ML20012E020
| ML20012E020 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/22/1990 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | |
| Shared Package | |
| ML20012E019 | List: |
| References | |
| NUDOCS 9003290221 | |
| Download: ML20012E020 (14) | |
Text
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- Docket Number 50-346 o
Licens: Number NPF-3 ,
l- - Serial Number 1788 . . i
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Enclosure i Fage 1 1 I ,
4 APPLICATION FOR AMENDMENT TO i FACILITY OPERATING LICENSE NUMBER NPF-3 DAVIS-BESSE NUCLEAR POWER STATION F UNIT NUMBER 1 !
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Attached are requested changes to the Davis-Besse Nuclear Power Station, Unit .
Number 1 Facility Operating License Number NPF-3 Also included is the Safety Assessment and Significant Hazards Consideration, j j
The proposed changes (submitted under cover letter Serial Number 1788) concern License Condition 2.C(4). ,
For: D. C. Shelton Vice President Nuclear By: / h T. J M rs, Technical Services Director j
Svorn and subscribed before me this 22nd day of March 1990.
r otary Public, State of Ohio (My Commission Expires June 30, 1992)
JUDITH H1RSCH Notary Public State of Ohio My Commioobn Es it s t ne
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.9003290221 900322 - i PDR ADOCK 03000346
.P PDC
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Lic;ns] Nu;b;r NPF-3 Serial Number 1788 . .
Enclosure;
' 'Page 2 The:following information is provided to support issuance of the requested
-changes to the Davis-Besse Nuclear Power Station, Unit Number 1 Operating License Number NPF-3, License Condition-2.C(4).
-A. Time Required to Implement: This change is to be implemented prior to power ascension following the sixth refueling outage.
'B. Reason for; Change'(License Amendment Request Number 90-0012).
Subsequent to the issue of the License Amendment Number 18 SER, alternate.
methods of compliance have been identified by Toledo Edison, and in other cases, analyses or code compliance reviews have been performed to demonstrate the acceptability of the original configuration.- These p alternative methods of compliance and analyses / reviews are the bases for L the proposed revision to. License Condition 2.C(4).
C. Safety Assessment and Significant Hazards Consideration: See attached Safety Assessment and Significant Hazards Consideration (Attachment 1).-
D. Proposed change to License Condition 2.C(4) and proposed changes to Fire Protection Safety Evaluation Report (dated July 26, 1979) (Attachment 2).
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SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION' L FOR LICENSE AMENDMENT REQUEST NO. 90-0012 l r
TITLE:'
Proposed Revision to License Condition 2.C(4).
DESCRIPTION: ,
. License Condition 2.C(4) was issued on July 26, 1979-(Log No. 402) as'part of License Amendment 18. License condition 2.C(4) refers to Table 1 of the NRC Safety Evaluation Report (SER) which required completion of numerous fire -
protection modifications. This License Condition-was subsequently amended on-April 22, 1980 (Log No. 546) as part of License Amendment 24. . In its present form, changes to the SER require a License Amendment to incorporate them-into the License.
Subsequent to the initial SER issuance, analyses demonstrating acceptability of alternate methods of compliance have been performed. These analyses or '
alternate methods of compliance are the bases for the proposed revisions to License Condition 2.C(4) to reflect the actual configuration and/or the latest analysis. The proposed change to License Condition 2.C(4) and proposed changes to the NRC. Fire Protection Safety Evaluation Report (dated July 26, 1979).are attached.
SYSTEMS, COMPONENTS, AND ACTIVITIES AFFECTED:
Emergency _ Lighting ~
L -Fire. Suppression-Sprinkler System
-Fire Barriers <
Fire Detection System Fire Extinguishers
" Fire Doors Fire Proofing I SAFETY FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS, AND ACTIVITIES:
l' The systems affected are fire extinguishers, fire doors, fire barriers,. fire proofing, fire detection, fire suppression and emergency lighting. These systems are not nuclear safety related. These systems provide detection and .
suppression of postulated fires, prevent fire propagation to other areas, and
' provide battery backed emergency lighting in case of normal lighting loss.
