ML20080G331

Forwards Revised Evaluation of NRC 830725-29 App R Audit Findings & Corrective Action Plan,Superseding Info Submitted w/830826 & 31 Ltrs.Findings & Plan Justify Continued Operation

ML20080G331
Person / Time
Site:	Davis Besse
Issue date:	09/13/1983
From:	Crouse R TOLEDO EDISON CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
986, TAC-52156, TAC-56864, NUDOCS 8309200223
Download: ML20080G331 (57)

Text

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Docket No. 50-346 7gL,gg License No. NPF-3 EDISON Serial No. 986 RCHARO P. CROUSE Vete Presdent Nuchter September 13, 1983 msassmi Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Eisenhut:

Several members of the Nuclear Regulatory Commission (NRC) Fire Protection Audit Team returned to the Toledo Edison Company (TED), Davis-Besse Nuclear Power Station, Unit 1 (DB-1) during the period September 7, 1983 through September 9, 1983. Their purpose was to verify the adequacy and completion schedules of the actions being performed by TED to adequately address the NRC concerns identified during the Appendix R Fire Protection Audit of July 25-29, 1983.

An evaluation and plan addressing our understanding of the findings and the actions being implemented to resolve those findings was developed.

This justification and action plan was initially forwarded to you on August 26, 1983 (Serial No. 981), as requested by your letter concerning this matter, dated August 19, 1983.

During this past week, several interfacing meetings were held between your staff and the staff of the Toledo Edison Company. These meetings, which we considered quite beneficial, resulted in clarifications of the original TED actions, NFPA and 10 CFR 50 Appendix R interpretation resolutions, and the identification and scheduling of additional TED actions. The result has been to provide both adequate assurance of the capabilities of the existing systems and programs and also to develop the specific compensa-tory measures necessary to satisfactorily supplement the existing systems until completion and resolution of the identified long term actions.

A program of short term, interim, and long term actions has previously been submitted for your review in the " Evaluation nf July 25-29, 1983 NRC Appendix R Audit Findings and Corrective Action Plan". This evaluation was originally forwarded as Attachment 1 to our August 26, 1983 letter (Serial No. 981) . Subsequent to that submittal, Revision 1 was made to correct minor typographical errors in the Action Summary portion of the original August 26, 1983 submittal. This Revision 1 was forwarded to you on August 31, 1983 (Scrial No. 983).

8309200223 830913 PDR ADOCK 05000346 F PDR THE TOLEDO EC. SON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652

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.D:ckat No. 50-346 License No. NPF-3 Serial No. 986-

_ September 13, 1983^

Page 2 As a result of your staff's visit, minor changes have-been made in the-submitted program. To ensure completeness, a full revision is forwarded to you as Attachments 1~and 2 of this letter. This revision, therefore,

. supercedes that information forwarded to you in the August 26, 1983 and the August:31, 1983 submittals. The changes are identified by revision bars placed in the margin. Page 38' has been reworded in one _ sentence to ensure. proper understanding. Page 40 has been revised to identify that the Emergency Plan' requiring revision has not been completed, however, this is in the current pending _ revision of the Plan and will be completed by November 1, 1983.

Significant additions have been made to _the Action Summary (Attachment 2).

Within this. Action Summary are the short term actions being performed by

~TED prior to restart, as identified by your staff, TED personnel, or simply expanded from our~ original submittal to ensure a complete action identification and listing.

. Included in Attachment 1 is a discussion of the additional actions and/or; clarifications identified prior to and during the re-audit. These items have been discussed at length with your staff.. This information is included to more fully. identify the extent-of the actions being performed-by TED. The intent cf the additions to.the submittal is to provide fuller details of our actions being' performed'to supplement the originally discussed actions and satisfy the concerns of the NRC' Audit-Team relative to the-action plan and evaluation. Revision bars placed in the margin identify this additional information.

-Toledo Edison reasserts that, with the corrective actions discussed in Attachment 1, we are confident that DB-1 can;be operated in a manner to ensure protection of plant equipment important to safe shutdown and with no adverse effects to the health and safety of the public. These actions, combined with the program plan activities identified, provide adequate justification for operation of the facility until the identified audit findings are completely resolved.

Very truly yours,

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cc: -DB-1 NRC Resident Inspector 4

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D6cket No. 50-346

• Licence No.-NPF-3~

.; Serial 986 Attachment 1 Page l'.

TOLEDO EDISON. COMPANY DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 EVALUATION OF JULY 25-29, 1983 NRC APPENDIX R AUDIT FINDINGS AND CORRECTIVE ACTION PLAN

Docket No. 50-346 Y License No. NPF-3~

Serial 986~

- Attachment 1 Page 2 I. INTRODUCTION _

The NRC conducted an onsite audit of the Davis-Besse Nuclear Power Station, Unit'l (DB-1) during the week of' July 25-29, 1983. The purpose of this audit was to -ascertain whether the Plant was in conformance with Sections III.G, III.J, III.0 and III.L of Appendix R' to 10 CER-50. Twenty-nine findings-were identified by the NRC audit team _at the exit meeting on July 29, 1983. Of the findings the NRC audit _ team identified, eleven are considered deficiencies to Appendix R while eighteen are considered Fire Protection Program -

NFPA-commitment' type deficiencies.

- The Toledo Edison Company (TED) has initiated a program for correc-tive action in response to the findings of the NRC audit team.

Immediate corrective actions have been or are being implemented as described in Section III. Longer-term corrective actions addressing the programmatic generic deficiencies are described in Section IV.

TED has evaluated each audit finding and has concluded that adequate fire protection features will be.in place, prior'to return to power-operation for Fuel Cycle 4, to assure the protection of plant equipment important to safe shutdown. . The specific audi. findings, and the basis for conclusions justifying continued plant operation,

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are discussed in Section III.

II. -BACKGROUND

. DB-1 was originally designed and licensed for-protection against fire

- in accordance_with General Design Criterion'3 of Appendix A to 10 CFR 50. .In September, 1976, the NRC requested that TED compare the existing fire protection provisions at DB-1 with the new NRC t guidelines, as set forth in Branch Technical Position (BTP) APCSB

9.5-1.

LIn October,2 1976~, TED notified the NRC that the requested information would be in-the form of a Fire Hazards Analysis Report (FHAR)' based on Appendix A to BTP APCSB 9.5-1. The FHAR was initially issued on

February 11, 1977.

< - Subsequent to this issue of the FHAR, six revisions were made to the

- document. .These revisions were developed to resolve concerns evolv-4 ing from~the ongoing discussions and interfacing activities. held between the NRC and TED at the time. The_ seventh' revision currently being developed incorporates the most recently completed Facility Change Requests (FCR) relative to Fire Protection System Upgrades.

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Dock 2trNo. 50-346'

+- Licanze No. NPF-3

--Serial 986 Attachment 1 Page 3; s

I 'The Safety Evaluation Report (SER). issued as License Amendment 18 was received by TED in July, 1979.

Within the SER, the-NRC stated that the fire protection program at 5/ -DB-1 is adequate at the present time and meets General Design

-Criterion 3. Extensive fire protection improvements, however, were required, scheduled, and implemented. These modifications consisted 4

of _ service water system modifications, installation of additional fire extinguishers, sprinkler systems, water curtains, concrete curbing, hose stations,- battery room alarms, fire rated doors, dampers, fire detection systems, emergency lighting, conduit protec-e' tion, additional fire protection of structural steel and cable trays and the ' additional availability of portable radio communication equipment for emergency fire fighting _ operations. Administrative controls and training procedures were additionally upgraded. The 1980 Refueling Outage was significantly1 extended to ensure the installation of all~the required equipment with the exception of a-backup;to the service water system which was scheduled for. completion in mid-1984. In November,_1980, the NRC published a final rule on fire protection programs for operating nuclear power plants as 10 CFR 50.48 and App'endix R.to 10 CFR 50. This rule became-effective on February 19,;1981. With respect to certain generic issues, Appendix R

then~re-established specific fire protection features required to

. satisfy General Design Criterion 3.

.Section III.G of Appendix R,:" Fire Protection Safe Shutdown Capabili-ty," requiresLfire_ protection for equipment important to safe shut-down. Such fire protection is achieved by various combinations of fire barriers,-fire suppression-systems, fire detectors, and separa-tion of safety trains (III.G.2) or alternative safe shutdown equip-ment free of the fire area (III.G.3 and III.L). The objective of

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, this protection is to ensure that one train of. equipment needed for

i. hot shutdown would be undamaged by fire, and that. systems needed for cold shutdown could be repaired within'72 hr. (III.G.1).

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Section III.J of Appendix R, " Emergency Lighting", requires that-emergency lighting units with at least an 8-hr. battery power supply be provided 'in all areas needed' for operation of safe shutdown equipment and in routes.thereto.

Section III.0 of ' Appendix R, " Oil Collection System for Reactor

, Coolant Pump", requires each reactor coolant puro to be equipped with

an oil collection system.

On February 20, 1981, the NRC published Generic Letter 81-12. This

' letter stated that Appendix R would' require each licensee to reassess

- all those areas of the plant to determine whether the requirements of Section III.G.2 of Appendix R were satisfied. If not, licensees were to: (a) make any modifications necessary to comply with Section III.G.2 Y

-4 Dockst No. 50-346 Licen n No. NPF-3 Serial'986 Attachment 1 Page 4

~ requirements; or (b) provide alternate shutdown capability in con-formance with Section III.G.3; or (c) request an exemption if there was some justifiable basis. Licensees were also requested to submit the results of their reassessment of plant design features for meeting the requirements of Sections III.G,Section III.J, and Section III.0 of Appendix R.

TED provided a response'to Generic Letter 81-12. In March, 1982, TED personnel met with NRC representatives to discuss the Appendix R requirements. A need for two specific exemptions were subsequently identified. Two' specific exemptions from the requirements of Appen-dix R were requested by a letter dated April 29, 1982. The NRC issued an SER on June 2,1982, granting both exemptions requested.

F-Dockst.Ns. 50-346 Licenze No. NPF-3

' Serial 986-JAttachment 1~

!Page 5 III. FINDING EVALUATION _

Section A below lists each of the twenty-nine audit findings ac they were orally presented to TED by the NRC audit team at the audit exit inte rview. Section B evaluates the current plant condition, describes actions to be implemented prior to return to power operation for Fuel Cycle 4 and summarizes our current conclusions regarding' the justifica-tion for continued plant operation pending further analyses /modifica-tions. Long-term actions are. described in Section IV.

A. Summary of Audit Finding.

1. ' Alternative Shutdown Capability to Achieve Hot Standby-There is no' demonstrated alternate shutdown capability for achieving hot standby in.the event of a fire in the cable spreading room / control room.

2. Alternative Shutdown Capability to Achieve Cold Shutdown There is no demonstrated alternate shutdown capability-for achieving cold shutdown-in the event of a fire in the cable spreading room / control room.

3. Auxiliary Shutdown Panel-The auxiliary shutdown panel does not meet the shutdown capability' requirements of Appendix R with respect to source range flux', cold leg temperature,'and the range for hot leg temperature.

4. Emergency Lighting Design The-emergency lighting'oes d not meet the requirements of Appendix R with respect to equipment. operation, access and egress routes, testing, lighting intensity, positioning and Einstallation.

5. ~ Fire Doors Two fire doors, designated as doors 215-and 217, are not

, labeled as UL approved.

6. ~ Reactor Coolant Pump Oil-Collection System The. reactor coolant pump oil collection holdup capacity cannot accommodate the entire-lubricating oil system inventory as required by Section III.O of Appendix R.

r is D:ckst No. 50-346

• Licenze No..NPF-3 Serial 986 Attachment 1~

Page 6

7. Housekeeping Wooden scaffolding was found stored in Mechanical Pene-tration Room 3 since April 30, 1983, and scrap wood and sawdust were present in the room.

8. Fire Damper Inoperability Three dampers were inoperable with no fire watch for a

-period of approximately two to three months due to person-nel error and an inadequate' test procedure.

9. Service Water Discharge Valve Room Discharge valves and local controllers are exposed to a single disabling fire in violation of Section III.G of

' Appendix R. One hour wrap deficiencies exist and there is partial versus full suppression capability in the room.

