PLA-2917, Forwards Rev to App R Deviation Request 3, Fire Doors - Nonrated, in Response to Enforcement Action 85-112.Encl Rev Addresses Water Tight Doors in Fire Barriers Separating Listed Fire Zones
| ML17146B006 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/21/1987 |
| From: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| To: | Butler W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17146B007 | List: |
| References | |
| EA-85-112, PLA-2917, NUDOCS 8710230342 | |
| Download: ML17146B006 (8) | |
Text
REGULA Y INFORMATION DISTRIBUTI YSTEM (RIDB)
F ACC:ESSI ON NOR: 8710230342 DOC. DATE: 87/10/21 NOT*RIZED:
NO DOCKET FACIL: 50-387 Susquehanna Steam Electric Stationi Unit ii Pennsglva 05000387 50-388 Susquehanna Steam Electric Stationi Unit 2i Pennsglva 05000388 AUTH. NAME AUTHOR AFFIL'I*TION KEISER! H. W.
Pennsylvania Poujer h Light Co.
RECIP. NAME RECIPIENT AFFILIATION BUTLER'S W. R.
Pro gee t Directorate I-2
SUBJECT:
Forwards rev to App R Deviation Request 3I "Fire Doors Non-Ratedi " in response to Enforcement Action 85-112. Encl rev addresses eater tight doors in fire barriers separating listed fire zones.
DISTRIBUTION CODE:
A0060 COPIEE RECEIVED: LTR I
ENCL t
SIZE:
TITLE: OR/Licensing Submittal: Fire Protection NOTES: 1 c g NMSS/FCAF/PM.
LP DR 2c g s Tran s cr i p ts.
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05000387 05000388 RECIPIENT ID CODE/NAME PD1-2 LA THADANIiM INTERNAL: ACRS NRR WERMEILiJ NRR/D PSB IL 01 COPIES LTTR ENCL 1
0 1
1 3
3 1
0 1
1 1
REC IP IENT ID CODE/NAME PD1-2 PD ARM/DAF/LFMB NRR/DEST/ADS OGC/HDB2 COP IEB LTTR ENCL 5
5 1
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EXTERNAL:
LPDR NBIC 2
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1 NRC PDR NOTES:
TOTAL NUMBER OF COPIES REGUIRFD:
LTTR 23 ENCL 19
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Pennsylvania Power 8 Light Company Two North Ninth Street
~ Allentown, PA 18101
~ 215 l 770-5151 Harold W. Keiser Vice President-Nuclear Operations 21 5/770-7502 OCT 21
$967 Director of Nuclear Reactor Regulation Attn.:
Dr.
W. R. Butler, Project Director Project Directorate I-2 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, D.C.
20555 C:3 SUSQUEHANNA STEAM ELECTRIC STATION REVISION TO APPENDIX R DEVIATION REQUEST NO.
3 PLA-2917 FILE A17-15 Docket Nos.
50-387 and 50-388
Dear Dr. Butler:
g 1)
On page 1 of the Deviation Request, the type II door's fire resistance rating was changed to state ".
. at least lj hours
.." so as to be consistent with the wording for the other door types.
In our response to Enforcement Action 85-112 (PLA-2887, dated 7/15/87),
we committed to provide a revised Appendix R Deviation Request No. 3, "Fire Doors Non-Rated", prior to start up following Susquehanna SES Unit 1 third refueling and inspection outage.
Attached is the revision to the deviation request which addresses the water tight doors in the fire barriers separating Fire Zones 1-lE and 1-1F in Unit 1 and Fir'e Zones 2-1E and 2-1F in Unit 2.
Also please note the followin 2)
All the Factory Mutual recommended modifications to the doors in the deviation request are complete except for Door //531.
The modifications to this door have been entered in our plant work authorization system and should be completed in the near future.
3)
In Supplement 3, dated May 1987, to the Evaluation of Selected Fire Door and Door Frame Assemblies
- Report, Door f/115 has been corrected to be Door
//115-R.
This error was an oversite when the report was being prepared.
If you have any questions, please contact us.
Very truly yours, F0387 pDR,,"ADOCN, o, pDR LI l
H.
W. Keiser Vice President-Nuclear Operations cc:CNRC Document Control -Desk (original)- "
NRC Region I Mr. L. R. Plisco, NRC Resident Inspector Mr. M. C. Thadani, NRC Project Manager
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8
DEVIATION RE(VEST NO.
