ML17146B006

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: ML17146B006 ML17146B009 ML17146B010 ML18040A852
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*R I ZED: 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 AFF IL'I*TI ON 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 f ire 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 t s. 05000387 1cg NMSS/FCAF/PM. LPDR 2c g s Tran s c r i p t s. 05000388 RECIPIENT COPIES REC IP IENT COP IEB ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-2 LA 1 0 PD1-2 PD 5 5 THADANIiM 1 1 INTERNAL: ACRS 3 3 ARM/DAF/LFMB 1 0 NRR WERMEILi J 1 0 NRR/DEST/ADS 1 1 NRR/D PSB 1 1 OGC/HDB2 1 0 ~

IL 01 1 EXTERNAL: LPDR 2 2 NRC PDR NBIC 1 1 NOTES:

TOTAL NUMBER OF COPIES REGUIRFD: LTTR 23 ENCL 19

Cy k P

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 C:3 Attn.: Dr. W. R. Butler, Project Director Project Directorate I-2 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, D.C. 20555 SUSQUEHANNA STEAM ELECTRIC STATION REVISION TO APPENDIX R DEVIATION REQUEST NO. 3 Docket Nos. 50-387 PLA-2917 FILE A17-15 and 50-388

Dear Dr. Butler:

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 following

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.

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, pDR,,"ADOCN, o, F0387 l pDR LI 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

J II 4

J J

'I I',, P I

I J

'I P

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 UNIT DOOR DOOR FM FIRE ZONES NUMBER NUMBER TYPE REPORT 1-1A/1-1B 13 1/85 1-1E/1-1F 23 8/87 1-2A/1-2B 8/85 1-3A/1-3B-N 201 8/85 1-4A-S/1-4G 407 6/86 1-5A-W/1-5E 515 8/85 1-5B/1-5A-N 531* 5/87 2-1A/2-1B 8/87 2-lE/2-1F 24 8/87 2-1I/2-6A 115-R 5/87 2-2A/2-2B 112 6/86 2-3A/2-3B-N 202 6/86 2-4A-S/2-4G 408 5/87 2-5E/2-5A-W 514 6/86 2-5A/2-5B 530 6/86 2-4G/2-6A 711 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