10. One Hour Fire Barriers - Test Report The adequacy of the Kaowool wraps was left as an open item with the'following comments:

a. The test report in support of crediting the wraps as one-hour barriers was' inconsistent and inadequate.

b. The test report did not address configurations exist-ing at Davis-Besse.

11. One Hour-Wraps - Installation The one hour wraps are incomplete,.poorly installed, and not in accordance with the test installation.

12. Fire in the Auxiliary Shutdown Panel A-fire in the auxiliary shutdown panel can cause a loss of both trains of the auxiliary feedwater pump governor control circuitry.

13. Diesel Fire Pump Test Procedure The diesel fire pump test procedure was not written nor the test performed in accordance with NFPA 20 requirements.

14. Fire Hose Stations Fire hose stations are not in accordance with NFPA 14 reqdirements to have pressure reducers on standpipes.

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s 1Dockst Ns. 50-346

= License Ns. NPF-3' Serial 986 Attachment 1 Page 7 L15. Fire Door Modifications Modifications were made to the fire door to room 320 with no documentation.

16. Sprinkler System Routing of water suppression below cable trays located near the ceiling is in violation of NFPA STD-13 and -16 and License Amendment'18.

17. Yard Hydrants'and Valves No physical barriers exist around some yard hydrants / valves.

18. Fire Pump Test The. fire pump test is not in accordance with NFPA as stated in the FSAR.

19. Control of Combustibles A procedure does not exist for control of combustibles.

20. Fire Protection System Flush The fire protection system flush and valve operation is.

performed every three years instead of every year as required by NFPA.

21. Fire Detector Maintenance '

Dust accumulation requires photoelectric detector adjust--

- ment. Procedures do not address this.

22. Fire Door and Damper Maintenance Procedures for fire door and damper maintenance identified no surveillance from 1978 until recently. NFPA requires a monthly visual check as a minimum.

23. Emergency Lighting - Surveillance Procedures should be revised to perform surveillance quarterly instead of semi-annually.

T s-Docket No. 50-346

• . _ License No. NPF-3 Serial _986 Attachment l' Page 8

24. Off-Site Fire Department Training The level of training, knowledge and responsibility for off-site fire department assistance is inadequate.

~25. Welding Permits Welding permits are not-to be issued for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required in NFPA 51 and 51B. Weekly permits .

are allowed at Davis-Besse.

26. Sprinkler Tests The 1980-1983 sprinkler tests are inadequate relative .ta)

NFPA.

27. Off-Site Contractors Fire Watch Training Off-site contractors are inadequately trained as fire watches.

28. Fire' Protection Coordinator Staff The fire protection effort appears understaffed relative to Administrative Procedure AD 1810.00 and License Amendment 18.

29. High/ Low Pressure Interfaces The_ nonexistence of.high/ low pressure interface deficiencies on the PORV's and letdown cooler isolation valves should be verified.

lB . Evaluation of Audit Findings An evaluation was performed for each audit finding. These evaluations are' presented below.

Of the twenty-nine audit findings, eighteen are not directly related to Appendix R, rather they are fire protection program

' items, the majority . coming under the NFPA code or Fire Protection Handbook items.- Eleven, findings are directly-related to Appendix R.

Each evaluation below is based on the following:

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• ' status of the item

[ .* a review of the status for compliance against the appropri-ate references (Appendix R or NFPA)

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Dockst No. 50-346 t Licanze Ns. NPF-3 Serial 986 Attachment 1 Page 9

• an identification of short-term and/or long-term actions to correct any NRC identified deficiencies

• any compensatory actions taken

• justification for start-up and continued operation in view of the degree of non-compliance and the corrective actions planned to be taken

1. Alternative Shutdown Capability to Achieve Hot Standby

2. Alternative Shutdown Capability to Achieve Cold Shutdown The audit team identified that an item-by-item listing of those systems and components required to achieve hot standby

• and cold shutdown condition was not developed.

Component listings are included in the Fire Protection Manual Preplans in addition to the listing in FHAR Appendix 5, however, they were identified as being cumber-some to'use. These listings, as well as the Fire Preplans themselves, were not referenced in the appropriate control room evacuation procedure. This led to the deficiency identified by the' audit team that inadequate procedures existed to demonstrate personnel, equipment and operational preparedness in accordance with the 10 CFR 50 Appendix R.

TED had originally developed the Fire Preplans which identify the rooms, access routes, locations of power supplies and receptacles, room ventilation information, support information in addition to the evaluation of potentially lost equipment and.the evaluation of the shutdown capability (i.e., identification of alternate trains available) to support the fire fighting and plant operability conditions as a result of a fire in each area.

To not have this information directly incorporated into the Evacuation of the Control Room Procedure was identified as a deficiency.

l A review of the Fire Protection Manual Preplans is being performed to ensure no inconsistencies exist. During the l- audit, two discrepancies were found in the tables, "Evalu-l ation of Fire and Shutdown Equipment". The resolution of the discrepancies is addressed in the actions resolving Findings Numbers 9 and'12. This was interpreted by TED as requiring the generic review. This action will sufficiently address'the inconsistency concern. If additional dis-crepancies are found, resolution will be provided prior to restart. - A'long-term task has been incorporated to thoroughly review and re-validate the Preplans. This task with its schedule, is discussed in Section IV, Task 8.

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Dock:t No. 50-346 Licenze No. NPF-3 Serial 986 Attachment 1 Page 10 The NRC audit team conducted a walk-thru on July 28, 1983, to test the plant's ability and the ability of the operators to achieve hot standby in the event of fire in the control room. The audit team praised the operators in their ability to quickly formulate a procedure during the drill tieing much information together from various procedures.

However, the audit team concluded that development of procedures for achieving hot standby and cold shutdown in the event of a fire in the control room and cable spreading room, using on-site power only, was necessary.

TED is developing a detailed procedure (AB 1203.26) to be used in the case of a total loss of the control room and/or cable spreading room due to fire to get the plant to a safe hot standby condition and subsequent cold shutdown condi-tion. The procedure is designed to be responsive to the requirements of Appendix R.

The criteria inherent in the development of the procedure is:

a. loss of off-site power due to the possibility of spurious power breaker operation,

b. total burnout of power and/or control to all trains of equipment with power or control power in the control room or cable spreading room (whichever has the fire)

c. worst possible position of all components in the trains that were burned out

d. use of only_ the components which the fire preplan identified as remaining available subsequent to the fire

e. capability to accomplish hot standby by current on-shift organization

f. total loss of the Gai-tronics communication system The basic approach to the new procedure is to de-energize all equipment which could cause the spurious or maloperation of' safe shutdown equipment and additionally to de-energize

non-safety related equipment which could mislead the j operator. The emergency' diesel generator buses will be j manually reloaded sequentially with the equipment necessary to achieve hot standby and cold shutdown. Required safety l and repair equipment will be identified. The fire preplans were consulted in the writing of the new procedure, and the i

Dockat'No.{50'-346 e ,

a License'No. NPF-3 ">

~ Serial 986

~ Attachment 1 Page.11 procedure integrates the applicable information provided in the fire preplans concerning potential effects of-a fire in the' control room or cable spreading room. -Instrumentation is. discussed under Finding 3.

The operating procedure AB1203.26 prepared by TED to get to ihot standby and cold shutdown was forwarded to NRR and I&E Region III representatives prior to the re-audit. Comments were discussed both prior to and during the re-audit.

While requiring some minor changes, it was identified that the procedure was not only good on an interim basis, it was very close to being an acceptable final procedure. The following clarifications and supplemental actions,were discussed and agreed to by both NRC and TED staff.

a. The minimum staffing required to perform the current

. procedure includes eleven plant operations personnel

'and sufficiently trained' personnel to perform those instrumentation and control (I&C) and electrical modification activities identified. These actions.

include those necessary to ensure the availability of

-hot and cold leg temperature-(T and T indication throughthe.installationofa'dIgitalfo)lt-ohmmeter.-

(DVOM) and _the performance of the jumper installation,

-wire cutting and breaker racking out activities respectively, identified in the procedure. TED will

-have one I&C technician and one electrician available prior to criticality at all times to perform this 2 action.L In the' future however, additional training of existing personnel and/or appropriate grouping of activities may alleviate the need for one or both of

.- the additional personnel.

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b. The procedure revision will include,the following:

• A note or step requiring the reactor coolant system sampling to ensure adequate Boron concen-

! ' tration, be ' performed as soon as possible after plant stabilization at hot standby.

N- * .A note concerning tasks performed within the control room prior to control room evacuation such that if time did not allow them to be performed prior to the evacuation, that they will be performed locally.

• Additional minor changes as discussed.

D:cket No. 50-346 License No. NPF-3 Serial 986 Attachment 1 Page 12

c. The revised procedure will be forwarded to NRR and.

Region III as soon as it is available. The cover sheet verifying adequate approval will also be for-warded as soon as possible.

d. -The completion of the required training of all appro-priate personnel will be completed and verified by the NRC Resident Inspector prior to restart.

e. Plans and engineering analysis are being performed to revise Procedures-1107.02, Plant Startup and 1102.10 Station Shutdown and Cooldown, to ensure the high/ low pressure interface concern relative to decay heat valves DH11 and DH12 have been adequately alleviated.

This will be done following engineering approval 2 through the initiation of temporary modifications to the procedures ensuring de-energizing of at least one of the valves when the system is at pressure. A

. technical specification and license amendment review is now being performed.

f. The wiring requiring cutting in this procedure will be permanently marked for' ease of identification prior to restart.

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g. Consistent with the long-term Task 8, this preplan review will ensure that the " Evaluation of Fire and Shutdown Capability" tables are grouped by component loss and/or the location of the fire within that area.

This will be performed for the Cable Spreading Room and Control Room fires. This will aide in their use s in identifying the required actions to diagnose the lost equipment for specific smaller fires that may occur.

The training of each operator will be documented. The ongoing operator training program will include reviews of the new procedure.

This procedure is considered interim in nature for two reasons. First, a major long-term review is being per-formed on the entire fire protection program both relative to 10 CFR 50 Appendix R, Generic letter 81-12, the clarifi-cation letter to the Generic Letter, in addition to the original work and commitments made to meet Appendix A to BTP 9.5-1. Integral to our review program is a feedback loop to ensure procedure accuracy and to upgrade the procedure as necessarv. This will validate that hot standby and cold shutdown for a fire in the Control Room or y > - - -r r g y - -e e -

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• Licsnsa No. NPF-3 '

Serial'986~

Attachment 1 Page 13 -

E Cable Spreading Room is not'only achievable but is procedur-alized for the minimum equipment necessary.

Secondly, as discussed in our August 16, 1983 meeting, for a non-fire related issue a' major, verification analysis is-engoing-to ascertain appropriate cooldown rates based on c natural circulation conditions. Our current expectations

, are that a significant time in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> would be required. To address this problem in the interim, the procedure under development is for a cold shutdown under

. loss of offsite power conditions independent of time. Of course, the plant condition that.would require this proce-dure to be implemented also generates a " Site Emergency"

! condition under the auspices of 10 CFR 50, Appendix E, and fully activates all utility, industry, state, and federal emergency. response organizations,.' An evaluation of the conditions and acceptability of any action will be under the direct purview of our respective emergency response personnel. They would consider the latest available information and an appropriate engineering assessment at the time of the condition and confer in the appropriate actions.

These procedures are considered to be acceptable and certainly justify plant operation until modified as a result of the longer term activity identified in Section -

IV.

,f' Additional actions required to address the Appendix R requirements relative to these deficiencies will be re-viewed and addressed integral ~to long-term Tasks 1 and 2

,(see Section-IV). The lack of an associated circuits submittal was not identified as an audit finding. During the audit, three DB-1 representatives were provided to support the associated circuit review auditor. No unre-solvable associated circuits deficiencies were identified.

This was a result of the circuit isolation, design, and coordination activities integrated at DB-1 during plant design and construction.

