cases not listed for Byron-l. Components such as these are generally not susceptible to fire damage. 4.- In many cases, specific components which are part of or are related to electrical control and power circuits are deleted. Components such as junction boxes, electrical containment O penetrations, limit switches, etc., are included in this category. Since the cables which these specific components are associated with are explicitly included, deletion of these components is acceptable, and does not affect the results of the analysis. This. is a refinement of the analysis, and does not represent a change.in the philosophy or method of performing the analysis. ~ 5. Equipment added or deleted as a result of design changes since the Byron-1 analysis was completed. 6. Equipment deleted as a result of a reevaluation of its safe shutdown role, and shown to be not required for safe shutdown. ,.? s 34
3 h ATTACHMENT C COMPARISON OF BYRON-1 VS. BYRON-2 APPENDIX R DEVIATIONS SECTION DIFFE RENCE S A.5.8 General: An introduction is provided in the Byron-2 writeup which was not included in the Byron-1 writeup. The introduction was provided to explain that Appendix A.5.8 addresses deviations that will exist during plant operation. This differs from Byron-1 in that certain Byron-1 deviations (e.g., A.16 and A.19) were written which discuss the addition of a 3-hour fire barrier around one division of cables. Once the barrier is added, no deviation exists. Therefore, for Byron-2, instead of writing a deviation to discuss the addition of a fire barrier around cables in a given zone, the addition of the barrier was discussed in Section 2.4. Also, for the Byron-2 auxiliary building deviations (AS.8.1 through A5.8. 24), 1 penetration tabulations for the barriers referred to in the deviations were not included. Tables of redundant cables / equipment presant in the zones discussed were not included since this information is provided in Table 2.4-4. (The deviations reference this table.) In addition,-figures showing exact routings of cables for Byron-2 were not included since review of the text of the deviations in conjunction with the figures in Section 2.3 is sufficient to determine the approximate separation of the cables / equipment involved. For the containment deviations 4 (A5.8.25 through AS.8.32) figures were provided since the cable routings are more difficult to visualize without the aid of figures showing i these routings. Containment azimuth angles are given by "R" designation rather than in degrees. Note also, that, in general, equipment locations for Byron-2 are the " mirror image" of corresponding locations for Byron-l. Thus, in the detailed comparisons that follow many of the deviations are said to be the same for both Byron-1 and Byron-2 due to the " mirror-image" correspondence. 1 4
i ATTACHMENT C (Cont'd) SECTION DIFFERENCES d AS.8.1 Deviation is nearly the same for both Byron-1 and Byron-2. The difference is that the redundant Division 22 cables on El. 346 feet are located near column-rows 19/P-Q for Byron-2 (20-21/L for Byron-1) and are about 17 feet from the nearest unrated floor penetration between the two zones (30 feet for Byron-1). This smaller separation for Byron-2 is acceptable due to the low fire loading and existence of flood seals. AS.8.2 Deviation is nearly the same for both Byron-1 and Byron-2. The difference is that the redundant Division 21 cables on El. 346 feet are located near column-rows 16/L-M for Byron-2 (13-15/Q-S for Byron-1). Also, the separation between the Division 21 cables and the nearest unrated floor penetration between the zones is about 30 feet (40 feet for Byron-1). A5.8.3 Basic deviation is the same for both Byron-1 and Byron-2, however, the justification for the Byron-2 deviation references Section 2.4 instead of deviation A.16 since there is no Byron-2 deviation corresponding to Byron-1 O deviation A.16. Section 2.4 provides the applicable information. Also, cable locations are different from Byron-1 and the Byron-2 l deviation mentions protection of Division 21 cables near 16/L-M on El. 346 feet. i A5.8.4 Deviation is the same for both Byron-1 and Byron-2, except that wording of description of deviation is slightly different regarding non-rated floor openings. Also, the Byron-2 deviation mentions that Division 21 cables will be protected on El. 364 feet as well as on El. 383 feet. AS.8.5 Basic deviation is the same for both Byron-1 and Byron-2. The primary difference is that for Byron-2 redundant cables are not directly above each other on both of the elevations involved. Also the wording of the description of the deviation regarding non-rated floor j openings is slightly different. O l
