ML20129A315
| ML20129A315 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/09/1985 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-514, NUDOCS 8506040537 | |
| Download: ML20129A315 (15) | |
Text
m._
-y e
Docket No. 50-346 TOLEDO EDISON License No. NPF-3 Serial No. 1-514 RiCHARO P. CROUSE
- u. pram May 9, 1985
$ 322, PRIORITY ROUTING b
j$ [
Mr. James G. Keppler, Director M-iA]y-
~
Unites States Nuclear Regulatory Commission Region III
-t_ _
799 Roosevelt Road fi(
37-Glen Ellyn, Illinois 60137
' W.i FILE 4
Dear Mr. Keppler:
The Toledo Edison Company submitted to you on September 13, 1983, (Serial No. 986) a detailed plan for resolution of findings identified during the July 25-29, 1983 Fire Protection Audit. The audit was conducted by members of your staff at the Davis-Besse Nuclear Power Station, Unit 1 (DB-1).
Since that time Toledo Edison has acted aggressively to systematically
~
identify the full extent of the Fire Protection deficiencies with regard to our commitments and to implement activities aimed at resolving them.
t Toledo Edison's aggressive program has consisted of short and long term actions to resolve specific, as well as generic, fire protection program.
deficiencies. A significant expenditure of resources has been committed to implement such a program.
This resource allocation, and the need for Toledo Edison to assure it's resources were being applied appropriately, necessitated reviewing certain identified tasks with the findings identified in the Fire ~ Protection In-spection Report. This review was required prior to final task implementa-tion.
The status and/or results of these tasks were then identified to be sub-mitted to the NRC with the Toledo Edison response to the inspection report, Toledo Edison letter, Serial No. 1042, dated April 16, 1984.
On September 5, 1984, the Toledo Edison Company received the Nuclear Regula-tory Commission's (NRC) Inspection Report (Log No. 1-1024) documenting the results of the special' safety inspections conducted at DB-1 on July 11-13 and July 25-29, 1983. Toledo Edison was not required to respond to that inspection report, therefore, we are providing the status of those tasks categorized above with this submittal.
8506040537 850509 gDR ADOCK 05000346 PDR IMAY161985, THE 10LEDO EDISON COMPANY EDISCN PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652
/ s/' \\
v.
Dock *t Ns.-50-346:
' License No. NPF-3
-Serial No. 1-514
~May 9, 1985 Page 2c 1:
, identifies and references each commitment.. Attachment.2 pro-
.vides the status of each task. Attachments 3 and 4 provide specific tech-nical information.
It is our intent to utilize allocated resources wisely to satisfactorily address this and all issues currently-facing Toledo Edison.
Very truly yours, W
RPC:JSH:sm/nif encl..
cc: Director of Inspection and Enforcement
. United States Nuclear Regulatory Commission Washington, DC 20555 DB-1 NRC Resident Inspector - w/o attachments 4
Docket N3.-50-346 LLicense No.-NPF-3'
- Serial No.~1-514
~
May 9, 1985
- Page 1 COMMITMENT REFERENCE TASK
SUMMARY
Commitment Item Reference Task Summary 1.
Toledo Edison letter A review will be -performed to ensure Serial No. 986, dated commitment compatibility between the September 13, 1983 Fire Hazards Analysis Report (FHAR)',
Task No. 3 NFPA Code, Updated Safety Analysis Report (USAR), and the technical specifications.
2.
Serial No. 986, dated A review will be performed of com-September 13, 1993 pliance with previous commitments Task No. 7 made to BTP APCSB 9.5-1 Appendix A and appropriate NRC Submittal Documents for Fire Protection.
3.
Serist No. 986, dated-An engineering analysis on fire September 13, 1983 dampers will be initiated to Page 23' ascertain locations, maintenance and modifications activity re-quired, schedule for completion and program for continued damper opera-bility.
4.
Serial No. 986, dated Further clarification of personnel September 13, 1983 responsibilities will be provided Page 43 in our response to the inspection report.
5.
Serial No. 986, dated An additional review of the adequacy September 13, 1983 of test report documentation will Task No. 6 be performed to verify the accepta-bility of Kaowool fire barrier wraps on cable trcys and conduit in accordance with ASTM E-119.
h.
m.
s
~
g r1
, g Doiket N Q 50-346' 2
- License No.!NPF-3L Serial No. 1-514
'[
' L May. 9,;k1985.
m _
Page.1'.