During 1975-1976, TED, in conjunction with Bechtel, per-formed a detailed engineering inspection of the circuit separatio'n at DB-1. The resultr, of that review are docu-mented'in TED files. The review addressed the concerns relative to associated circuits identified at that time. '

TED will research the documentation of the 1975-1976 review to confirm to what extent it meets the associated circuit analysis requirements provided in Appendix R, Sections III.G and L, Generic Letter 81-12, and the NRC clarification

. i Dockst Ns. 50-346 Licensa No. NPF-3 Serial 986.

Attachment 1 Page 14 letter to the Generic Letter. This effort is part of our long-term program (see Section IV Task 5).

e - There are extensive fire protection measures presently in place to provide fire protection in the Control Room and

- Cable Spreading Room. The Cable Spreading Room (CSR) fire protection features include full Kaowool cable tray blan-keting to inhibit smoke and heat transmittal between trays,

> multiple area detection systems, full suppression, a linear fire detector location system, total penetration sealing and extremely tight security controlled access. Access to the CSR is computer controlled and extremely limited. The control room fire protection features have been previously submitted to you and approved in our April 29, 1982 exemp-tion request. Detailed information will be provided, if requested.

TED feels that due to the extensive fire protection fea-tures in place in the Control Room and CSR and together with the newly developed procedure, no additional interim measures are necessary prior to ulcimate resolution under the long-term program.

3. Auxiliary Shutdown Panel The NRC audit team concluded that the auxiliary shutdown panel does not meet the shutdown capability. requirements of Appendix R in that source range flux, cold leg temperature and an adequate range for hot leg temperature are not provided. Questions were additionally raised during the audit concerning the adequacy of isolation devices and separation of power supplies for instrument ioops.

The auxiliary shutdown panel was originally designed to achieve and maintain hot standby. The design basis of the auxiliary' shutdown panel was an event which necessitated an evacuation of the control room, and not a debilitating fire in the control room. The DB-1 Updated Safety Analysis Report describes the auxiliary shutdown panel design.

TED will perform a review of the~ isolation circuitry and power supplies for instrument loops to meet the require-ments of Appendix R as part of the long-term corrective action-program (see Section IV Tasks 1, 2, and 5).

Interim actions will be-taken to compensate for the absence of source range flux, cold leg temperature, and wide range hot leg temperature in the event of a fire in the control room / cable spreading room.

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Docket No. 50-346 Liern e No. NPF-3 Serial 986 Attachment .1 Page 15 A portable battery powered Digital Volt Ohm Meter (DV0M) will be used to take resistance readings and convert them to appropriate cold leg and hot leg temperatures. A conversion table has been developed to quickly provide this indication. The DVOM can be connected by an I&C technician in separate-locations. The procedure to perform this hookup will be available prior to restart.

The long-term program will evaluate how to provide perma-nent cold leg temperature indication and wide range hot leg

, temperature indication (see_Section IV Tasks 1 and 2).

1 Concerning source range flux monitoring the following actions will ensure adequate reactivity control for the shatdown conditions required by Appendix R.

Insufficient demineralized water sources exist that could get to the reactor coolant system through spurious opera-tion of fire damaged circuits to cause a significant

dilution. accident resulting in criticality. The procedure

-for Control Room Evacuation due to fire adequately elimi-I nates the possibility of a long-term dilution accident by immediately stationing an operator at the makeup pump area to ensure appropriate valves are lined up, letdown is.

aligned appropriatelyiif and when needed, and systems are

. operating properly. Concentrated boron from the Boric Acid Addition Tanks and_ water from the Borated Water Storage Tank are both used as makeup water sources.

The reactor, by procedure, is to be shutdown prior to Control Room evacuation.

Primary water samples are taken as soon as possible to verify suitable boron concentration. The letdown system is returned to service early to enable sampling.

Concerning the circuit isolation finding, the audit team again found no unresolvable deficiencies. Preliminary review indicates that a fire in the Control Room and/or CSR may result in loss of reactor coolant pressure and hot leg temperature indication through inadequate isolation.

Alternate hot' leg temperature indication is provided it through use of the DVOM as discussed. -Reactor coolant pressure would be available through installation of a mechanical pressure gauge en RC 54. These actions will adequately provide the necessary indications on an interim basis. These actions are incorporated into the new proce-dure. Until-the long-term tasks are completed to address these three parameters on the auxiliary shutdown panel, TED a

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Dockst Ns. 50-346 4-Licen:e.No. hPF-3 Serial 986 Attachment'l.

Page 16 concludes that these interim measures will provide adequate monitoring.

4. . Emergency Lighting Design The NRC Audit Team identified that the emergency lighting does not meet the requirements of Appendix R with respect  ;

to equipment operation, access and egress routes, testing, '

- lighting intensity, positioning and installation.

The DB-1 Emergency Lighting System is a system of battery powered lanterns providing illumination of critical plant areas in the event of a loss of the normal plant lighting system. The lanterns are powered by individual nickel cadmium batteries which are continuously charged by an integral battery charging system to maintain the batteries in a fully charged condition, The emergency lighting is t 4 located in-critical areas such as access and egress routes 4 and areas where equipment is located which requires opera-tor action.

Emergency lighting is located in the following areas:

545'-0" Elevation Rooms 101, 105, 110, 113, 114, 115, 116, 117, 122, 124, 125 565'-0" Elevation Rooms 201, 202, 203, 204, 208, 209, 211, 212, 221, 223, 225, 227, 230, 234, 235,'236, 237, 238, 240, 241, 242, 243, 244,

.- 249 585'-0" Elevation l Rooms 300, 303, 304, 310, 312, 313, 314, 318, 319, 320, 322, 323, 324, 325, 328 603'-0" Elevation Rooms 401, 402, 404, 405, 406, 411, 412, 427, 428, 428A, 428B, 429, 429A,.4293, 432 623'-0" Elevation Rooms 500, 501, 502,'515, 516 643'-0" Elevation Rooms 600, 601, 602 A new procedure (AB 1203.26) is developed and will be available by restart for fire in the Control Room or Cable Spreading Room. 'This procedure contains provisions for restoring normal plant lighting after aligning necessary

' MCC's and associated lighting control panels to the emer-

~

gency-diesel generators. Plant lighting will be supplied from the diesel generators' after all required essentially fed-loads are being carried ca the diesel generators.

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r Dockst No. 50-346

-Liczare Ns. NPF-3 Serial 986~

Attachment 1 Page 17 During the walkdown activity associated with the procedure training, all emergency lighting units will be properly directed to provide maximum illumination for the components to be operated and/or the access and egress routes to be used.

Ten portable " Captain's" lanterns (of the same type as presently utilized for the fire brigade) were purchased and are on-site. These lanterns are solely for use by the operators should the need arise (i.e., loss of normal lighting). They are stored with the communications equip-ment necessary to implement Procedure AB 1 03.26. These lanterns in conjunction with the present emergency lighting system will allow the operators to successfully carry out their required tasks. Control and accountability of the portable lanterns will be in accordance with Procedure PT 5116.04.

In addition, the security force maintains an adequate inventory of portable lanterns to supply all security personnel while performing their duties during a station blackout.

A long-term review is planned to close out the open audit item on emergency lighting. The finding stated that in many areas the lighting intensity was insufficient. The long-term review will determine the adequacy of the present emergency lighting system and the locations required for emergency lighting necessary for plant operations as well as access / egress routes.

No credit has yet been requested for the use of the exist-ing DC lighting as emergency lighting to meet the require-ments of 10CFR 50 Appendix R, Section III.J. An exemption request will be filed consistent with Task i performance.

This DC lighting was considered an acceptable alternative by the reviewers as an additional backup to the previously I' installed 8-hout emergency lighting systems.

2 t-The walkdown of the energency lighting to adequately direct the emergency lighting units providing maximum illemination for routes and components requiring operation will be completed prior to restart. We understand this will be p ,

verified by the NRC Resident-Inspector.

i Long-term actions are addressed in Section IV Task 4.

i l

l

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Dock?t No. 50-346 Lic:nne No..NPF-3 Serial 986 Attachment 1 Page 18

5. Fire Doors The NRC Audit Team identified that two fire doors, desig-nated as doors 215 and 217, are not labeled as U. L.

approved.

Review of available documentation verifies the configura-tion of Door 215 to be U.L. listed as a three-hour fire barrier. TED delineation and door schedule drawings along with specification 7749-A2 indicated Door 215 to be of Class A construction with a U.L. fire barrier rating of three (3) hours. Door 215, located between the two auxiliary feedpump rooms, is a dual purpose fire barrier and pressure rated door. Additional information is available in DB-1 FHAR Appendix 3, Section 16.

Review of available documentation verifies that Door 217 is part of a double door configuration leading into the Emergency Diesel Fire Pump Room, Room 51. Door 217 is not designed to Class A construction and is not intended to perform as a fire barrier. Door 217A and its associated hardware, located immediately behind Door 217, is rated as a three (3) hour Class A constructed fire barrier and conforms to 10 CFR 50 Appendix R criteria for fire door construction (Ref. FCR 79-005).

Existing documentation is undergoing review consistent with 2 the long-term Task 2 performance involved in barrier requirements and verification.

This finding is considered to be adequately resolved for .

restart.

6. Reactor Coolant Pump Oil Collection System The reactor coolant pump oil collection system was identi-fied as not being capable of collecting lube oil from all potential leakage sites from all four reactor coolant pumps as required.

Each of the four DB-1 Reactor Coolant Pumps (RCPs) has a self-contained lubricating oil system. An oil spillage collection system has'been installed on each RCP. This system consists of a set of catch basins, drip pans, and enclosures, assembled as attachments to the RCP motor to contain or catch any spilled or leaking oil and route it to a drain tank.

'Dockst No. 50-346 Licensa No. NPF-3 Serial 986

' Attachment 1 Page 19 The reactor coolant pump oil collectica system contains two RCP motor oil drain tanks each with a 250 gallon capacity yielding 500 gallon capacity total oil storage. A failure of either RCP upper or lower bearings, oil lift pumps, oil cooler or oil supply piping will collect and drain to the RCP oil drain tank. The upper RCP bearing has an oil capacity of 200 gallons and the lower RCP bearing has an oil capacity of 25 gallons yielding a total of 225 gallons per RCP.

RCP oil drain tank overflow would be through a Ik inch overflow to the area beneath the tank and ultimately to floor drains which are routed to the containment building normal sump.

The oil collection system's function is to keep oil leakage away from hot spots on the RCP and motor. Any RCP fire would be limited to that residual oil remaining on pumps or collection system surfaces and could be extinguished manually by locally mounted dry chemical fire extinguisher or by the 150 lb. wheeled dry chemical fire extinguishers located nearby on the 565'-0" elevation.

Due to plan. layout, it is unlikely that any overflow from the collection tanks would come into contact with hot RCS surfaces as the RCP oil drain tanks are separated and are

.on a lower elevation than each RCP. There is a very low probability of gross _ rupture of multiple RCP lube oil systems resulting in overflow of the RCP oil drain tanks and a low probability of an ignitifon in the event that an overflow does occur. .Therefore, the present design poses no threat ~to safe shutdown capability. However, a' review will be made to determine if as-built conditions ensure that any overflow will be properly drained so that it does

not present a fire hazard. This review will culminate in an exemption request which will be filed by October 1, 1983.

This finding is considered to be resolved upon approval of

.the exemption request.

i

7. Housekeeping l The NRC Audit Team identified that wooden scaffolding was found stored in Mechanical Penetration Room 3 since April 30, 1983, and scrap wood and sawdust were present in the room.