ATTACHMENT C (Cont'd) SECTION DIFFERENCE S AS.8.6 Deviation for Byron-2 differs from that for Byron-1 in that Byron-2 deviation discusses commitment to protect floor support steel on the Unit 2 side of Fire Zone 11.6-0 bounded approximately by 23-26/M-P. Also, Byron-2 deviation does not discuss sealing of penetration on 426 feet since Division 22 cables are protected on both elevations 401 feet and 426 feet, and sealing is not required. In addition, the wording of the description of deviation regarding non-rated floor openings is slightly different. AS.8.7 Deviation is the same for both Byron-1 and Byron-2, except that the Byron-2 writeup does not include Tables A5.8.7-1 and AS.8.7-2 listing safe shutdown cables within 20 feet of the equipment hatch for elevations 414 feet and 426 feet. A5.8.8 Deviation is the same for both Byron-1 and Byron-2 except the wording of the justification for deviation regarding non-rated wall penetrations is slightly different. A5.8.9 (Byron-1) No writeup for Byron-2 Zone 11.2-0 since one division of redundant cables was protected, as discussed in Byron-2 Section 2.4. AS.8.9 (Byron-2)/ Deviation is the same for both Byron-1 and A5.8.10 (Byron-1) Byron-2 except that the wording of the Byron-2 description and justification for deviation I regarding non-rated walls and penetrations are slightly different. Also, Byron-2 writeup discusses protection of both trays and conduits in Zone 11.3-2. AS.8.10 (Byron-2)/ Deviation is the same for both Byron-1 and A5.8.11 (Byron-1) Byron-2 except the separation between redundant cables / equipment for Eyron-2 is greater than 35 feet rather than 45 feet. Also, description of cables / equipment involved is more specific for Byron-2, and wording of description and justification for deviation are slightly different regarding non-rated walls and penetrations. In addition, Byron-2 writeup discusses protection of both trays and conduits in Zone 11.3-2. O
ATTACHMENT C (Cont'd) SECTION DIFFE RENCE S AS.8.ll (Byron-2) This is a new deviation for Byron-2 and does not appear in Byron-1 Appendix A5.8. The deviation involves Zones ll.3D-2 and 11.3-0. The justification for the deviation is similar to other auxiliary building deviations in that the redundant cables / equipment are separated by a wall of 3-hour construction and also separated by a large distance. No plant modifications are required. AS.8.12 Deviation is the same for both Byron-1 and Byron-2, except that the separation between redundant cables / equipment for Byron-2 is greater than 75 feet rather than 85 feet. 4 Also, wording of description and justification for deviation are slightly different regarding non-rated penetration. In addition, the Byron-2 writeup discusses protection of both trays and conduits in Zone 11.3-2. A5.8.13 Deviation is the same for both Byron-1 and Byron-2, except that the separation between redundant cables / equipment for Byron-2 is greater than 30 feet rather than 45 feet. {)g Also, the combustible loading fgr Byron-2 Zone x_ 11.3-2 is given as 9,800 Btu /f t. (The combustible loading giveg in the Byron-1 writeup is 17,400 Btu /ft however, this value ,2 is revised to 9,900 Btu /ft in Amendment 8.) In addition, protection of both trays and conduits are discussed for Byron-2. AS.8.14 Deviation is the same for both Byron-1 and Byron-2, except that wording of description of deviation regarding non-rated wall is slightly different. Also, in the Byron-2 justification for deviation it is stated that " penetrations," rather than "two small openings," will be sealed along row Q. A5.8.15 Deviation is the same for both Byron-1 and l Byron-2. This deviation discusses a modification provided on Byron-1 which applies to Byron-2. Thus, no additional modifications are required for Byron-2 regarding the components involved. 1 l l l
ATTACHMENT C (Cont'd) SECTION DIFFE RENCE S -O-A5.8.16 (Byron-1) No corresponding Byron-2 deviation for Zone 11.3-0 since one division of cables will be protected with a 3-hour barrier, and therefore, no deviation will exist. A5.8.17 (Byron-1) No corresponding Byron-2 deviation for Zone 11.4-0 since one division of cables will be protected with a 3-hour barrier, and therefore, no deviation will exist. AS.8.16 (Byron-2)/ Deviation is the same for both Byron-1 and AS.8.18 (Byron-1) Byron-2. A5.8.19 (Byron-1) No corresponding Byron-2 deviation for Zone 11.5-0 since one division of cables was protected with a 3-hour barrier, and therefore, no deviation will exist. A5.8.17 (Byron-2)/ Deviation is the same for both Byron-1 and AS.8.20 (Byron-1) Byron-2, except wording of justification of deviation is slightly different regarding non-rated walls. AS.8.18 (Byron-2)/ Deviation is the same for both Byron-1 and AS.8.21 (Byron-1) Byron-2. A5.8.22 (Byron-1) No corresponding Byron-2 deviation for Zone 11.6-0 since one division of cables was protected with a 3-hour barrier, and therefore, no deviation will exist. A5.8.19 (Byron-2)/ The basic difference between the Byron-1 and AS.8.23 (Byron-1) Byron-2 deviations is that for Byron-2 cables 20C001, 2DC002, and 2DC003 were'not included as purt of the deviation. These cables are to be wrapped with a 1-hour barrier (CO2 suppression is also present), and therefore, no deviation will exist. The remaining part of the deviation regarding cables 2DC021 and 2DC023 is the same, except that the separation for Byron-2 is given as more than 50 feet rather than 30 to 35 feet. AS.8.20 (Byron-2)/ Deviation is the same for both Byron-1 and A5.8.24 (Byron-1) Byron-2. l A5.8.21 (Byron-2)/ Deviation is the same for both Byron-1 and l A5.8.25 (Byron-1) Byron-2. .O s ,...-,,n,- ,.,..wn,-- ,-_..,-.,-..--.-,.,-n,n ~-,-nn.,_,,,n n-,.n,--.- .n.