. SPECIFIC-FIRE PROTECTION TASK ~ STATUS
^
Commitment
. Item Reference
- Task Summary-
-1.
Toledo: Edison letter:
A review will be performed.to
! Serial No. 986, dated ensure-commitment compatibility
- September 13, 1983 between the Fire Hazards. Analysis Task No. 3 Report-(FHAR), NFPA Code, Updated Safety,Aaalysis Report (USAR), and-
~
the technical specifications.
The intent of this task was to document and clarify as necessary the Fire Protection' commitments made within the referenced documents, and to. develop the checklists re-quired to perform any field verification walkdowns that may be required.,
Toledo Edison has completed this task. The task was initi-ated through the performance of a review of. Fire Protection commitment documents to ascertain the extent of the NEPA Code commitments. The results of this review were then verified against. purchase and. design specifications to iden-tify the codes and the appropriate year to each applicable code. A summary listing of the NFPA codes with the year of the codes identified is included as Attachment 3.
The commitment review effort also identified commitments in other existing docketed information. The results of ttis review were utilized together with the~NFPA Codes.to perform a review of the FHAR, USAR and Technical Specifications for inconsistencies and/or inaccuracies in the documents.
The FHAR is currently undergoing a major revision. This revision w111' correct inconsistencies identified as a re-sult of the commitment assessment effort. Additionally,
~
this revision will Incorporate revisions and update the FHA with regard to impacting Fire Hazards Change Notices and update combustible loading data.
Provide a documented technical review of the planned filar revision against the DB-1 SER (NURFG-0136) and the Fire Protection Program SER (Log No. 409), to ensure compatibility.
- +'
s Dockst'Ns. 50-346
~ License No.1NPF-3 r
Serial No.-1-514 r'
May 9,_1985-'
Page 2
?!
_ Incorporate information from existing Safety Evalua-tion Reports.
With, regard to the USAR and the Technical Specifications, efforts have.bnen initiated to update these. documents, to resolve identif f ad inconsistencies 'and/or contradictions..
Fire Protection Technical Specifications will be updated -
subsequent to Toledo Edison's receipt and review of Generic Letter ' 85-01'.-
. Finally-to ensure that the' as-built plant condition ade-quately reflects the Toledo Edison Fire' Protection commit-ments, a series of field verification activities are under-way. These field verifications will document the plant
.FirePro$ectionsystemmodificationconsistencywithregard.
to our Fire Protection commitments.
Docket-No.c50-346 i
. License No..NPF-3 Serial No. 1-514
LMay 9 1985 Attachment.2
'Page 3 L
Commitment
. Item Reference Task' Summary
.2.
Serial No. 986, dated A review.will be performed of com September 13, 1983 pliance with previous commitments Task No. 7 made to BTP APCSB 9.5-1 Appendix A and appropriate NRC Submittal-Documents for Fire Protection.
-Concurrent with Item 1-(Serial No. 986, Task No. 3), this task was initiated to document Fire Protection commitments made to ccmply with BTP 9.5-1 Appendix A and other appro-priate supplemental guideline documents.
-The results of.this review are currently being factored into the revision of the Fire Hazards Analysis Report.
I
my e
e 7
Dock t No. 50-346 License No. NPF-3
- Serial No. 1-5141 May 9,u1985 1 Attachment 2 Page 4 X
~ Commitment-Item.
Reference Task Summary
~
3.-
' Serial No. 986, dated An engineering analysis on fire September.13, 1983 dampers will be initiated to Page 23 ascertain locations, maintenance.
-and modifications activity re-quired, schedule for completion and program for continued damper operability.
Toledo Edison acted aggressively to determine the extent of problems to the operability, maintainability and testability of fire dampers required for fire area separation. is included to summarize the Fire Dampers Improvement Program initiated at DB-1.
Currently, accessible dampers capable of being maintained which affect safety related areas have been tested and are operable.;-Re-testing of these dampers has been initiated in order to obtain a normal testing frequency. Testing has been completed on 88 of 128 safety related fire dampers.
Modifications are being performed on the remaining fire dampers to allow adequate testability and maintainability.
Additionally, a special Safety Inspection was conducted _on
[
June 7, 8, 1984 by your Mr. Joseph U11e. This inspection was documented in NRC letter dated July 5, 1984, (Log No.
1-988).- During that inspection, the Fire Damper Program, summarized as Attachment 4, was reviewed. No items of noncompliance or deviations were identified.