The control of transient combustibles can be adequately demonstrated in Maintenance Procedure MP 1410.75. This f

Docket No. 50-346 License No. NPF-3 Serial 986 Attachment 1 Page 20 ll procedure will be implemented by November 1. 1983. The total transient combustible loading of Mechanical Penetra-tion Room 3, as identified by the TED Fire Protection Staff on or around June 1,1983, equalled 1591 BTU's/ft2 . This transient combustible loading is well below the allowable transient loading as specified by MP 1410.75, " Control and Regulation of Transient Combustibles" (273,989 BTU's/ft 2),

' Administrative implementation of MP 1410.75 provides for a continuous evaluation of transient combustibles for each safety-related room or area of the plant. Attachment 3 (Combustibles for Work Activity) of Procedure MP 1410.75 has provision for continual monitoring of transient combus-tibles based on the premise that appropriate sign off's are demonstrated for addition and removal of transient combus-tibles based on:

a, the scope of the work activity

b. the time duration and sign off's indicating removal of transient combustibles after individual maintenance or modification activities have been completed

'l The transient combustibles stored in the radioactive waste barrels were removed from the pipe chase in Mechanical Penetration Room 3, which is a high radiation area. The wood contained in the radioactive waste barrels was await-ing clearance from Chemistry and Health Physics personnel prior to being removed from the area, i

Scaffolding erected in the area was for ongoing maintenance activities associated with the new piping supports and hangers installed in the area and was scheduled to continue into the outage, beginning in late July, ref. MWO No. 1-83-2795-00, status as of 08/11/83."being scheduled."

Upon completion of the maintenance work activity, the scaffolding will be removed from the area as required by

" Plant Cleanliness Inspection Program", AD 1835. MP 1410.75 is currently being implemented on an interim basis during the current outage to develop the necessary administrative controls and to evaluate the effect of the procedure on maintenance and modification activities. Training programs are currently being developed to train personnel associated with maintenance and modification activities to ensure their understanding of the Transient Combustible Control Procedure and the necessity of articulate performance while completing httachment 3 of the procedure.

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i Dockat.Ns. 50-346

• ~ License No. NPF-3 Serial 986 Attachment 1 Page 21

. Additional control of transient combustibles is demonstrat-ed in AD 1810.01 " Control of Combustibles and Ignition Sources". It is the policy of.the Fire Protection Staff at Davis-Besse to conduct routine periodic inspections of all areas listed in AD 1810.01 Section 1, to ensure that good housekeeping policies are enforced in accordance with AD 1835, " Plant Cleanliness Inspection Program".

We believe the above actions are adequate to address this issue.

8. Fire Damper Inoperability The NRC Audit Team identified that three dampers were inoperable with no fire watch for a period of approximately two to three months due to personnel error and an inade-quate test procedure.

Violation of Limiting Condition of Operation (LCO) concern-ing fire dampers has.been reviewed by the TED fire protec-tion staff with the following action steps incorporated to correct the deficiency and ensure tighter administrative control of fire damper and barrier surveillance testing.

A complete review of all surveillance testing accomplished

'by the individual responsible for improper notification and testing of fire dampers has been completed. This review included'the following surveillance tests; ST 5071.01, ST 5011'.03, ST'5051.10, ST 5074.01 and ST 5051.09. This review encompasses the total work scope of the aforemen-tioned individual from January 1, 1983 to August 12, 1983.

This review, conducted by the lead Maintenance Engineer, concluded that the surveillance tests mentioned above were

! properly performed and reviewed.

~ Revision of ST 5016.11, " Fire Protection System Barrier Surveillance Test" has been completed and the following areas of the procedure have been. revised to reflect tighter administrative control by the TED Fire Protection Staff.

The revised procedure clearly indicates administrative steps to be taken when functionability of a fire barrier, fire door, or fire damper is unsatisfratory. Revision of Section III of the procedure ST 5016.11 clarifies the definition of " operable" and provides explicit guidance in testing and maintenance of. fire dampers. Separate attach-ments incorporated into ST 5016.11' provide. direct and

-explicit control of fire door and dampers which function unsatisfactorily. The attachments incorporate the follow-

.ing information to aid in control of barricr/ separation

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Dockst No. 50-345 Licenze No. NPF-3 Serial 986 Attachment 1 Page 22

' criteria failure; time and date fire barrier declared inoperable, maintenance work order under which fire barrier '

was repaired, and time fire barrier was retested and returned to service. Under the guidelines of the revised procedure (ST 5016.11) maintenance personnel were trained utilizing a program approved by both the Maintenance and

. Fire Protection Staff. All fire dampers inadequately tested shall be re-tested utilizing the revised procedure prior.to plant startup. -

Licensee Event Report (LER) NP-33-83-50 is being reviewed by both Maintenance and Fire Protection Staff and will be

. processed on or before August 26, 1983, as per AD 1804.00, Enclosure 5. The LER will include events listed in DVRs83-092, 83-094,83-095, 83-096,83-097 and resolve LCO concerns regarding fire dampers.

4 During the re-audit, an NRC reviewer observed performance of the surveillance testing in progress. This surveillance testing is being performed using the revised test proce-dure. Ninety percent (90%) of all identified dampers

.. requiring retesting, have been completed. All fire dampers

!- improperly tested per the old surveillance test have been retested on schedule as of. September 10, 1984. The revised

. test was verified as acceptable-and the completion of the testing will be available to be verified by the NRC Resi-dent Inspector. All' dampers declared as inoperable per the test-procedure will be addressed as appropriate in accor-2 dance with~the TED DB-1. Technical Specifications.

, The damper testing program currently being performed will

+

be extended to include all fire dampers performing required fire barrier. functions. A review was performed to identify dampers requiring testing prior to restart due to plant

, operation restricting access to the damper. No such dampers were identified. Additionally, an engineering analysis will be initiated to ascertain:

.- *' The locations of all fire dampers.

• The maintenance and/or modification activity required to enabic testing of each. fire damper.

• A schedule for which the completion of all damper testing can be' identified.

• A program enabling the development of the preventive maintenance - surveillance frequency and actions to ensure fire dampers. continued operability.

D:ck;t No. 50-346 Liccnso No. NPF-3 Serial 986 Attachment 1 Page 23 2

This analysis and its results will be completed and submit-ted to you by November 30, 1983. .

This finding is considered to be adequately resolved for restart with the re-evaluation of the affected dampers using the revised surveillance test procedure.

9. Service Water Discharge Valve Room The Service Water Discharge Valve Room was identified to not meet the requirements of 10 CFR 50 Appendix R, Sec-tion III.G since local controllers are exposed to a single disabling fire and could fault closed as a result of damage to discharge valves or local controllers located in the Service Water Valve Room.

To ensure exposure to a single disabling incendiary event will not cause failure due to an electrical short of service water return valves or associated local control-1ers, the following action will be taken by TED. Procedure SP 1104.11 " Service Water System Operating Procedure" will be revised prior to restart to allow for de-energization of the breaker for whichever service water discharge flow path is in use. De-energizing the appropriate breaker will remove power to the motor operated valve and associated local control circuitry eliminating the possibility that a single disabling fire could cause all service water returns to fail closed. In the event of a fire, the de-energized valve and its associated circuitry will fail "as is" allowing service water return at all times. The discharge valves can be manually operated.

Implementation of the above actions will be accomplished prior to restart.

Concerning the one-hour wrap deficiency in the service water valve room, a walkdown of the required conduit wrapping will be performed to ascertain all deficiencies.

All deficiencies will be eliminated prior to restart (see Finding 11 discussion).

This , finding is considered to be adequately resolved for restart with the completion of the above actions.

Many areas in the DB-1 station utilize partial versus full suppression. A review of all these areas will be performed consistent with the long-term actions in Section IV, Task 2. It is expected that an exemption request will be submitted.

Docket No. 50-346 License No. NPF-3

- Serial 986 Attachment 1 Page 24

10. One-Hour Fire Barriers - Test Report The NRC Audit Team identified that the adequacy of the '

Kaowool wraps was left as an open item with the following comments:

a. The test report in support of crediting the wraps as one-hour barriers was inconsistent and inadequate.

b. The test report did not address configurations exist-ing at Davis-Besse .

The test report provided by Bechtel provides different results for each configuration tested. The one-hour rating is consistent with Test No. 3B for Aluminum Open Ladder Cable Tray and Aluminum Conduct Wrapped with 2" Kaowool Blanket (Tight Rutt Joints). The closest tray and conduit configuration identified in the test report that is repre-sentative of the DB-1 fire barrier design, per FCR 79-032, is consistent with Test No. 2 - Steel Solid Bottom Cable Tray and Steel Conduit Wrapped with 2" Kaowool Blanket (Tight Rutt Joints). The results of this test indicate fifty (50) minutes of protection from a total engulfment fire. The test report provided by Bechtel adequately represents the DB-1 conduit fire barrier system, including the tray configurations cited in FCR 79-032 for trays ICJP10 and ICJP12, as contained in Rooms 303 and 304. It should be noted that all other Kaowool tray applications pertain to preventing the propagation of fires from within one tray to.another tray and do not attempt to protect the cables contained within these trays. All safe shutdown

~

circuits that require protection are identified in FCR 79-032 as being ir. conduit and the two (2) cable trays cited above.

As part of the corrective action program (see Section IV, Task 6) additional review of the adequacy of the test

- report will be performed to verify the acceptability of the Kaowool fire barrier wraps on cable trays and conduit in accordance with ASTM-119.

When identified, inadequate protection based on existing

- fire area / zone combus'tible loading will be modified to assure safe. shutdown capabilities.

Justification for. interim operation is based on the reasons cited below.

• All safe shutdown circuits that require protection ~in tray and conduit have passive fire barrier protection in accordance with FCR 79-032,

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Dockat No. 50-346 Liczase No. NPF-3 Serial 986 Attachment 1 Page 25

• No fire zone containing protected shutdown circuits in tray or conduit has a combustible loading exceeding 49,000 BTU /ft2 (equivalent 37 minute fire per NFPA Handbook, Section 6).

• These areas are protected by ionization type smoke detectors and automatic wet sprinkler suppression systems.

• The existing tray protection does provide some degree of fire protection yet not quantified.

• A one-man roving fire patrol will be continuously administered for all areas and zones containing protected safe shutdown circuits having a combustible loading greater than 20,000 BTU /ft 2(Rooms 053, 209, 304, 313, and 314). Rooms 304, 313, and 314 are radiation areas. Due to ALARA controls, a roving fire patrol is recommended for all rooms.

• The Bechtel test reflects total fire engulfment of cable tray. Existing fire suppression systems will preclude total fire engulfmeat of cable trays.

• All other Kaowool tray applications throughout the plaut will contain a fire generated within the tray and prohibit transfer to other cable trays.

This finding is considered to be adequately resolved for restart.

11. One-Hour Wraps - Installation The NRC Audit Team identified that the one hour wraps are incomplete, poorly installed, and not in accordance with the test installation.

FCR 79-032 identified those conduits and cable trays requiring Kaowool blanket wraps to provide fire protection to assure safe shutdown capability. A fire protection walkdown will be performed to the requirements of FCR 79-032

.to identify any deficient cable tray and conduit Kaowool wraps. Subsequent to this review, all identified missing wrap segments, if any, will be reworked to meet the FCR 79-032 requirements prior to restart. Appropriate Quality Assur-ance and Quality Control measures will be in place for this

. work. The walkdown results including a listing of the wrap 2 repairs performed will be forwarded to Region III for review.

Dock 2t No. 50-346 Licenza No. NPF-3 Serial 986 '

Attachment 1 Page 26 This finding is considered to be resolved for restart upon completion of the short term action.

To prevent future alteration of these protective barriers, an evaluation will be performed to determine how to prevent recurrence. The final solution will be discussed in TED's response to the Inspection Report.

12. Fire in the Auxiliary Shutdown (S/D) Panel A fire in the Auxiliary S/D panel may defeat the auxiliary feedwater turbine control from both the Aux. S/D panel and the control room.

A fire in the Auxiliary S/D panel will not require the evacuation of the control room and will not require the use of the auxiliary feedwater system. A plant shutdown would not result l' rom fire in the auxiliary shutdown panel, and normal feedwater would be available.

In the highly unlikely event that a loss of offsite power occurs concurrently with a fire in the Auxiliary S/D panel, then auxiliary feedwater pump turbine (AFPT) control from both the auxiliary shutdown panel and control room may be defeated.

A fire in the Auxiliary S/D panel while AFPT control is from the Auxiliary S/D panel may result in blowing the AFPT governor control circuit fuses in the disconnect switch cabinets CDE12A-1 and CDF12A-1. A fire in the Auxiliary S/D panel while AFPT control is from control room in

" auto-essential" mode may result in blowing the AFPT governor reritote control circuit fuses in the disconnect switch cabinets. If AFPT control is from control room in manual mode, no blowing of control circuit fuses will occur. If these fuses blow, AFPT control will not be possible from the control room.