The affected systems and components are discussed individually in the following section. Modifications that are described have been or vill be addressed by.the safety evaluation prepared for that modification.
EFFECTS ON SAFETY:
The.following discussions are presented in the order of appearance in the License' Amendment 18 SER Table 1. The numbering corresponds to the item numbers from Toledo Edison letter dated February 16, 1990 (Serial 1757)
Attachment 3. The Fire Hazards Analysis Report (FHAR) and the Compliance
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_ Dock,t:Nunbte 50-346 Lic nsa Nu::bar NPF-3 Serial Number 1788
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Attachment:
1 Page 2 Assessment Report (CARP), as referenced herein, are Revision 11 and' Revision 5, respectively. These revisions were provided to the NRC in a letter dated December 18, 1989 (Serial No. 1746).
- 1. The SER required additional hand-held portable fire extinguishers to be provided in the No. 3 Mechanical Penetration Room (Room 303). The proposed revision states that one hand-held dry chemical portable fire _
erthguisher in Room 303 is sufficient. FHAR Section 5 for Fire Area DE
$ oom 303) and FHAR Appendix 2 describes the manual suppression capabilities in Room 303 as one dry chemical, portable fire extinguisher-and a hose aiction located in the room. This FHAR section further *
< describes addithcal a nual suppression capabilities available from adjacent areas. Additionally, Toledo Edison has performed a National Fire Protection Association (NFPA) 10, " Standard for Portable Fire a Extinguishers", review for Room 303. The review considered the size of the i room, the type and size of the existing hand-held portable fire ;
extinguisher, the type of combustibles present, and the fire loading in the room. The review determined that the currently installed extinguisher in this room is sufficient. Thus the proposed revision, which reflects existing plant configuration, has been evaluated and it has been concluded that there is no adverse impact on the manual suppression capabilities needed-in Room 303.
- 2. The SER required additional hand-held portable fire extinguishers to be '
added in the Maintenance Room (Room 320). The proposed revision states that.one hand-held dry chemical portable fire extinguisher in Room 320 is sufficient. FHAR Section 5 for Fire Area N (Room 320) and FHAR Appendix 2 describes the manual suppression capabilities in Room 320 as one dry <
chemical, portable fire extinguisher and a hose line from an adjacent hose station. This FHAR section also describes additional manual suppression capabilities available from adjacent areas 4 Additionally, a NFPA 10 Standard review was performed for Room 320. The review considered the
/ size of the room, the type and size of the existing hand held portable fire extinguisher, the type of combustibles present, and the fire loading in the room. The review determined the currently installed extinguisher
- is sufficient. Thus the proposed revisjon, which reflects the existing plant configuration, has been evaluated and it has been concluded that there is no adverse impact on the manual suppression capabilities available for Room 320.
3&4 The SER requirement was to install vet pipe sprinkler systems equipped with quick response type sprinklers in ten different fire areas. The original installation was completed and included special " fast acting h sprinkler heads" in the Service Vater System Pump Intake Structure based on the specific conditions in that room. The sprinkler systems were evaluated for compliance with NFPA-13, " Standard for the Installation of Sprinkler Systems" and the sprinkler systems, except for Service Vater Valve Room 53, are being upgraded to resolve the code deficiencies as identified in the Toledo Edison letter to the NRC, dated May 23, 1988 (Serial No. 1497). The method of Appendix R compliance in Room 53 has
..- Dockst Nu;bst 50-346- >
>c Lic:nsa Nu;ber NPF-3 Serial Number 1788 - .
