ML19332D131
| ML19332D131 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/22/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1735, GL-86-10, NUDOCS 8911300053 | |
| Download: ML19332D131 (3) | |
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. TOLEDO 1
EDISON i
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DONALD C. SHELTON -
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!DocketNumber 5013461
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License Number NPF-3 SerialiNumber 1735 November ~.22, 1989 i
- a-United States Nuclear' Regulatory Commission
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' Subjects Fire Protecti' n -~ Protection of Equipment Against the Ef fects of o
Inadvertent Fire Suppression System Actuation 4
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- Gentlement'
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- October l 31, 1989,- a conference-call was held between staff members of Toledo ; Edison-and the:NRC's = Senior Project Manager and Lead Fire Protection p
reviewer for the Davis-Besse NuclearLPower Station.
The purpose.of the call L
' was; to. discuss protection-of equipment from the ef fects of inadvertent fire s
suppression system actuations. This letter documents that conference call
-including Toledo. Edison's basis, for and approach to this subject and the Company's understanding that the NRC concurs that the approach is acceptable 1
vith respect.to present NRC regulatory requirements and staff guidance.
j Background' e
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During a' recent' internal Quality Assurance audit of Davis-Besse fire protection' program activities, it became apparent that the docketed material describing the approach taken and commitments made at Davis-Besse to protect
-plant equipment'against the effects of inadvertent fire suppression actuation i
- cani be' interpreted several different ways. Toledo Edison plans to revise the USAR and FHAR to clarify the approach taken and commitments made with respect'
'1 toothis issue.
Position Toledo-Edison's design approach for suppression system additions and modifications is to demonstrate that at least one train of redundant Appendix.
-R' safe shutdown equipment will be maintained free of damage from the effects of inadvertent or fire induced suppression system actuation.
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THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 1-
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, 4,A. Dock 3t Nu2b;r 50-346
. License: Number NPF-3' Serial Number 1735
- Page 2 Justification The position'and approach stated above is consistent with 10CFR50, Appendix R Section III.G separation requirements, the NRC staff definition of fire damage,'and1the more general requirements in the General Design' Criteria (GDC).
l Section III.G.1(s) of 10CFR50' Appendix R; states in parts v
One train of systems necessary'to achieve and maintain hot shutdown conditions from either the control room or emergency control station (s) is free of fire damage.....
The-NRC has further clarified the meaning of fire damage as used in Appendix R
'in Generic Letter'86-10, Enclosure 1, paragraph 3 as follows:
The term " damage by fire" also includes damage to equipment.
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from the normal or inadvertent operation'of fire suppression j
- systems.
J Appendix R'to 10CFR50 has been identified in 10CFR50.48 paragraph (b) as a means of interpreting and implementing GDC 3, Fire Protection.
In evaluating postulated suppression system damage to Appendix R equipment to demonstrate meeting the regulatory requirements, Toledo Edison evaluates various damage mechanisms such as flooding and exposure to spray. Also,,as stated in Toledo Edison's FHAR Table 4-1, where deemed necessary to prevent 1
~ damage to safety-related systems, portions of piping systems are seismically
- supported.
.NRC Concurrence l
The NRC stated that they are in agreement with the basis and focus of Toledo Edison's position as stated, that it is consistent with the present NRC i
regulations and staff guidance, and that no additional requirements are necessary..
Implementation Toledo Edison plans to update the USAR and FHAR during normally planned document updates to reflect the approach above for protecting equipment against the effects of inadvertent fire suppression system actuations.
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' License Number,NPP-3=
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l, IfLyou have'any. questions,concerning.this r.atter, please contact
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' Mr. R.'.V. Schrauder, Nuclear' Licensing Manager at (419) 249-2366.'
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> ces: cP. M.: Byron,DB-1 NRC Senior. Resident Inspector A. B. Davis,LRegional Administrator,,NRC Region III:
D;'J.LKubickie',NRC/NRR Staff Reviewer 1 r,
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-T. V.;Vambach,.DB-1 NRC Senior Project Manager-3 m,
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