~.
T
?i)ocket-Noy50-346
' License No. NPF-3
'd
- Serial No. 1-514-W
- May'9,l1985;
. Attachment 2.
-Page.5:
'q Commitment-Item-
-Reference
. Task ~ Summary 4.
Serial No. 986, dated-Further clarification of personnel September 13, 1983 responsibilities will be provided Page 43' in our response to the inspection report.
Af ter the 1983 NRC audit, several recommendations were made to upgrade fire protection staffing. As a result, several 0
. changes have been made, with others.still under review.
p
'An evaluation was completed in March, 1984, to assess the adequacy of the Fire Protection staff at DB-1 against existing fire _ protection commitments. The report recom-mandations relating to staffing, with the actions taken _by
_ Toledo Edison, are listed below.
~
1.
ADD AN ASSISTANT' FIRE PROTECTION COORDINATOR.
.In July, 1984 a new assistant Fire Protection Coor-dinator was added tol the Station's staff!to help reduce the Fire Protection Coordinator's workload.
2..
TRANSFER TRAINING AND TESTING TO TRAINING DEPARTMENT.
1.
This item has not been carried out. Both traininr and testing are part of a Fire Protection Performance Enhancement Program (PEP) action plan'(D/FP-1,
" Development of a Fire Protection Program"). The action plan provides for a review of the needs of fire protection training and testing and the staffing neces-sary to carry them out.
i 3.
ADD A FIRE PROTECTION ENGINEER.
Two fire protection engineers are on staff in the Nuclear Facility Engineering Department. Both of these engineers are full members in the Society of Fire Protection Engineers and work full time on fire protection.
4.
REDUCE THE WORKLOAD OF THE FIRE PROTECTION COORDINATOR.
This has been done by the addition of an assistant fire protection coordinator (see Item 1 above).
t 7
- c. -
Docket N2.-50-346 License.No. NPF-3.
Serial No. 1-514
-May 9,;.1985 Attachment'2
.Page'6-m.
Additionally, a special~!iafety Inspection was con-ducted on June 7, 8, 1984 by your Mr. ' Joseph Ulie.
This insp'ection was documented-in-NRC letter dated July 5, 1984 (Log No. 1-988);.During that inspec-tion the qualifications of. Toledo Edison Fire Pro-c l
tection Engineers were reverified and tu) items of l
noncompliance or deviations were identified, f.
i l
As shown above Toledo Edison has taken positive steps to l,
improve staffing.
i l
l l
t 1
l
/
Docket No. 50-346 License No.'NPF-3 Serial No. 1-514 May 9, 1985 -
Page 7 Commitment Item
-Reference Task Summary 5.
Serial No. 986, dated An additional review of the i
September 13, 1983 adequacy of test report docu-Ta.k No. 6 mentation will be performed to verify the acceptability of Kaowool fire barrier wraps on cable trays and conduit in accordance with ASTM E119.
The evaluation performed-to justify the use of Kaowool as a one hour barrier in certain configurations has been com-pleted.
The objective of that report is to demonstrate the adequacy of Kaowool blanket wrap as installed at DB-1 to provide one hour of protection from an engulfing fire as required in Section III.G.2.c of Appendix R to 10 CFR 50.
The report concludes that:
1.
Two 1 inch layers of Kaowool blanket wrap as installed at DB-1 will provide 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of protection from an en-gulfing fire to straight sections, tees, and elbows of cable trays.
2.
Two 1 inch layers of Kaowool blanket wrap similarly installed, will provide 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of protection to straight sections, tees, and elbows of conduits of 2 inch or larger diameter.
This report has additionally been revised to address certain concerns raised within the proposed ~Ceneric Letter 85-01.
)
Dockct Na 50-346 License No. NPF-3 Serial No. 1-514 May 9, 1985 Page 1 TED NFPA COD (S, 1.
NFPA 4 (1971)
Organization for Fire Services 2.
NFPA 4A (1969)
Organization of a Fire Department 3.
NFPA 6 (1974)
Organization of Industrial Fire Loss Prevention 4.
.iFPA 7 (1974)
Management Control of Fire Emergencies 5.
NFPA 8 (1975)
General Manager.knt Responsibility 6.
NFPA 10 (1975)
Standard for Portable Fire Extinguishers 7.
NFPA 13 (1978)
Standard for che Installation of Sprinkler System 8.