ATTACHMENT C (Cont'd) SECTION DIFFERENCES A5.8.22 (Byron-2)/ Deviation is the same for both Byron-1 and AS.8.26 (Byron-1) Byron-2. (Note that Byron-1 deviation has been corrected in Amendment 8 to indicate there is no ionization detection on El. 475 feet 6 inches.) AS.8.23 (Byron-2)/ Deviation is the same for both Byron-1 and A5.8.27 (Byron-1) Byron-2. A5.8.24 (Byron-2)/ Deviation is the same for both Byron-1 and A5.8.35 (Byron-1) Byron-2. AS.8.25 (Byron-2)/ Deviation is the same for both Byron-1 and A5.8.28 (Byron-1) Byron-2 except that cable routings and separations are slightly different and the PORV control cables are to be routed in conduit for Byron-2. A5.8.26 (Byron-2)/ Deviation is the same for both Byron-1 and A5.8.29 (Byron-1) Byron-2 except the minimum vertical cable separation is about 15 feet and the horizontal separation is about 60 feet for Byron-2 (17 and 65 for Byron-1, respectively). Routing elevations are also somewhat different. AS.8.27 (Byron-2)/ Deviation is basically the same for both AS.8.30 (Byron-1) Byron-1 and Byron-2. Although the Byron-2 deviation lists three cables for each source range detector instead of one, the routings are nearly the same as for Byron-l. 4 i A5.8.28 (Byron-2)/ Deviation is the same for both Byron-1 and AS.8.31 (Byron-1) Byron-2, except cable separations are slightly different. Routing elevations are also somewhat different. AS.8.29 (Byron-2)/ Deviation is the same for both Byron-1 and A5.8.32 (Byron-1) Byron-2, except vertical cable separation and routing elevation are slightly different. A5.8.30 (Byron-2)/ Deviation is basically the same for both j l AS.8.33 (Byron-1) Byron-1 and Byron-2. The main difference is that the Byron-2 deviation addresses the as-built configuration of the dual element RTD cables. Cable separations and routing elevations are also slightly different. In addition, a figure is provided with the Byron-2 deviation which was not provided for Byron-l. i /~'i , G - ~..
ATTACHMENT C (Cont'd) SECTION DIFEE RENCE S O A5.8.31 (Byron-2)/ This Byron-2 deviation is different from the A5.8.34 (Byron-1) Byron-1 deviation in that the Byron-2 deviation addresses the as-built configuration of the dual element RTD cables. Cable separation is different and a figure is provided for the Byron-2 deviation. The justification for deviation also differs for the following reason: At Byron-1 a commitment was made to route cables for the new dual element cold leg RTD's so that all indication would not be lost after a fire in this zone. This modification proved to be not feasible for both Byron and Braidwood. Therefore, the Byron-2 justification for the deviation describes an acceptable means of verifying primary system conditions in the event that all cold leg RTD indication is lost. i A5.8.32 (Byron-2) This is a new deviation for Byron-2 and does not appear in Byron-1 Appendix A5.8. The deviation addresses RCFC high-speed cables routed in containment. No plant modifications are required. l 6 l 7 i -}}