In the event of loss of AFPT governor control, the governor will either control at the setting prior to the loss of power to the governor speed changer motor or control at one of the governor limit stops. If the governor continues to control at its previous setting, or controls at the high speed stop, then AFPT control will be accomplished by operating the AFPT steam inlet valves from the control room. The governor is normally on the high speed limit setting.

Docket No. 50-346 Liczn=e No. NPF-3 Serial 986 Attachment 1 Page 27 In the event that the governor controls at the low limit stop, then the start up feed pump powered from the essential busses, will be utilized in accordance with Procedure AB 1203.05.

Upon restoration of Auxiliary feedwater, the control room mode switch can be selected to manual and the appropriate AFPT governor remote control circuit fuses can be replaced by maintenance personnel to return AFPT governor control to the control room.

A review will be performed to investigate the possibility of correcting this problem. This occurs becarse cabling is routed through the Aux. S/D panel to the control room for permissive interlocks. Also, the OTSG level :ontacts are located internal to the Aux. S/D panel. If the cables for the permissive interlocks are rerouted, and if the OTSG 1evel contacts are relocated to the disconnect switch cabinets, then no loss of AFPT governor control would be experienced in the event of a fire in the Aux. S/D panel.

Based on the identified capabilities to supply feedwater given a fire at the auxiliary S/D panel, TED considers this finding to be resolved for restart.

This finding will be addressed in the long term actions (see Section IV, Task 5).

13. Diesel Fire Pump Test Procedure The Diesel Fire Pump Test Procedure was identified as not written nor performed in accordance with NFPA 20 require-ments for annual Fire Pump Flow Test.

NFPA requirements for Annual Fire Pump Tests as stated in NFPA 20, Sections 11-3.1 thru 11-3.3 require the pumps performance to be evaluated at peak loads. The peak load for the diesel fire pump at DB-1 is 3750 gpm at 150% of rated flow.

ST 5016.12 " Diesel Fire Pump Annual Flow Test" has been revised to include a 3750 gpm (150%) flow test as required by NFPA 20 Section 11-3. The 14th Edition NFPA Handbook is utilized by the Fire Protection Staff for additional guidance and not as a basis for test procedure format.

To determine the extent, if any, of the reduction in operating characteristic of the fire pump assembly (ref.

NFPA 20 11-3.3) the Original Acceptance Test TP 180.01 was

Dockat No. 50-346 License Ns. NPF-3 Serial 986

' Attachment 1 Page 28 modified and performed in part by the Fire Protection Staff. A pump performance curve was plotted and compared to both the manufacturer's shop test and the 1976 original acceptance test (ref. T-7314). Based on the results of the revised Original Acceptance Test, the pump was judged to be 6-7% below acceptable margins.

Inspection of both the diesel engine and pump shaft speeds indicated they were performing below manufacturer's design speed at all' flows with the exception of the 627 gpm flow test.

Conference with Maintenance personnel, the Fire Protection Staff, and the manufacturer of the Diesel Engine resulted in the conclusion that the Diesel Engine is operable.

However, it is in need of service outside the realm of routine periodic maintenance procedures. A manufacturer's representative has been scheduled to service the diesel engine, thus resolving NFPA 20 requirements as stated in Section 11-3.3 for deteriorated operating characteristics.

Even in the deteriorated condition demonstrated by T-7314 the Diesel Fire Pump meets and exceeds Surveillance Requirements 4.7.9.1.1.f.2 of the DB-1 Technical Specifi-cations, Appendix A.

TED does not run shut-off head tests on the Diesel Fire Pump. NFPA 20, Section 11-3 "Anr.ual Fire Pump Tests" does not require shut off head test performance during the Annual Flow Test. NFPA Handbook 14th Edition is once again used by TED only as a guideline. The Diesel Fire Pump at DB-1 is equipped with a full flow 2500 gpm relief valve.

This finding is considered to be resolved for restart.

Long-term commitment compatibility review will be performed (see Section IV, Task 3).

14. Fire Hose Stations Fire hose stations and stand pipes were identified as not

designed.in accordance with NFPA 14. Investigation by TED has shown that no commitment was made to design' stand pipes in.accordance with NFPA 14 except for sizing, spacing, and pipe supports. Requirements established in NFPA 14 are

. written for application by untrained personnel not by trained personnel such as those of the Toledo Edison Fire Brigade who utilize the equipment. The fire brigade is trained in the use and operation of the aforementioned fire

Dock:t Ns. 50-346 License No. NPF-3 Serial 986 Attachment 1 Page 29 suppression equipment. Consequently, the lack of pressure reducing devices presents no significant safety concern.

Further documentation regarding TED's commitments may be obtained by referencing Davis-Besse FHAR Table 4-1 (Sheet 33a).

This finding is considetud to be resolved for restart.

Long-term commitment compatibility review will be performed (see Section IV, Task 3).

15. Fire Door Modifications The NRC Audit Team identified that modifications were made to the fire door to room 320 with no documentation.

A preliminary walkdown of selected fire areas confirms that certain three-hour rated fire doors may have been modified using non U.L. listed hardware. The modifications to the fire doors were due to the installation of the card key access control system. Due to the low combustible loading in the affected areas and the nominal effects of the minor modifications identified, TED believes that the fire ratings of the doors in questions have not been signifi-cantly affected. The ultimate resolution of this issue shall be addressed in the long term program (see Section IV, Task 2).

16. Sprinkler System The NRC Audit Team identified that routing of water sup-pression below cable trays located near the ceiling is in violation of NFPA STD-13 and -16 and License Amendment 18.

The NRC conducted a plant tour in 1978 to review the adequacy and necessity of certain plant fire protection features. Based on that site visit and the subsequent meeting in Bethesda in October, 1978, the following sprin-kler system design criteria were derived and agreed upon for the Auxiliary Building:

• The sprinkler heads shall be positioned in such a manner that they will adequately control and/or extinguish a fire that could originate on the floor of the protected area and cause an -xposure to conduits, piping and/or equipment required for safe shutdown.

• The design of the sprinkler systems should consider the fire to involve transient combustible and external

Docket No. 50-346 Liesnse No. NPF-3 Serial 986 Attachment 1 Page'30

) ignition sources and not caused by electrically ori hinated fires in overloaded cables based on the fire tests which are discussed in Section 6 of the Fire Hazard Analysis Report.

• The sprinkler designs shall utilize sprinkler heads which.will respond quickly to thermal conditions.

• The sprinkler designs shall be supported seismically and analyzed for a moderate energy pipe crack in accordance with the criteria stated in NRC Branch Technical Position (BTP) MEB 3-1.

• The sprinkler systems shall be designed to the appli-cable portions of NFPA 13-1978.

• Heat collectors,.where applicable, shall be installed to assure reliable sprinkler actuation.

• Safety related equipment is required to be protected from inadvertent-sprinkler operation which could -

render equipment inoperable due to water spray.

In order to support the above general design criteria as dictated by the authority having jurisdiction * (NRC),

exceptions to portions of NFPA 13 were taken for the Auxiliary Building and Intake Structure sprinkler systems.

Therefore, generic justification for the sprinkler head placement'is provided below:

• The ceiling spaces of the various rooms which are sprinklered are heavily congested with large diameter piping, rigid steel conduit and steel cable trays with

! solid metal bottoms. The cabling in.the. cable trays have been fire tested and have been proven a non-g propagating fire retardant type. The tops of the cable trays are enclosed with a two (2) inch thick-Kaowool thermal blanket which has a one-half hour fire

(~ resistive rating. Conduits containing critical cabling required for shutdown are wrapped in a two (2) inch Kaowool thermal blanket. The Kaowool blanket

• The National Fire Protection Association does not approve, inspect or

. certify any installations, procedures, equipment, or material, nor does it approve or evaluate testing laboratories. In determining the acceptability of installations cr procedures, equipment or materials,.

the authority having jurisdiction may base acceptance on compliance with L ' NFPA or other appropriate standards. This note is a direct excerpt from NFPA Chapter 13, Paragraph 1-3.

l.

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Dock 2t No. 50-346 License Ns. NPF-3 Serial 986 Attachr4ent 1 Page'31 t

affords the conduit with a one-half hour fire resis-tive rating. The equipment located within the ceiling spaces is considered to be noncomburtible.

• With the sprinkler heads located near the ceiling as required by Chapter 4 of the NFPA 13-1978, inadequate sprinkler water distribution covering the floor would exist.

• The heavy congestion of piping, cable trays, and conduits in the ceiling space of the sprinklered rooms creates a false ceiling effect which could preclude heat from reaching sprinkler heads mounted at the ceiling level, thus causing delayed sprinkler actuation.

• The false ceiling effect created by the piping, cable trays and conduit congestion in the ceiling space creates an area of heat collection below the lowest level of cable trays and conduits.' This is shown by sprinkler response tests conducted by Union Carbide in July of 1973 for the U.S. Atomic Energy Commission under U.S. Government contract W.7405 eng. 26, Document V-JA-96. The sprinkler heads were equipped with heat collection canopies and were placed at-five (5) feet and seven (7) feet above the floor elevation.

The tests were conducted because of the complexity of

_ piping fixtures and structural interferences, as it was realized that it would be expensive and probably ineffective to install sprinklers near the ceiling as per the code.

The tests concluded that in most cases the sprinklers installed under canopies actusted faster than those not installed under canopies. However, when a high heat source was used the tests did demonstrate that the sprinkler position had little effect on the sprinkler actuation times and any slower buildup of heat, due to smaller fires which would result in a time delay of sprinkler actuation, would be compen-sated by' canopies.

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Dockat Ns. 50-346 Licenna No. NPF-3 '

Serial 986'

. Attachment 1 Page 32 l

• Based on the congestion in the ceiling spaces and the requirements to support the sprinkler pipe seismical-ly, the pipe supports had to be attached to wall (s) and/or the floor. This requirement and the congestion in ceiling space dictated the routing of the sprinkler piping, at an elevation approximately 7'-8' above the floor in most cases.

The sprinkler systems were hydraulically designed in accordance with NFPA 13-1978 and the calculations took into account the convoluted piping arrangement.

Grinnell Fire Protection Systems Company, Inc., was contracted by Bechtel to review the Auxiliary Building t

sprinkler and water curtain designs and associated hydraulic calculations, and give recommendations and guidance concerning the type of sprinkler head or water spray nozzles best suited for a specific appli-cation, considering the restrictions on the layout of various sprinkler heads and/or water spray nozzles.

In summation, it is considered that the best possible sprinkler design currently exists in the DB-1 auxiliary building.

. The long-term Task 2 performance will verify barrier and suppression system adequacy. Specific exemptions and/or 2 modifications may be proposed to ensure requirement compliance.

In addition, the American Nuclear Insurers (ANI) has found the Auxiliary B911 ding sprinkler system designs to be

!. acceptable for insurance coverage related to fire protection.

4 This finding is considered to be resolved for restart.

The long-term actions relative to NFPA-USAR commitment compatibility will be reviewed to reflect this information.

(See Section IV, Task 3)

17. Yard Hydrants and Valves No physical barriers exist around some yard hydrants / post indicating valves at DB-1.

J e

I -.

~

_ Dockst Ns. 50-346 Licznsa No. NPF-3 Serial 986' Attachment 1 Page 33 Review of NFPA 24 Section 3.34 depicts that " Post Indicator Valves shc11 be properly protected against mechanical damage where needed." Post indicator valves addressed during the.10 CFR 50 Appendix R audit are located within the protected area where vehicular traffic is held to a minimum and with few exceptions is monitored by the Nuclear Security staff. NFPA 24 Section 4-3.5 states that, "Hy-drants shall be protected if subject to mechanical damage."

.Again, hydrants identified during the 10 CFR 50 Appendix R audit are located within the protected area where vehicular traffic is held to a minimum. Additionally, all post indicating valves and hydrants utilized at the DB-1 are of the " breakaway" type. This type of valve stem is recog-nized by NFPA as designed such that failure of a valve stem will not affect the operability of the Fire Suppression System. This is identified as acceptable under NFPA.