NFPA 13A (1981)
Recommended Practice for the Inspection, Testing and Maintenance of Sprinkler Systems 9.
NFPA 14 (1978)
Standard for the Installation of Standpipe and Hose Stations 10.
NFPA 15 (1977)
Standard for Water Spray Fixed Systems for Fire Protection 11.
NFPA 20 (1974)
Standards for the Installation of Centrifugal Fire Pumps 12.
NFPA 24 (1968/73)
Standard for Outside Protection 13.
NFPA 26 (1976)
Recommended Practices for the Supervision of Valves Controlling Water Supplies for Fire Protection 14.
NFPA 27 (1975)
Recommendations for Organization, Training and Equipment 15.
NFPA 30 (1973)
Flammable and Combustible Liquids Code 16.
NFPA SOA (1973)
Gaseous Hydrogen System
- 17. NFPA 51 (1974) _
Standard for the Installation and Operation of Oxygen-Fuel Gas Systems for Welding and Cutting 18.
NFPA 51B (1975)
Fire Prevention in Use of Cutting and Welding Processes 19.
NFPA 69 (1973)
Standard on Explosion Prevention Systems 20.
NFPA 72D (1975)
Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems
- 21. NFPA 72E (1978)
Standard on Automatic Fire Detectors 22.
NFPA 78 (1975)
Lightning Protection Code 23.
NFPA 80 (1977)
Standard for Fire Doors and Windows 24.
NFPA 90A (1978)
Standard for Installation of A/C and Ventilating Systems 25.
NFPA 92M (1972) a, Water Proofing, Draining of Floors
- 26. NFPA 204 (1978)
Guide for Smoke and Heat Venting 27.
NFPA 251 (1972)
Standard Methods of Fire Tents of Building Construction and Haterials
+-
Dockst Ns. 50-346
= License No. NPF-3 Serial No; 1-514 May 9, 1985 Page 1-FIRE DAMPER PLAN
SUMMARY
Within the September 13, 1983 NRC Audit Response. Submittal (Serial No. 986) the following commitment was made concerning fire dampers.
The damper testing program currently being performed will be extended to include fire dampers performing required fire barrier functions. Addi-tionally, an engineering analysis will be initiated to ascertain:
The locations of fire dampers.
The maintenance and/or modification activity required to enable testing of each fire damper.
A schedule for which the completion of damper testing can be identified.
A program enabling the development of the preventive maintenance -
surveillance frequency and actions to ensure fire dampers continued operability.
History of Damper Testing In January of 1982, a NRC Fire Protection Inspection took place at DB-1.
The Inspection covered aspects of the Toledo Edison's Fire Protection and Fire Prevention Programs. A review of the Inspection Report identi-fies that fire dampers were not considered a part of that audit nor were any deficiencies identified with regard to fire dampers.
It is understood, however, that discussions concerning fire damper functionability verifi-cation were held.
Subsequent to that audit. Toledo Edison personnel dis-cussed the issue of verifying the functionability of fire dampers installed at DY-1.
As a result of these discussions, because of the concern placed upon this issue by the Toledo Edison staf f, Surveillance Test ST 5016.11
" Fire Protection System Barrier Surveillance Test" was revised to include the functional testing of fire dampers. Damper testing commenced at DB-1 in April, 1983.
Current DB-1 Technical Specifications define the Surveillance Requirements pertaining to fire dampers, as follows:
4.7.10 The above required penetration fire barriers shall be verified to be functionals a.
At least once per 18 months by a visual inspection.
b.
Prior to returning a penetration fire barrier to functional status following repairs or maintenance by performance of a visual inspection of thu affected penetration fire barrier (s).
K n
!DockAt No. 50-346-cLicense No.-NPF -
-Serial No.-1-514 May'9, 1985-L
' Attachment ~4 ~
Page 2~
Thus while'only a visual inspection of fire dampers is required. Toledo Edison has deemed ~it necessary to operationally verify the required fire dampers ability to function.
Audit and Post Audit Activities During the audit..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 personne1~ error and an inadequate test procedure.
- The violation of Limiting Condition of Operation (LCO) concerning fire dampers has been reviewed by the Toledo Edison Fire Protection staff.
' Steps were taken to correct the deficiency and ensure tighter administra-
- tive control of fire damper and barrier surveillance testing within pro-cedure ST 5016.11. " Fire Protection System Barrier Surveillance Test."