Attachment 1 4 Page~3 been reaevaluated and it has been determined that an acceptable method of Appendix R compliance for Room 53 is to provide a three hour fire bartier-vithout-requiring the sprinkler system. The Appendix R and Appendix A sprinkler systems vill be upgraded prior to power ascension following the sixth and seventh refueling outages, respectively. This is the schedule as stated in the Toledo Edison letter to the NRC dated, December 2, 1988 (Serial No. 1595). The quick response type sprinklers and'the special
" fast acting sprinklers heads" vill be replaced with sprinklers which comply with NFPA-13 requirements. The proposed revision except for Room 53 reflects upgrades to correct NFPA-13 Code deviations and results in upgraded systems that provide equivalent or improved suppression capabilities. The deletion of the Room 53 Sprinkler System has been analyzed for compliance and an equivalent method of Appendix R compliance is provided with the three hour barrier on the circuits for Service Water Pumps 1 and 3 vithout area suppression.
- 5. The SER requirement was to install a vet pipe sprinkler system equipped with thermal actuated type water spray nozzles in the Cable Spreading-Room. The original installation was completed. The sprinkler system was evaluated for compliance with NFPA-13 " Standard for the Installation of Sprinkler Systems" and the sprinkler system is being upgraded to resolve the code deficiencies as identified in the Toledo Edison letter to the NRC dated May 23, 1988 (Serial No. 1497). The upgrade vill be completed prior to power ascension from the sixth refueling outage as. stated in the Toledo Edison letter to the NRC dated December 2, 1988 (Serial No. 1595). The thermal actuated type water spray nozzles vill be replaced with sprinklers which comply with NFPA-13 requirements. The proposed revision reflects upgrades to correct NFPA-13 code deviations and results in an upgraded 1 system that provides an equivalent or improved suppression capability.
- 6. The SER requirement was for Door 508 to have a 1% hour fire rating since it was 'part of the fire rated boundary for the Control Room Complex. The original requirement was satisfied. The proposed change deletes the requirement for Door 508 to have a 1% hour fire rating. FHAR Section 5 for Fire Area FF (i.e., Control Room Complex Fire Area) was revised to redefine the fire rated boundary such that the vall containing Door 508 is no longer part of the Control Room Complex fire boundary. Thus, Door 508
-does not require a 1% hour fire rating. The proposed revision reflecting the revised boundary is described in the FHAR and it has been concluded that there is no adverse impact on providing the required fire boundary for the Control Room Complex.
- 7. The SER requirement was to apply a spray-on type fire proofing on the supports for four horizontal cable trays penetrating ini. 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier at. column line 0-F on elevation 602'0". In lieu of using a spray-on fire proofing, additional sprinklers have been installed to protect the supports and to prevent the potential assrelated degradation of the fire barrier between the Turbine Building anr' the Cable Spreading Room. It is noted that the location of the cable tray supports at column line 0-F and 602'-0" was incorrectly identified in the SER. The correct
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Serial-Number 1788
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n location is 9-F and 603'-0". -The cdditional sprinklers provide adequate cooling to ensure the integrity of the cable tray supports in the event of a fire in_the area. The' additional sprinklers were installed in accordance with NFPA 13 requirements to assure that the associated fire barrier vill not be breached.
- 8. The SERLrequirement was to apply a spray-on fire proofing on the supporting structural steel in mechanical and electrical penetration rooms (Rooms 208, 236, 303, 314, 402, and 427). In lieu of using a spray-on fire proofing, sprinklers have been installed in these~ rooms (see FHAR .
1 Sections 15.DB (Room 236), 5.DC (Room 208), 5.DE (Room 303), 5.DF (Room 427), and 5.DG (Room 402)). In response to Revision 6 of the FHAR submitted by Toledo Edison letter dated May 15, 1980 (Serial No. 617),
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the NRC accepted the use of the sprinklers in lieu of a spray-on fire proofing. This acceptance was documented in an NRC letter to Toledo Edison dated July 17, 1980. Although FHAR Revision 6 provides justification for use of suppression systems as the means of protectinC against an exposure fire for each of the rooms listed above, the July 17, 1980 NRC letter did not include Room 314 in the list of those rooms for which structural steel fireproofing was not required. The proposed change
" reflects the use of sprinklers to protect the supporting structural steel in Rooms 208, 236, 303, 314, 402 and 427. These systems vill be upgraded to satisfy NFPA-13 requirements and these upgrades vill be completed prior to power ascension from the sixth refueling outage as stated in the Toledo Edison letter to the NRC dated December 2, 1988 (Serial No. 1595). Thus, the proposed revision provides adequate assurance that the supporting structural steel capabilities vill not be compromised.