Further protection from mechanical damage is not warranted.

This finding is considered to be resolved for restart.

Long-term commitment compatibility review will be performed (see Section IV, Task 3).

18. Fire Pump Test Z

The Diesel Fire Pump Test Procedure was identified as not written nor performed in accordance with NFPA 20 require-ments for annual Fire Pump Flow Test.

NFPA requirements for Annual Fire Pump Surveillance Tests as stated in NFPA 20, Sections 11-3.1 thru 11-3.3 require the pumps performance to be evaluated at peak loads. The peak load for the diesel fire pump at DB-1 is 3750 gpm at 150% of rated flow.

ST 5016.12 " Diesel Fire Pump Annual Flow Test" has been revised to include a 3750 gpm (150%) flow test as required by NFPA 20 Section 11-3. The 14th Edition NFPA Handbook is utilized by the Fire Protection Staff for additional guidance and not as a basis for test procedure format.

To determine the extent, if any, of the reduction in operating characteristic of the fire pump assembly (ref.

i

. \

Dock t No. 50-346 Liccn!c Ns. NPF-3 Serial 986  !

Attachment 1  !

Page 34 NFPA 20 11-3.3) the Original Acceptance Test TP 180.01 was modified and performed in part by the Fire Protection Sta ff. A pump performance curve was plotted and compared to both the manufacturer's shop test and the 1976 original acceptance test (ref. T-7314). Based on the results of the revised Original Acceptance Test, the pump was judged to be 6-7% below acceptable margins.

Inspection of both the diesel engine and pump shaft speeds indicated they were performing below manufacturer's design speed at all flows with the exception of the 627 gpm flow test.

Conference with Maintenance personnel, the Fire Protection Staff, and the manufacturer of the Diesel Engine resulted in the conclusion that the Diesel Engine is in need of service outside the realm of routine periodic Maintenance procedures. A manufacturer's representative has been scheduled to service the diesel engine, thus resolving NFPA 20 requirements as stated in Section 11-3.3 for deteriorated operating characteristics.

Even in the deteriorated condition demonstrated by T-7314 the Diesel Fire Pump meets and exceeds Technical Specifi-cation Requirements.

TED does not run shut-off head tests on the Diesel Fire Pump. NFPA 20, Section 11-3 " Annual Fire Pump Tests" does

, not require shut off head test performance during the Annual Flow Test. NFPA Handbook 14th Edition is once again used by TED only as a guideline. The Diesel Fire Pump at Davis-Besse is equipped with a full flow 2500 gpm relief valve.

In addition, the Fire Protection Staff in its efforts to review existing test procedures to insure their adequacy with applicable NFPA codes has incorporated vibration readings in ST 5016.08 " Electric Fire Pump Annual Flow Test", at all three levels of flow; 1250 gpm, 2500 gpm, and 3750 gpm, in accordance with NFPA 20.

This finding is considered to be resolved for restart.

\

D:ck:t No. 50-346 l Licenze Ns. NPF-3 Serial 986 Attachment 1 Page 35 Long-term commitment compatibility review will be performed (see Section IV, Task 3).

19. -Control'of Combustibles The control of transient combustibles is adequately demon-strated in Maintenance Procedure MP 1410.75.

. Administrative implementationlof MP 1410.75 provides for a continuous evaluation of transient combustibles for each safety-related room or area of the plant. Attachment 3 -

(Combustibles for Work Activity) of Procedure MP 1410.75 has provision for continual monitoring of transient combus-tibles based on the premise that appropriate sign off's are demonstrated for addition and removal of transient combus-tibles based on:

i

a. the scope of the work activity,

b. the time duration and sign off's indicating removal of transieat combustibles after individual maintenance or modification activities.

Additional control of transient combustibles is demonstrat-ed in AD 1810.01 " Control of Combustibles and Ignition

. Sources". It is the policy of the Fire Protection Staff at Davis-Berse to conduct routine periodic inspections of all areas listed in AD 1810.01.Section 1, to ensure that good

. housekeeping policies are enforced in accordance with AD 1835, " Plant Cleanliness Inspection Program". Training programs are currently being developed to train personnel associated with maintenance and modification activities, i

This will ensure their understanding of the Transient Combustible Control Procedure and the necessity of complet-ing' Attachment 3 of the procedure. MP 1410.75 will be in

place on or before November 1, 1983.

The level of transient combustibles maintained in safety-related areas at DB-1 is held to'a minimum. Pre-implementation studies performed in accordance with

.2 MP 1410.75 indicate transient combustible levels at DB-1 to be below 10,000 Btu's/ft 2 in each fire zone. This study was performed during the week of September 5,1983. The amount'of allowable transient combustibles specified in 1

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Docket -No. 50-346 Liczaza No. NPF-3 Serial 986 Attachment 1 Page 36-Item 7 is the maximum allowable fire loading based on the suppression system ability to remove heat. This guideline is in no way intended to allow transient combustible loading of this magnitude to be brought into any safety-related area of the plant, but to identify the capacity of a 0.3 design density suppression system's ability to remove heat. should combustion of transient type material occur.

The level of allowable transient combustibles in locations 2 not having fixed suppression systems will be held below 40,000 BTU's/ft2 or additional fire suppression equipment will be brought into the area. The level of transient fire loads will be held to levels such as 40,000 - 80,000 BTU's/ft 2 as recommended by MP 1410.75 and by the fire protection staff. Additionally, in practice the 10,000 BTU's/ ft 2 operating level will more closely be maintained. <

This finding is considered to be resolved for restart upon completion of the short term action.

Long term commitment compatibility review will be performed (see Section IV, Task 3).

20. Fire Protection System Flush The NRC Audit Team identified that the fire protection system flush and valve operation is performed every three years instead of every year as required by NFPA.

NFPA requirements for valve operation indicate that for good testing policies, valves should be cycled at least once per year. Review of ST.5016.10 " Fire Protection System Valve Surveillance Test" shows that each Technical Specification and non-Technical Specification valve in the flow path'is cycled through at least one complete _ cycle of

-full travel annually. This surveillance test is performed

,. in accordance with NFPA Handbook; Section 11.G Chapter 2,

14th Edition.

NFPA requirements for Fire Protection Flushing indicates that underground lead-in connections to system risers shall be flushed at least annually. This test is currently

. performed in accordance with NFPA requirements as stated in NFPA 15 Section 6-2.9 as referenced in ST 5016.16 " Fire

Dock:t No. 50-346

- .Licznza No. NPF-3 Serial 986 Attachment 1 Page 37 Protection System' Flush". Records are available demon-

.strating performance of this' test.

This finding is considered to be resolved for restart.

21. Fire Detector Maintenance The NRC Audit Team identified that dust accumulation requires photoelectric detector adjustment. Procedures do not address this.

Fire detection maintenance and demonstration of operability at DB-1 is performed in accordance with NFPA 72D and manufacturer's recommendations. Reference of all applica-ble manufacturers operation and maintenance manuals is supportive of the fact that current DB-1 maintenance procedures are sufficient and no further action is neces-sa ry. 'In the case that excessive amounts of dust are present in the environment surrounding detectors at DB-1, degraded performance of the detector is not experienced.

Increased sensitivity of the detection system accompanies increases in the amount of dust present in the surrounding environment. NFPA clearly states that maintenance practic-es are left up to the authority having jurisdiction.

Current policy at DB-1 is to replace detectors which give inaccurate detection.

This finding is considered to be resolved for restart.

Long term commitment compatibility review will be performed (see Section IV,_ Task 3).

22. Fire Door and Damper Maintenance i

The NRC Audit Team identified that procedures for fire doors and damper maintenance identified no surveillance from 1978 until recently. NFPA requires a monthly visual l check as a minimum.

l -Prior tr 1981, surveillance testing was not performed on fire dampers. A new Technical Specification concerning g testing of-fire doors, penetration barriers, and fire

! dampers was transmitted to the NRC for-their approval in May, 1981, via FCR 80-265A. This transmittal addressed the l

Dockst Na. 50-346 Licznsa No. NPF-3 Serial 986 Attachment 1 Page 38 requirements of NRC letter dated September 23, 1980 (Log No. 609), and complied with NRC requests concerning TED, NRC letter dated December 26, 1980 (Log No. 669). Since May, 1981, all fire dampers that have been tested have been 2 done so in accordance with this yet to be approved Techni-cal Specification above and beyond any existing requirements.

A newly issued procedure (ST 5016.11, Rev. 1) is currently-being implemented for the first time to address surveil-lance testing of fire barriers, fire doors, and fire dampers. It will be implemented by restart. Test results

will be available for review upon completion of the sur-veillance test. NFPA 80 requirements indicate that period-ic inspection and maintenance programs should be implemented and should be the responsibility of property management.

A monthly preventive maintenance program has been in effect since 1981 to assess the operability of fire doors at DB-1.

The implementation of surveillance cesting based on the yet to be approved Technical Specification and the program of I monthly preventive maintenance activities as addressed in generic maintenaree work orders demonstrates TED's good faith effort to adequately verify the operability of fire barriers, fire doors, and fire dampers.

This finding is considered to be resolved for restart upon j completion of the short term action.

Long term commitment compatibility review will be performed

- (see Section IV, Task 3).

23. Emergency Lighting - Surveillance The NRC Audit Team identified that procedures should be revised to perform surveillance quarterly instead of semi-annually.

The periodic test currently in place for the maintainabili-

-ty of the Emergency Lighting ~ (EL) units has incorporated all identified manufacturer's recommendations. These actions include measurement of electrolyte level, 90 second

r

~

Dockst Mo. 50-346 Licenza No. NPF-3 Serial 986 Attachment 1 Page 39 burn test, subsequent fast charge and then return to trickle charge verification and a thorough cleaning.

In addition to these surveillance actions, a battery _ life determination will be made and then factored into the battery replacement schedule.

TED has planned to replace all batteries on the emergency lighting units of the older type that have failed the eight hour burn test performed during the audit. Prior to replacement, units of this type will be selected at random and an eight hour burn test will be performed. This will act as baseline information for determining battery life.

Additionally, maintenance will begin random sampling all of the remaining EL units beginning October 1, 1983, and perform.eight hour burn tests on these as well. Based on the results of this study, a guideline will be established to indicate the optimal replacement time for lighting units at DB 1. TED believes that the results of this study will provide a better indication of the need to replace batter-ies than by performing surveillance testing on a quarterly basis. TED will continue to conduct surveillance testing in accordance with manufacturer's specifications until this study is completed. Long term actions will be considered resolved at this point (see Section IV, Task 4).

This finding is considered to be resolved for restart.

24. Off-Site Fire Department Training Review of the existing level of training and responsibility delineation for off-site fire department assistance was determined to be inadequate. Our understanding of this finding is that the offsite fire department by State law is charged with taking control of the situation upon their arrival. The training was deemed inadequate assuming that the offsite agency did not use in plant fire brigade advice to fight the fire. TED does not agree that the offsite agency will not use the fire brigade input in fighting the fire.

The training programs in effect at DB-1 are indicative of the fact that the DB-1 Fire Protection Staff is aware of e - ,- , , . , - .,_m-, -,,,,i,w., . .- , . - - - - _ ,--p,y r+_-. , -,-

Docket No. 50-346 License No. NPF-3 Serial 986 Attachment 1 Page 40 the special requirements for fighting fires in a nuclear environment and takes every precaution to ensure adequate training of offsite fire departments.

It is our understanding this deficiency concerns the inadequacy of the auth2rity and responsibility delineations of the offsite fire personnel.

2 The Emergency Plan Section 8.1.1 will be revised to depict the role of offsite fire departments when responding to fires at DB-1. The letter of mutual aid will be revised prior to startup to ensure conformance of offsite fire departments with the revised Emergency Plan and its impli-cations of authority, jurisdiction, direction of offsite fire departments by the Davis-Besse fire brigade.

This finding is considered to be resolved upon completion of the short term action. The Emergency Plan revision will 2 be implemented by November 1,1983.

25. Welding Permits The NRC audit team found that welding permits are not to be issued for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required in NFPA 51 and 51B, and that weekly permits are allowed at Davis-Besse.