~
A revision of the damper testing procedure has been completed and the procedure now reflects tighter administrative controls by the Toledo Edison Fire Protection Staff. The revised procedure now clearly indicates administrative steps to be taken when functionability of a fire barrier,-
fire door, or fire damper.is unsatisfactory. Revision of Section III of the procedure ST 5016.11 clarifies the definition of " operable" and pro-vides explicit guidance in testing and maintenance of fire dampers.-
i Separate attachments incorporated into ST 5016.11 provide direct and ex-plicit control of fire door and dampers which function unsatisfactorily.
The attachments incorporated the following information to aid in control 1
of barrier / separation criteria failure; time and date fire barricr de-clared inoperable, Maintenance Work Order under which fire barrier was repaired, and time fire barrier was ratested and returned to service.
Under the guidelines of the revised procedure, maintenance personnel were trained utilizing a program approved by both the Maintenance and Fire l
Protection Staff.
l The NRC Audit Team reviewed this procedure prior to restart and found it i
acceptable.
Fire dampers inadequately tested were retested utilizing the revised pro-cedure prior to plant startup.
Licensee Event Report (LER) NP-33-83-50 was processed per AD 1804.00, The LER included events listed in DVRs83-092, 83-094,
[
83-095,83-096, 83-097 and resolve LCO concerns regarding fire dampers.
t l
[
I
Docket N;. 50-346 License No. NPF-3 Serial No. 1-514 May 9, 1985 Page 3 Location and Modification Support Incorporation Identification Soon after plant restart, a walkdown verification program was implemented to:
1.
Identify damper locations.
2.
Identify and document the damper ratings, serial numbers and UL approvals.
3.
Verify wall ratings for comparison to damper ratings.
4.
Verify accessibility to fire dampers.
5.
Verify testability of fire dampers.
6.
Verify maintainability of fire dampers.
7.
Obtain preliminary information needed to perform modifications as necessary to enable items 4, 5 and 6 above.
8.
Identify drawing deficiencies not reficcting in-plant conditions.
A detailed procedure, MC 7500.57, " Damper Verification Check List Proce-dure," was implemented in order to accurately collect the necessary in-formation. Walkdown teams were developed utilizing Toledo Edison and contractor personnel, to obtain the information.
Cameras were fully utilized to obtain the as installed information to support Facility Change Request (FCR) generation.
As a result of the field walkdown, the locations have been physically verified for fire dampers in the Auxiliary Building and Tutbina Building.
The results were brok.m down into two types, one being fire dampers acceptable for continued testing and the other being those requiring modification prior to the resumption of testing.
Categorization and Facility Change Request Development Criteria was developed prior to the walkdown to determine if a fire damper could be tested. This criteria was baned on a number of factoral e.g.,
existence, accessibility, testability and maintainability.
In order to resume testing, every fire damper was assessed against this criteria in detail. Maintenance personnel, familiar with damper maintenance and testing, acting as part of the walkdown teams, utilised their experience in the criteria assessment. This effort is complete. The location and information needed to support FCR development was identified.
u
4 Docket-Ns.'50-346
-License No. NPF-3 Serial No. 1-514 jHay 9, 1985' Page 4 The fire dampers were divided into three categories; the first are those fire dampers which are' considered safety related (i.e., required for
.10 CFR 50, Appendix R and/or Appendix A to BTP9.5-1) as well as being required per NFPA 90A. The second category are fire dampers which are considered non-safety related, but fall under the requirements of NFPA 90A and are not subject to reportability activities. The third category relates to fire dampers not located in designated, required fire barriers or fire partitions not subject to NFPA 90A requirements:
1.
Category One (Safety Related) a.
Acceptable for Testing - 88 b.
Physical Modifications Required (Safety Related) FCRs in Progress - 40 l
2.
Category Two (Non-Safety Related, NFPA) a.
Acceptable for Testing - 13 i
b.
Physical Modifications Required (Non-Safety Related) - 14 3.
Category Three (Non-Safety Related, Non-NFPA) - 22 Preventative Maintenance and Surveillance Frequency Development i
A Preventive Maintenance Program is being developed within the following guidelines Category la dampers have been tested par the guidelines within the revised Surveillance Test Procedure ST 5016.11.
The test data will be rev!cwed and a test frequency will be identified, scheduled, and incorporated into the appropriate procedures that will best as.ute required damper operability.
i
}
l i
I.
-