- 9. The SER requirement was to apply a spray-on fire proofing on the supporting structural steel in the turbine building as determined by the turbine building thermal expansion analysis. The proposed revision provides an-equivalent level of structural steel fire protection using sprinklers.
Toledo Edison concluded that sprinklers vould provide an acceptable means o of controlling a postulated-fire and therefore reduce the potential for fire damage. This approach was provided to the NRC by a February 28, 1979, letter (Serial No. 486) containing revision 5 to the FHAR but this approach was not reflected in the SER. Sprinklers were either added or f previously existed in Turbine Building Heater Bays (FSA-3501, 4501, 5501, 6501, 7501), Turbine Build!ng Heater Bay Roof Truss (FSA-7502), Turbine Building Basement, Mezzanine and Operating Floor (FSA-4105), Turbine Building Roof Train Bay (FSA-5106) and Turbine Building Meteorological Laboratory (Het Lab) (FSA-5731) to provide fire protection and to prevent heating of portions of the structural supporting steel in the Turbine Building. The proposed change requires sprinklers in the Turbine Building Heater Bays (FSA-3501, 4501, 5501, 6501 and 7501), and the Turbine Building Basement, Mezzanine, and Operating Floor (FSA-4105). The proposed revision does not require either sprinklers or spray-on I fireproofing in the Turbine Building Roof Train Bay (FSA-5106), Turbine l Building Het Lab (FSA-5731) and Turbine Building Heater Bay Roof Truss (FSA-7502). The required systems vill be upgraded to satisfy NFPA-13
a Dockit'Nu:ber 50-346 Lic nsa Nu;ber NPF-3
' Serial Number 1788
- Attachment l' i g, Page 5 requirements'and these upgrades vill be completed prior to power' ascension.
from the sixth refueling outage as stated in the Toledo Edison letter to the NRC dated. December 2, 1988 (Serial No. 1595). Based on a' review of '
the required fire protection, Toledo Edison has concluded that' these three suppression . systems are not required since they do not. contribute to the .
protection of structural steel as described below:
- a. Turbine Building Roof Train Bay ,
The sprinklers in the Turbine Building Roof Train Bay are at the j 692 ft. elevation and provide coverage for 2400 sq. ft. of the 1 Railroad Bay which is at the 585 ft. elevation. The Train Bay is ,
in the northeast corner of the Turbine Building and two Valls of the Train Bay are exterior valls with the remainder open_to the :'
Turbine Building Operating Floor (elevation 623 ft.). Due to the
- open construction of the Train Bay and the height of the Turbine Building roof over the Train Bay, the sprinklers provide very e limited fire suppression capability. The sprinkler system protects the roof steel'and does not protect the Turbine Building structural
-steel. Thus the proposed revision does not alter the conclusion that thermal expansion in.the Turbine Building is limited to an acceptable level. _;
- b. Turbine Building Heteorological Laboratory (Met Lab)
The Met-Lab includes a calibration lab and' fire brigade locker room that is constructed at the 623 ft. elevation on the Turbine Building Operatwg Floor and is approximately 10 f t. in height.
Originally the art.a was a lunch room and an instrumentation and control shop, but has been converted to a calibration lab and fire brigade-locker-room with a significant reduction in the combustible loading. The minor amount of combustibles contained in this small enclosure on the Turbine Building Operating Floor vould not produce enough heat to cause unacceptable expansion of the supporting structural steel members considering the large volume and area of L the Turbine Operating floor and the installed smoke and heat vents I.
in the Turbine Building ceiling. The proposed change deletes the sprinkler system in the Met Lab as part of the requirement for protecting structural supporting steel in the Turbine Building.