We have reviewed NFPA 51B and the Fire Protection Handbook, 14th Edition, and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> minimum requirement as stated by the audit team does not exist. NFPA 51B requires the area where welding is to be permitted to be inspected by the individual responsible for authorizing the welding operations to ensure that it is a firesafe area. NFPA 51B states, "This individual shall designate precautions to be followed in granting authorization to proceed, preferably in the form of a written permit. (A suggested form of written permit is shown in Appendix A. It may be modified to suit conditions.)" The form has an entry for designated as " permit expires".

- DB-1 allows weekly permits during periods of heavy activi-ties such as during outages, and during periods of non power production (Modes 2 through 6 as specified in the Technical Specifications). Otherwise, during power production

W Dockst Ns. 50-346 Lic:nsa No. NPF-3 Serial 986

' Attachment 1-

-Page.41

~ '

(Mode 1),' 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> welding permits are used. The current level of controls and durations are considered acceptable.

This finding is considered to be resolved.

2

26. Sprinkler Teats, The NRC_ Audit Team identified that the 1980-1983 sprinkler tests are inadequate relative to NFPA.

Review of NFPA requirements to DB-1 test procedures indi-cates the necessity to revise the " Diesel Fire Pump Annual Flow Test" Procedure ST 5016.12. The test was revised as discussed in response to finding 13. The two inch drain test is run in accordance with NFPA 13A on all sprinkler systems at'the plant (ref. ST 5016.07). In addition to the two" inch drain test, the Inspector's test as referenced in NFPA 13A is run on all wet sprinkler systems installed in the plant on an annual basis.

This finding is considered to be resolved for restart.

Long term commitment compatibility review will be performed (see Section IV, Task 3).

27. Off-Site Contractors Fire Watch Training The audit team indicated that offsite contractors were inadequately trained as fire watches.

Davis-Besse Fire Protection Staff reviewed training pro-grams of offsite contractors as fire watch and has identified the lack of hands-on training for offsite contractors. Current levels of training include:

' presentation of industrial fire safety films

• presentation and explanation of AD 1844.07 Maintenance "Open Flame, Welding,. Grinding and Cutting Permits"'

• AD 1810.01 " Control of Combustibles and Ignition Sources" m

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Dockst Ns. 50-346 Licensa No. NPF-3 Serial 986 Attachment 1 Page 42

• Standing Order No. 30, the Blocking of Penetration

~ Fire Barriers, Fire Doors, and Negative Pressure

, -Doundary Doors.

• Fire extinguisher training to include (a) matching extinguishers to the hazard, .(b) the correct method of using portable fire extinguishers, Land (c) the opera-tion and use of fire extinguishers.

. All appropriate TED employees utilized as fire watch or fire brigade receive thorough hands-on training. The lack of hands-on training for offsite contractor personnel is directly correlated to finding 28, which addresses the lack of trained and qualified manpower to perform such evolu-

.tions. A hands-on program has, in the past, been performed by individual contractors performing maintenance or modifi-cation activities on site. This program was discontinued eliminating _ training as specified in NFPA-51B.

Hands on training in accordance with NFPA SIB will be accomplished prior to restart for all offsite contractor personnel involved in welding, grinding and burning activi-ties. On-going hands on training for all personnel associ-

.ated with these activities will be performed on a periodic basis. All TED personnel involved in these activities have 2 previously had. training in accordance with NFPA 51B.

Delineation will be made between fire watch and fire barrier watch personnel. Personnel will be trained in accordance with their activity functicn. This delineation will be accomplished in accordance with administrative procedures currently under development (ref. AD 1810.00,

Rev.16). .. Procedure implementation is scheduled for November 1, 1983.

This task action will be additionally addressed in the response to audit finding 28.

. Long teta commitment compatibility review will be performed (ree Section IV, Task 3).

s

I

Docket Na. 50-346 l

• ~

. Licznse No. NPF-3 o Seria] 986 Attachment 1

.Page 43  ;

28. Fire Protection Staff The NRC audit team stated that the fire protection effort appears understaffed relative to Administrative Procedure AD 1810.00 and License Amendment 18.

The full-time Fire Protection Coordinator has been on the Toledo Edison staff in that position at DB-1 in excess of three years. The fire protection engineer position is filled by a consultant as designated in the Fire Hazards Analysis Report, Volume I, Section 1.

The Toledo Edison Company currently maintains that suffi-

.cient manpower exists to address the fire protection program. This conclusion may not have been apparent to the audit team due to.the dispersion of duties among various-TED personnel. In lieu of the audit finding, however, the Toledo Edison management responsible for Davis-Besse has

-directed that the staffing required to support fire protec-tion activities be're-studied. This will ensure that all the. requirements of the fire protection program, as well as all the short-term actions and the long-term Appendix R review programs are directed, monitored and followed through to completion, A review of personnel responsibilities will be performed to determine whether additional staff is needed and when.

This study will be reviewed by the Vice President, Nuclear.

Toledo Edison management is dedicated to providing a

. quality fire protection staff with responsibility for the fire protection activities as defined in Administrative Procedure AD 1810.00.

Further clarification of this item will be provided in cur response to the Inspection Report.

t

29. High/ Low Pressure Interfaces All valves including the Pdcar Operated Relief Valve and the Letdown Cooler Isolatig2 Valves are subject to spurious actuation in the event of a fire in the Control and/or Cable Spreading Room.

Dockst No. 50-346 Licznme No.'NPF-3 Serial 986-Attachtent 1.

Page 44 The long-term generic actions are described in Secticn IV, Task 5.

The PORV block valve (HVRC11) can be isolated by discon-necting the control circuits at disconnect switch CDE16B and utilizing the pushbutton at the MCC BE 1602. The TED action will be to utilize existing procedures to close and de-energize the PORV block valve at the appropriate motor control center. In addition, the motor-operated letdown containment isolation valve will be closed and de-energized from the appropriate motor control center.

This finding is considered to be resolved far restart.

IV.

CORRECTIVE ACTION PROGRAM-1 A two phased' approach has been initiated by TED to respond to the NRC fire protection audit findings.

The first phase is a short-term program of corrective actions which is already underway, as described in Gection III, to address the NRC audit findings and to provide the basis for startup and operation of t' DB-1.

2l TED considers twelve (12) out of the twenty-nine (29) audit findings to be resolved in the short-term (prior to restart). The resolved findings are listed below.

i- Finding No. Item 5 Fire Doors I Diesel Fire Pump Test Procedure 13*

14* Fire Hose Stations 16* Sprinkler System 17*: Yard Hydrants and Valves 18* Fire Pump Test 20* Fire _Yrotection System Flush 21* Fire Detector Maintenance 2 22* Fire Door and Damper Maintenance 25* Welding Permits 26* Sprinkler Tests 27 Off-Site Contractors Fire Watch Training In. addition to the short-term actions, a number of compensatory .

actions have been taken by TED in lieu of meeting the NRC audit

. . findings related to Appendix R on an interim basis. The compensatory actions are summarized in Attachment 2.

• Resolved except'for NFPA, USAR, FHAR, Tech Spec compatibility review

~

(Task 3).

Dacket No. $0-346 Lic:n:2 No. HPF 3 Serial 986 Attachment 1 Page 45 The accond phase is a longer-term generic review program which will involve performing and documenting additional Appendix R analyses (Appendix R, Sections III.G, J, 0, and L as clarified by NRC Generic Letter 81-12). The longer-term program includes the actions neces-sary to supplement and address certain NRC fire protection audit findings. Any design or procedural modifications that may be identi-fied from the analyses will be implemented, or exemptions requested.

A summary of the specific longer-term tasks of this program, as defined to date, and a schedule for their completion, are:

Task 1. Safe Shutdown Systems Identification Minimum systems, components and circuits required for hot standby and for cold shutdown will be identified. Associ-ated circuits whose damage could affect shutdown capability as defined in Generic Letter 81-12 will be included.

The systems, components and circuits identified will be located in the plant. Fires will be postulated in each fire area / zone and the fire protection features for the systems, components and circuits will be evaluated against the requirements of Appendix R,Section III.G.2.

Review of.the isolation cf circuits between the Auxiliary Shutdown Panel and the control room / cable spreading room will be included in this task.

Systems, components and circuits required for hot standby and cold shutdown will be identified by October 17, 1983.

The fire protection evaluation against requirements of Appendix R is scheduled for completion by January 31, 1984.

Task 2. Fire Hazards Analysis Report (FifAR) - Appendix R Review Revision 6 of the DB-1 FHAR will be reviewed against the requirements of 10 CFR 50 Appendix R, Sections III.G, J, O and L. Revisions resulting from Task I will be incorporat-ed in the FHAR. Feedback will be provided to upgrade the interim procedures when information affecting the proce-dures becomes available.

This effort is scheduled to be completed and submitted to the NRC for review by January 31, 1984.

A generic review of the instrumentation will be performed to identify the extent of conformance to the alternative shutdown capability requirements of Appendix R,Section III.L.

Dock 2t No. 50-346 License Ns. NPF-3 Serial 986 Attachment.1 Page 46

+-

Recommendations concerning modifications and/or exemptions will be made.

This review is scheduled to be completed by January 31, 1984.

Task 3. Fire Hazards Analysis Report - Compatibility Review j A review will be performed to ensure commiuaent capability

. between the DB-1 Fire Hazards Analysis. Report (including referenced documents), the' National _ Fire Protection Associ-ation Code, the updated Final Safety Analysis Report and the DB-1 Technical Specifications.

This effort is scheduled to bc completed by November 30, 1983.

Task 4. Emergency Lighting Review Areas requiring emergency lighting will be identified.

This will include the areas for whica. operator actions are required as well as access and egress routes from the control room to the Alternate Shutdown Panel and from the Alternate Shutdown Panel to other locations in the plant.

Based on the identification of areas, the existing plant Emergency Lighting System will be evaluated for compliance to Appendix R Section III.J.

This review is scheduled to be completed by November 30, 1983.

. Task 5. Associated Circuit Analysis A review will be performed of the TED 1975-1976 engineering inspectior, of channel separation at DB-1 to determine 1 consistency with the guidelines provided in Appendix R Sections III.G and L, Generic Letter 81-12, and the clari-fication letter to the Generic Letter. Existing TED analyses will-be upgraded, as necessary, to meet the

.' aforementioned guidelines.

This review and analysis is scheduled to be completed by

~ January 31, 1984.

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Dockst Ns. 50-346 Licznse No. NPF-3

' Serial 986 Attachment 1 Page 47 Task 6. One-Hour Barrier Review A one-hour barrier review will be conducted'to verify the adequacy of the one-hour barriers in the plant where they are necessary to meet the requirements of Appendix R,Section III.G.2.C. Included in this review will be (1) the evaluation of the acceptability of Kaowool as a one-hour barrier as used in the plant, (2) the adequacy of the installed one-hour barriers with respect to completeness and test documentation.

This review is scheduled to be completed by December 16, 1983.

Task 7. BTP aPCSB 9.5.1 Review A review will be performed of compliance with previous commitments made to BTP APCSB 9.5.1 and appropriate NRC Supplemental Guideline Documents for fire protection.

This review is scheduled for completion by November 30, 1983.

Task 8. Fire Protection Manual Preplans Review The Fire Protection Manual Preplans will be reviewed to ensure that: (1) they are complete for all fire areas /

zones identified in the FHAR, (2) individual preplans are accurate, (3) any identified deficiencies in the preplans have been resolved, and (4) the procedure to achieve hot standby and cold shutdown is compatible with the fire preplans and revisions thereto. Any revisions to the preplans will be made subsequent to this review and will include all impacting inform. tion identified through the performance cf the other actions and long-term tasks.

This review is scheduled for completion-by April 30, 1984.

The schedule for'any procedure or document revisions, for plant modifica-tions, or for submittal of exemption requests to the NRC will be identi-fied as the specific evaluations are completed.

DBP 4328EE/1-47 l

Dock t Na. 50-346 tLiernsa Na. NFF-3 Serial.986

-Attechnent 2 . ACTION

SUMMARY

Itgr 1 To Be Considered Completed Interim Finding .