3 REVISED SEPTEMBER 1987 PAGE 1 of 3 APPENDIX R
DEVIATION RE UEST FIRE DOORS - NON-RATED DEVIATION RE VEST:
F Existing unlabeled,
- untested, doors are acceptable for use as fire doors based on confirmation by Factory Mutual that the doors are of sufficient construction to provide equal or better fire resistance to that of a rated fire door.
Existing watertight doors whi'ch have not been fire tested are acceptable as 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> fire doors based on Factory Mutual's evaluation of these doors.
FIRE ZONES AFFECTED:
For the effected fire zones see Table 3-1.
REASON FOR DEVIATION RE VEST:
Various fire barriers within the Unit 1 and 2 Reactor Buildings have been identified as requiring 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating to meet the requirements of Appendix R.
Existing doors within these barriers are not fire rated (see Table 3-1 for a listing of these doors).
JUSTIFICATION:
There are three types of doors within the Reactor Buildings.
Factory Mutual has reviewed each door type, and door within that type, and compared them to either known data or an existing fire rated door at Susquehanna.
Water Tight Doors (Type I)
Factory Mutual in their January 1985 and August 1987 Reports concluded that these special purpose (flood) doors would be expected to provide at least 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of fire resistance (see Attachments 1
and 5).
Pressure Resistance Doors (Type II)
Factory Mutual in their August 1985 and June 1986 Reports compared various non-labeled pressure resistant doors, with pressure resistant door number 279 which is an Underwriter's Laboratories labeled 3-hour fire door.
Factory Mutual concluded that the doors would be expected to provide at least 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of fire resistance (see Attachments 2
and 3).
c DEVIATION REQUEST NO.
3 REVISED SEPTEMBER 1987 PAGE 2 of 3 Hollow Steel Doors (Type III)
Factory Mutual in their August 1985 and June 1986 Reports compared various non-labeled hollow metal doors with hollow metal door number 421 which is an Underwriter's Laboratories labeled 3-hour fire door.
Factory Mutual concluded that the doors should be expected to provide at least lk hours of fire resistance.
In their May 1987 Report (see Attachment 4), Factory Mutual compared various non-.labeled hollow metal doors with hollow metal door number 115-R which is an Underwriter's Laboratories labled lk hour fire door.
Factory Mutual concluded that these doors should be expected to provide at least lk hours of fire resistance.
The combustible loading in the Reactor Buildings have been conservatively estimated and a 15-minute allowance for transient has been provided.
'Ihe present calculated average combustible loading in each Reactor Building,.'".
Fire Zone is less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Changes in these combustible loadings-are expected over the plant life time.
This Deviation Request is valid so long as:
o The calculated maximum average combustible loading in the fire zones adjacent to these fire barriers is below the minimum rating of the door.
o The concentrated combustible loading adjacent to these fire barriers is calculated to be below the minimum fire rating of the door.
dk/g026i:mg
DEVIATION REQUEST NO.
3 REVISED SEPTEMBER 1987
'PAGE 3 of 3 DEVIATION RE UEST NO.
3 FIRE DOORS - NON-RATED TABLE 3-1 WALL BETWEEN FIRE ZONES 1-1A/1-1B 1-1E/1-1F 1-2A/1-2B 1-3A/1-3B-N 1-4A-S/1-4G 1-5A-W/1-5E 1-5B/1-5A-N 2-1A/2-1B 2-lE/2-1F 2-1I/2-6A 2-2A/2-2B 2-3A/2-3B-N 2-4A-S/2-4G 2-5E/2-5A-W 2-5A/2-5B 2-4G/2-6A UNIT NUMBER DOOR NUMBER 13 23 201 407 515 531*
24 115-R 112 202 408 514 530 711 DOOR TYPE FM REPORT 1/85 8/87 8/85 8/85 6/86 8/85 5/87 8/87 8/87 5/87 6/86 6/86 5/87 6/86 6/86 6/86
- This door was inadvertently numbered as door 504 in PLA-2762.
The correct door number is 531.
dk/g026i:mg
,C SUSQUEHANNA STEAM ELECTRIC STATION - UNITS 1 5 2
PIRE PROTECTION PROGRAM - CONCERN 81 DOCKETS NO. 50-381 50-388 APPENDIX A - EXEMPTION REQUESTS EXEMPTION REQUEST NO ~
3 ATTACHMENT 1