Based on the above discussion, this revision does not alter the conclusion that the thermal expansion in the Turbine Building is limited to an acceptable level.
- c. Turbine Building Heater Bay Roof Truss Two sprinkler systems were installed at the 692' elevation in the Turbine Building Heater Bay area and cover the same area with one set of nozzles aimed upward and one set aimed dovnvard. These sprinkler systems were evaluated for compliance with NFPA-13,
" Standard for Installation of Sprinkler Systems" and the sprinkler systems are being upgraded to one system that resolves the code l
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deficiencies as identified in the Toledo Edison-letter to the NRC
< dated May 23, 1988 (Serial No. 1497). These upgrades vill be ,
completed prior to power ascension from the sixth refueling outage as stated in the Toledo Edison letter to the NRC dated December 2, 1 1988 (Serial No. 1595). The proposed-change deletes the sprinklers in the Turbine Building Heater Bay Roof Truss (FSA-7502) and j
' retains the sprinklers in the Turbine Building Heater Bay (FSA-7501). This sprinkler system (FSA-7501) vill be in compliance I
1 with NFPA-13. Thus the proposed revision does not alter the conclusion that that thermal expansion in the Turbine Building is limited to an acceptable level.,
- 10. The SER requirement was to install a fire detector in Room 233. The
-proposed revision deletes the requirement for a detector in Room 233.
Room 233l(Fire zone G-8) is one of the nineteen rooms that comprise fire .
area G. The FHAR Section 5.G describes 13 fire detection zones that comprise the fire detection capability for fire area G. A review of fire zone G-8 vas performed which determined that a detector is not required due to minimal fire loading (400 BTU /ft ) and no safe shutdown cables.
2 being routed in the room. The room is inaccessible except through concrete shield plugs from the room above which are normally in place.
The lack of room openings and lov fire loading ensure containment of any postulated fire. The p oposed revision which reflects the existing plant configuration has ',een evaluated and there is no adverse impact on the fire detection capability for Fire Area G.
- 11. The SER requirement was to install additional area type detection in the Fuel Handling Area (Room 300). A review of Room 300 (Fire Area V) was performed which-determined that additional detection should be installed by the end of the sixth refueling outage as stated in Licensee Event Report 86-030 Revision 1 dated March 23, 1988. Local detection is provided in Room 300. Since the detectors are not required to resolve an
-Appendix R (safe shutdown) concern, the detectors will be installed by the i end of the seventh refueling outage. This schedule is consistent with I
that provided in a Toledo Edison letter dated December 2, 1988 (Serial Number 1595). The proposed revision requires the detector installation by the end of the seventh refueling outage.
- 12. The original requirement was to install in-tray linear type, thermal sensing fire detectors inside all the cable trays in the Cable Spreading Room (Room 422A). The original installation was completed. In addition, the Cable Spreading Room contains 5 area ionization type smoke detectors which are being upgraded to resolve the NFPA-72E, " Standard on Automatic Fire Detectors" code' deficiencies as identified in Toledo Edison letter to the NRC dated May 23, 1988 (Serial No. 1497). The NFPA 72E upgrade vill be completed prior to power ascension from the sixth refueling outage as l
h stated in the Toledo Edison letter to NRC dated December 2, 1988 (Serial No. 1595). Based on Cable Spreading Room construction of a smooth ceiling L
l approximately 8 ft. high and the upgrade to resolve the NFPA 72E lg deviations, the area ionization type smoke detectors provide adequate
, ,- :T)ockst Nuib3r 50-346-Lic:nsa Nu b;r NPF-3 Serial Number:1788 Attachment-l'
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e detection capability and the in-tray detectors are no longer required.
The proposed revision deletes the requirement for the in-tray, linear type, thermal sensing fire detectors. The upgrade of the area. ionization-type smoke detectors will provide an adequate level of' detection capability in the Cable Spreading Room.