Prior To Compensatory Na. Finding Action Restart Action Comments

1. Alt Shutdown Capability / Hot' Standby 1.1 Interim procedure developed X Being revised incorporating '

NRC comments to be for-warded to NRC 9/13/84.

Cover sheet forwarded when signed off 1.2 Operators classroom training X complete

,' 1.3- Operators walkdown training X Resident Inspector to verify complete

.J 4

1.4 Procedures implemented X- Resident Inspector to verify

-1.5 RC54 pressure gauge installed- )( Complete at time of're-audit

• L .

1.6 Required repair equipment X Complete at time of re-audit *

!" 2 verified i

1.7' Wiring requiring modification X during procedure permanently marked 1.8 _ Staffing verified onshift X X Additional staff agreed upon during re-audit *

' 1 '. 9 . Revalidation of procedure Tasks 1 and 2 after long-term Tasks I' Systems-Oct. 17, 1983 and'2" . Evaluation-Jan. 31, 1984 1.10 Associated circuits Task 5 analysis ~ Jan. 31, 1984 1.11 Preplan validation X Preliminary validation to ensure against identified problems completed Task 8~- Long-term review April 30, 1984

-2. JAlt Shutdown Capability / Cold Shutdown 2.1 Interim procedure developed X Being ' revised incorporating NRC comments to be for-2' :2 warded'to NRC 9/13/84.

Cover sheet forwarded when signed off.

L *Re-audit performed September 7-9,J 1983.

~

_ . _ - - _ _ _ _ _ _ _ = _ - _ - _ - _

Dock:1. Ns.'50-346

• Lic nso Ns. NPF-3

-S2 rial 986 Attachment 2 ACTION

SUMMARY

P;g2 2 To Be Considered Completed Interim Finding .

Prior To Compensatory Ns. Finding Action Restart Action Comments

2. ' Alt Shutdown Capability / Cold Shutdown (Cont.)

2.2 Operators classroom training X complete 2.3 Operators walkdown training X Resident Inspector to complete verify 2.4 Procedures implemented X Resident inspector to verify 2.5 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time requirement File for exemption exemption rcquest Oct. 1, 1983 submitted 2.6 Revalidation of procedure Tasks 1 and 2 after long-term Tasks 1 Systems-Oct. 17, 1983 and 2 Evaluation-Jan. 31, 1984 2.7 Associated circuits Task 5 analysis Jan. 31, 1984 2.8 Preplan validation - Preliminary validation to ensure against identified problems completed Task 8 - Long-term review April 30, 1984 2.9 Ensure dedicated repair Task 2 equipment identified Jan. 31, 1984

-3. Auxiliary Shutdown Panel 2 3.1 T and T interim c

X X Complete at time of re-audit *'

h readout capability 3.2 Source range flux, T and Task 1.

c ThPern.anent resolution Resolution identifica-tion and schedule provided Jan. 31, 1984 3.3 Permanent sampling and X X Per re-audit comment move 2 valve line.ap procedures up in time in procedure for reactivity monitoring to immediately following plant stabilization

• Re-audit performed September 7-9, 1983.

Docket Ns. 50-346 ELic;n:2 No. NPF-3

-S; rial 986 Attechment 2. ACTION

SUMMARY

-Peg 2 3-To Be Considered Completed Interim Finding- Prior To Compensatory N2. Finding Action Restart Action Comments

4. Emergency Lighting Design 4.1 Normal lighting X X Complete et time of re-audit *-

re-energizing from essential bus integrated into procedure

4.2 Battle lanterns availabic X X Complete at time of re-audit

• 4.3 Lighting walkdown maxi- X X Resident Inspector to 2 mizing illumination verify 4.4 Emergency lighting review Task 4 to App. R,Section III.J Nov. 30, 1983 4.5 Final confirming emergency Task 2 lighting review Janua ry 31, 1984 4.6 D.C. lighting exemption Task 2 request filed January 31, 1984

~5. ' Fire Doors 5.1 Resolution on NRC X Resolved for restart

-2 identified doors Barrier review and verification - Task 2 Janua ry 31, 1984

6. Reactor Coolant Pump Oil Collection System 6.1 File for-exemption request, File for exemption RCP oil collection system Oct. 1, 1983

7. Housekeeping 7.1 Transient loadings verified X Complete at time of re-audit

• 2 7.2 Transient combustible Procedure implemented by procedure implementation Nov. 1, 1983

8. Fire Damper Inoperability 8 .1.- LER processed X Complete at time of re-audit

• 2 8.2 Surveillance Tests (ST) X Complete at time of re-audit *

-reviewed

• Re-audit performed September 7-9, 1983.

__ i

Docket N3. 50-346

'Lic:nsa N1. NPF-3

-S; rial 986 Attschment 2 ACTION

SUMMARY

P;g2 4 To Be Considered Comp 1cted Interim

-Finding Prior To Compensatory No. Finding Action Restart Action Comments

8. Fire Damper Inoperability (Cont.)

28.3 Surveillance Test X Verified acceptable at Revision re-audit

• 8.4 . Surveillance Test portions X Test performance >90%

re performed complete at re-audit,*

Completed retesting on 9/10/83; Resident Inspector to verify 8.5 Testing to continue on all fire Schedule to be in place 2

dampers, post restart action and analysis complete by

. plan and schedule being November 30, 1983 develcped through engineering analysis for testing of all dampers.

8.6 Accelerated test program' To be included with analysis

' developed to identify long- by November 30, 1983 term maintenance and sur-veillance schedule 8.7 Applicable records X Complete at time of re-audit

• available for audit

9. . Service' Water Discharge Valve Room 9.1 Resolution of discharge X Complete at time of re-audit,*

2 valve deficiency by full procedure implemen-revised procedure tation to be verified by Resident Inspector 9.2 One-hour wrap deficiency See Finding Action 11 resolution

' 9.3 . Partial vs. full-sup- Task 2

'2 pression resolution Jan. 31, 1984 (possible exemption (when information request) is available)

10. 'One Hour Fire Barriers - Test Report 10.1 Kaowool wrap accept- Task 6 ability review Dec. 16, 1983

• Re-audit performed September 7-9, 1983.

Dockat No. 50-346

• Lic:nna No. NPF-3 Ssrial 986

~Attrchment 2 ACTION

SUMMARY

P2g2 5 To Be Considered Completed ~ Interim Finding Prior To Compensatory No. Finding Action Restart Action Comments

, mm

10. One Hour Fire Barriers - Test Report (Cont.)

10.2 Fire barrier watches in X X Fire barrier watches will

.2 place in high combustible be removed when analysis loading areas and/or modifications verify system adequacy

11. One Hour Wraps - Installation 11.1 Presently installed X X Wrap upgrade 90% complete 2 required wrap walkdown, at re-audit.* Forward wrap reinstallation, repair deficiencies found listing to F. Maura, Region III upon completion Task 6 - Long-term review Dec. 16, 1983 2 11.2 Administrative controls Final resolution will on wraps in place be provided in response to the Inspection Report-

'12. Fire in the Auxiliary Shutdown Panel (ASP) 12.1 Auxiliary feed pump X X Complete at time of re-audit

• 2 turbine circuitry resolution 12.2 Associated Circuits Analysis Task 5 Jan. 31, 1984 12.3 Perform review of affect of Will incorporate findings 2 fire in ASP on all controls and prioritize'into Task 5, and instrumentation Jan. 31, 1984

13. Diesel Fire Pump Test Procedure 13.1 NFPA-USAR compatibility Task 3 Nov. 30, 1983

, 2 13.2 Full procedure deficiency X Complete at time of re-audit

• identification 13.3 Procedure rectification X Complete at time of re-audit

• 13.4 Manufacturer's represen- Scheduled tative inspection and adjustment

• Re-audit performed September 7-9, 1983.

6 Dock;t N3. 50-346

'Lic:nsa Na. NPF-3

~Sarial 986 Attachment 2 ACTION

SUMMARY

Pzg2 6 To Be Considered Completed Interim Finding .

Prior To ' Compensatory No. Finding Action Restart Action Comments

14. Fire-Hose Stations 14.1; NFPA-USAR compatibility Task 3 Nov. 30, 1983 14.2~ Finding review and

~

2 X Complete at time of re-audit

• resolution

'15. Fire Door Modifications 2 15.1 Resolution of door Task 2 - Fire barrier deficiency verification Jan. 31, 1984

16. Sprinkler System 2 16.1' Sprinkler deficiency X Complete at time of re-audit

• resolution Design review and jutifica-tion, Task 2, Jan. 31, 1984 16.2 NFPA-USAR. compatibility. Task 3 Nov. 30, 1983

17. Yard Hydrants and Valves 2 17.1 Yard hydrant, and valves X Complete at time of re-audit

• resolution 17.2 NFPA-USAR compatibility Task 3 Nov. 30, 1983

18. Fire Pump Test 18.1 See deficiency 13 2' 18.2 Vibration reading X Complete at time of re-audit

• incorporation i

18.3 NFPA-USAR compatibility Task 3  !

Nov. 30, 1983

19. Control of Combustibles

.19.1 See deficiency 7

• Re-audit performed September 7-9,-1983.

_ ~--

-o

Dbckzt'No. 50-345-Licance No. NPF-3.

S; rial 986

Attschment 2 ACTION

SUMMARY

-P2g2 7 To Be Considered Completed Interim

. Finding Prior To . Compensatory No. _ Finding Action Restart Action Comments l20. Fire Protection System Flush 2 20.1 System flush deficiency X Complete at time of re-audit

• resolution-20.2 =NFPA-USAR compatibility Task 3 Nov. 30, 1983

21. Fire Detector' Maintenance 2 21.1 . Detector maintenance X Item discussed; considered deficiency resolution resolved for restart

22. . Fire Door-and Damper Maintenance 2 22.1 Issuance of new procedure X Complete at-time of re-audit

• 22.2 NFPA-USAR compatibility Task 3 Nov. 30, 1983

23. Emergency Lighting - Surveillance 123.1 -NFPA-USAR compatibility Task 3 Nov. 30, 1983 2 23.2 Manufacturer's recom- X Complete at time of re-auditt mendations revier i

23.3- Batteries replaced- Jan. 31, 1984 1

23.4.'-Random sampling- Jan. 31, 1984 completed 23.5 Replacement schedule Jan. 31, 1984 established, Sur-(veillance Test revised

~

24. Off-Site Fire Department Training 24.1 Off-site. personnel X- Complete at time of re-audit

• training: resolution 2

24.2 -Off-site responsibility X Emergency plan to be fully.

delineation' revised by November 1, 1983 1

4 j

.*Re-audit performed Septemb'er 7-9, 1983.

o bocket Ns. 50-346 LicInna No. NPF-3 Serial 986 I TAtt:chment 2 ACTION

SUMMARY

Pcge:8 To Be Considered Completed Interim

. Finding Prior To Compensatory No. Finding Action Restart Action Comments

25. Welding Permits 25.1 NFPA-USAR compatibility Task 3 Nov. 30, 1983 2 25.2 Welding permit defi- X Complete at. time of re-audit

• ciency resolved .s s

26. Sprinkler Tests 2 26.1 Test resolution X Ccaplete at time of re-audit

• 26.2 NFPA-USAR compatibility Task 3 Nov. 30, 1983

27. Off-Site Contractors Fire Watch Training 2 27.1 Fire watch training X All fire watch training resolution in accordance with NFPA will be complete prior to restart. Full procedure implementation will be accomplished by Nov. 1, 1983 27.2 NFPA-USAR Compatibility Task 3 Nov. 30, 1983

28. Fire Protection Coordinator Staff 28.1 Fire protection staff Jan. 31, 1984 resolution

29. High/ Low Pressure Interfaces 1

2 29.1 Specific deficiency X Complete at time of re-audit

• resolution.

29.2 Associated' circuits Task 5 analysis Jan. 31, 1984 N/A Additionally requested Task 7 BTP APCSB 9.5-1 review Nov. 30, 1983 N/A Preplan review Task 8 Apr. 30, 1984 DBP 4328EE/49-56

• Re-audit performed September 7-9, 1983.

_ _ -