- 13. TheLSER requirement'vas to install 8-hour emergency battery pack lights in Passage 241. In 1987, a lighting unit in Passage 241 was installed-vith- ,
the power supplied from'a battery unit.in Passage 227. The proposed o
revision clarifies that Passage 241 is illuminated without the 8-hour ,
emergency battery pack being in the room. The proposed revision, which reflects the existing plant configuration, has been reviewed and ensures there is sufficient illumination in Passage 241.
- 14. The SER requirement was to install 8-hour emergency battery pack lights in Makeup Pump Room 225. Instead of installing the lights in Room 225, the emergency battery pack lights were installed in the Vestibule (Room 226A) with light directed into Room 225 to provide illumination for access and egress in Room 225. The lighting from Room 226A is continuous because there is no door-or other intervening objects, which could block the light. Thus'the emergency light is situated such that its light beam provides adequate illumination to Room 225 for access and egress. In addition, an emergency lighting unit has recently been installed in Room 225 for Appendix R required manual actions. The proposed revision, which reflects.the existing plant configuration, has been reviewed and ensures there is sufficient illumination in Room 225 for access and egress.
- 15. The SER requirement was to install a 1/2 hour fire rated barrier (Kaovool) in the Service Water (SV) Valve Room (Intake Structure - Room _53) around.
the power and control circuits for the Service Water valves (SV 2930, SV 2931) located in the service water discharge header. The original installation was completed but'later removed. The affected valve was depowered which negated the.need for the fire barrier wrap. The proposed change deletes the requirement for the 1/2 hour fire rated barrier (Kaovool). CARP Section 4, Note 12 for Fire Area II (Room 53) states that one of the four Service Water Discharge Valves (SV 2929 through SV-2932) is normally open and depovered (controlled administratively)-to ensure a
'SV return flow path is available following a fire in.the area. The approach in the CARP is an acceptable alternative to the 1/2 hour fire rated barrier. The proposed revision has been analyzed in the CARP and' there is no adverse impact on the ability of the system to function as required for safe shutdown.
- 16. The SER requirement was to install a 1/2 hour fire rated barrier (Kaovool) in Passage 227 around the circuits for the Train 1 Auxiliary Feedvater Pump suction valve FU 786 and the interlock to Service Vater valve SV l 1382. The original requirement was met by installing Kaovool barriers on conduit 27572A (cabling for the interlock to SV 1382) and on conduit 27708A (cabling for Auxiliary Feedvater Pump suction valve FV 786). CARP Section 4'for Fire Area G (Passage 227) states that train 2 equipment is
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. JDock;t Nu b;r 50-346-Lic;nsa Nuxb;r NPF-3, Serial Number.1788-Attachment 1, Page-8 assured available for safe shutdown and SV 1382 and FV-786 are Train 1 valves. The proposed revision deletes the requirement for the 1/2 hour t rated barrier (Kaovool). The proposed revision has been analyzed in the L CARP and there is no adverse impact on the safe shutdown capabilities. ,
- 17. The SER-requirement was.to install a 1/2 hour fire rated barrier (Kaovool) in Passage 209 around the circuit for the Borated Vater Storage Tank (BVST)-level instrumentation, Makeup Pump No. 2, and Train 2 BVST outlet valve. .The original requirement was met by installing Kaovool barriers on conduit 28222A (cabling for Makeup Pump No. 2), conduit 27670C (cabling for BWST outlet valve DH 07A), and on the four conduits containing the four trains of BVST level instrumentation. The proposed revision deletes the requirement for the 1/2 hour rated barrier (Kaovool).
For the r' ire Area G (Passage 209) safe shutdown analysis, the High Pressure Injection (HPI) System takes suction from the BVST to maintain the water inventory in the Reactor Coolant System. Due to the large BVST volume (Technical Specification minimum of 482,778 gallons) and the limited water volume _ required to achieve cold shutdown it is not necessary to monitor the BVST vater level to ensure that there is adequate BVST vater to achieve cold shutdown. CARP Section 4 Note 19 for Fire Area G states that HPI is the system that is assured for RCS injection (level inventory and reactivity control) for safe shutdown in this fire area.
The Makeup System serves as a redundant system to the HPI and is not required-to assure safe shutdown in this fire area. CARP Section 4 Note 4 for Fire Area G states that there is ample time available to manually verify /open Train 2 BVST outlet valve (DH 07A) in Fire Area AC for a fire in Fire Area G to ensure BVST availability for safe shutdown. The proposed revision, which deletes the-requirement for the half-hour vraps, has been analyzed in the CARP and there is no adverse impact on the safe shutdown capabilities.
-18. The SER requirement was to install 1/2 hour fire rated barriers (Kaovool) in Passage and Hatch Area 310 and 313 around the conduits for both trains ~!
of Component Cooling Water (CCV) crossover header valves (CC 5095, CC 5096) and CCV return header from containment valves (CC 5097, CC 5098).
The original barrier on conduits 46088B and 47342A, which contain trains 1 and 2 power cabling respectively for CC 5095, CC 5096 and CC 5097, CC 5098 was installed. Originally, valves CC 5095, CC 5096, CC 5097 and CC 5098 l vere protected to provide cooling for the Makeup Pumps and the immediate L reestablishment of Reactor Coolant Pump seal cooling and seal return. The proposed revision deletes the requirement for the 1/2 hour fire rated barrier for CCV crossover header valves (CC 5095, CC 5096) and for CCV return header from containment valves (CC 5097, CC 5098).
CARP Section 4 Note 4 for Fire Area U (Passage and Hatch Areas 310 and 313) states that HPI is the system that is assured for RCS injection (inventory and reactivity control) for safe shutdown in this fire area.
Therefore, the Makeup Pumps are not required. The existing RCP seals are being replaced with a newly designed RCP seal. Based on test data, l
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-integrity of the_new seal is maintained without seal cooling for eight hours. Af ter eight hours, RCP seal cooling and seal return vill be -
L reestablished. As part of the process of providing RCP seal cooling and seal' return, some fire areas contain motor or air operated valves which could be exposed to a fire'in the area and require manual repositioning.
These motor or air driven valve operators would not be mechanically impaired by a fire in such a manner to prevent subsequent manual handvheel operation of the valves as discussed in Toledo Edison letter to the NRC dated February 16, 1990 (Serial No. 1757). The seal changeout and the procedure revision to reestablish RCP seal cooling and seal return vill be completed by the end of the sixth refueling outage. Since the valves are y not immediately required to achieve hot shutdown and adequate time is l available for required manual actions, the fire barrier wraps are not- 1 required. Thus the proposed revision has been analyzed and there is no adverse impact on the safe shutdown capabilities.
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- 19. The SER requirement was to install a 1/2 hour fire rated barrier (Kaovool) ;
in the Service Vater Pump Room (Room 52) around the circuits for the l Service Vater Pumps (1, 2 and 3) and for the Service Water valves on the !
return line to the forebay (SV 2930) and the cooling tower makeup (SV i 2931). The service' vater valve motors (SV 2930, SV 2931) located in Room '
53, were also enclosed with a 1/2 hour fire rated barrier. The original l installation was completed. The proposed revision' deletes the requirement l for the 1/2 hour fire rated barrier (Kaovool). CARP Section 4 Note 5 for Fire Area BF states that one of the four SV Discharge Valves (SV 2929 ;
through SV 2932) is normally open and depowered (controlled i administrative 1y) to ensure a SV return flow path is available following a fire in the area. CARP Section 4 Note 2 for Fire Area BF states that the l!
Backup Service Vater Pump, which is in Fire Area BD, is available as the
' backup for the three Service Water Pumps in Fire Area BF. The Backup Service Water Pump operation is not affected by a fire in Fire Area BF, i Therefore, the Kaovool barriers on the conduits for the Service Vater
, Pumps and valves and the Service Vater valve motors are no longer required. The approach in the CARP is an acceptable alternative to the l 1/2 hour rated barrier. The proposed revision has been analyzed in the
! CARP and there is no adverse impact on the ability of the system to l~ function as required for safe shutdown.
y 20. The SER requirement was to install a 1/2 hour fire rated barrier (Kaovool) in Component Cooling Vater Pump and Heat Exchanger Room (Room 328) around the circuits for the Component Cooling Vater pumps (1, 2, 3) and power and control circuits for the CCV crossover valves (CC 5095, CC 5096). The underside of the valve motors were also required to be protected with a 1/2 hour fire rated barrier. The original installation was completed.
The proposed revision deletes the requirement for the 1/2 hour fire rated barrier for the CCV crossover valves (CC 5095, CC 5096), but retains the fire barrier vrap requirement for the CCV pumps circuits.
CARP Section 4 Note 1 for Fire Area T states that HPI is the system that is assured for RCS injection (inventory and reactivity control) for safe
Dock:t Nu ber 50-346-Lic:ns3 Nu b r NPF-3 Serial' Number 1788 Attachment-1 Page 10 shutdown. CC 5095 and CC 5096 are required when the Makeup System is being utilized to provide RCS injection. As discussed in Item 18 above, procedural' actions to open/ verify valves CC 5095 and CC 5096 are required to restore RCP seal cooling and time is available for manual actions, the fire barrier vraps are not required. The Kaovool vrap required for the CCV Pump circuits as listed in CARP Section 4 Note 3 for Fire Area T is being replaced-during the sixth. refueling outage with a one hour fire rated wrap which is more durable than the Kaovool vrap. -Thus the proposed-
- revision has been analyzed in the CARP and there is no adverse impact on the safe shutdown capabilities.
As described above, the proposed revisions to the License Condition 2.C(4) do not degrade the safe shutdown evaluation or fire protection capabilities as described in the USAR, FHAR and CARP. ;
SIGNIFICANT HAZARDS CONSIDERATION:
The Nuclear Regulatory Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazard exists due to a proposed amendment to an Operating License for a facility. A proposed amendment involves _no significant hazards consideration if operation of the facility in accordance with the proposed change would (1) Not involve a significant increase in the probability or consequences of an accident previously evaluated;.(2) Not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Not involve a significant reduction in a margin of safety. Toledo Edison has reviewed the proposed change and determined that a significant hazards consideration does not exist because operation of the Davis-Besse Nuclear Power Station, Unit No.
1, in accordance with these changes vould:
la. Not involve a significant increase in the probability of an accident previously evaluated because the change to emergency lighting, fire suppression systems, fire barriers, fire detection systems, fire extinguishers, fire doors-and fire proofing do not contribute to fire initiating events and maintain an equivalent level of fire protection and safe shutdown protection.
Ib. Not involve a significant increase in the consequences of an accident previously evaluated because the change to emergency lighting, fire suppression systems, fire barriers, fire detection systems, fire extinguishers, fire doors and fire proofing maintains the level of fire protection provided prior to this proposed change and ensures the safe shutdown evaluation results are maintained.
2a. Not create the possibility of a new kind of accident from a"y accident previously evaluated because the change to emergency lighting, fire suppression systems, fire barriers, fire detection systems, fire extinguishers, fire doors and fire proofing maintains the level of fire protection provided prior to this proposed change and ensures the safe shutdown evaluation results are maintained.
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2b. Not create the possibility of a differentLkind of accident from any ,
accident previously evaluated because the change to emergency lighting,_ fire suppression systems, fire barriers, fire detection-systems, fire extinguishers, fire doors and fire proofing maintains-theslevel of fire protection provided. prior to this proposed change and ensures the safe shutdown evaluation results are maintained.
3 '. Not involve a significant reduction in a margin of safety because the change maintains the margin of safety for emergency lighting, fire i suppression systems, fire barriers, fire detection systems, fire
- . extinguishers,. fire doors and fire proofing and ensures the safe
- 7. shutdown evaluation results are not changed.
CONCLUSION.
On the basis of the above, Toledo Edison has determined the License Amendment Request does not involve a significant hazards consideration.
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