ML20133B832
Text
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Docket No. 50-346 g
.gy i yntsoo
%ur EDISON License No. NPF-3 Rceno P. Caoust Serial No. 1-396 m%
w December 16, 1983 Mr. James G. Keppler, Regional Administrator United States Nuclear Regulatory Com=ission Region III 799 Rocsevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
On December 1, 1983, the Toledo Edison Company (TED) met with you to discuss potential enforcement actions resulting from the July 25-29, 1983 Fire Protection Appendix R Audit perfor:ed at the Davis-Besse Nuclear Pcwer Station, Unit 1 (DE-1).
This letter prevides the Nuclear Regulatcry Co=cissien (NRC) with the requested information and documentation su ary concerning (1) the Toledo
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Edison effort put forth to meet the requirements of 10 CFR 50.48 and Appendix R to 10 CFR 50 and (2) the Kaevoel vraps, coc=itted to in the April 29, 1982 Ce:ponent Cooling Vater Pucp Roo (Roce 325) Execption Request (Serial Nc. 815).
The infor:ation requested is included as.
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The intent of this infcmation is to demonstrate:
i That Toledo Edisen, through its Fire Protection Program development made a good faith effort to meet the requirements of 10 CFR 50.48 and Appendix R.
The icplementation of a totally justifiable fire protection plan in the Ccepenent Coeling Water Pu=p Roo=, in lieu of the installation of a cne hour barrier around the cocponent cocling water pucps.
As discussed at our December 1, 1983 meeting, Toledo Edison is proceeding with a long tem program that vill provide the basis for resolving identified open issues with respect to Appendix R.
This program is systematic in nature and will go beyond the audit findings to further identify and resolve any additional potential deficiences found.
This progra= and our CORRESPDPE)ENCE PDR l
THE TOLEDO EDISON COMPANY EDISCN PLAZA 300 MADISON AVENUE TOLEDO. CH10 43552 j
695 ct Ec 50-346 k
1.icce r; !;c. NPT-3 Serial be, 1-396 Dece=ber 15, 1983 Page 2 enclosed report clearly demonstrate that Toledo Edison has endeavored to cupport a Fire Protection Program since the Browns Ferry fire that fully teets our understanding of the (NRC) Fire Protection requiremen'ts.
In sut: mary. Toledo Edison can demonstrate its history of support of the NRC fire protection objectives which prohibit adverse ef fects to the health and safety of the public in the event of a fire at DB-1.
Very truly yours, fk RPC:JSE:nif encl.
cc:
DB-1 NRC Resident Inspector a
S 7
Docket No. 50-346 License No. NPF-3 Serial No. 1-396 Page 1 s
TOLEDO EDISON COMPANY DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 1
4 1
DECDGER 1,1963 ENFOP"~rNT MEETING REQUESTED INFOR%1 TON PACKAGE I
Introduction II Tire Protection Progra:
III Response to Appendix R IV Cocponent Cooling Water Room Information 4
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I
Dreket b. 50-340 Liber..ec Sc. ITT.i Scrial Kr. 1-39(
AttachcCUt 1 Page 2 1.
INTRODUCTION On December 1, 1983, the Toledo Edison Company (TED) met with the. Nuclear Regulatory Commission (NRC) at Region III offices in Glen Ellyn, Illinois.
The reason for the meeting was to discuss potential NRC enforcement actions.
This action was to be based on the findings identified during the July 25-29, 1983 NRC Audit of the Davis-Besse Nuclear Power Station.
Unit 1 (DB-1).
The audit was performed to verify TED's compliance with 10 CFR 50.48 and Appendix R to 10 CFR 50.
That audit concluded that cignificant deficiencies existed relative to the Appendix R requirements.
In response to the findings of the audit. TED acted quickly, with NRC participation, to develop a plan for evaluation and rectification of each cudit finding.
This evaluation is docusented in the TED submittal of September 13, 1983 (Serial No. 986).
TED concluded that adequate fire protection features are in place at Davit-Besse to protect the public health and safety.
In addition, certain ccmpensatory measures have been implemented pending the completion of the final resolution activities, as e condition for resumption of plant operation in Septe=ber, 1983.
In the Safety Evaluation Report issued on Septe=ber 23, 1983 (Log No. 1375), the NRC concluded that DB-1 could restart based upcn the compensatory measures taken and the long ter= program instituted by 1ED to resolve the audit findings.
TED has endeavored to cc= ply with the NRC's fire protection require =ents.
DB-1 was one of the first operating plants to cceply with pre-Appendix R requirecents.
TED vas also one of the first plants to be inspected to Appendix R under the current Inspection Program.
At the time of inspection, TED earnestly believed that the actions taken cecplied with the intent of Appendix R.
Over the years since the issuance of Section 50.48 to 10 CFR 50 and Appendix R several internal NRC clarifying mecoranda have been issued.
These NRC clarifications, in part, have been transmitted to all licensees n: cecent as October 19, 1983 in the form of Generic Letter 83-33, because of the continued videspread discrepancies at the utilities.
Toledo Edison vill be including this most recent clarification information in our evaluation and rectification program.
Toledo Edison plans to make all necessary improvements in the DB-1 Station Fire Protection Systems, programs, and procedures to meet the Appendix R criteria as we now understand them.
Howe"er, TED would like to emphasize that at all times DB-1 has had an adequate fire protection program for the protection of the public health and safet).
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At the Dece=ber 1, 1983 meeting, the NRC tequested that TED provide supportive information with respect to:
(1)
The specific TED actions taken to assure itself of meeting the requirements of 10 CFR 50.48 and Appendix R to 10 CFR 50.
ppcket Ec. 50-346 Licente No. N77-3 Serial No. 1-396 Page 3 (2)
Concerns of Kaowool wrapping in the Component Cooling Water Pump Room (Room 328), detailed in the exemption request justification dated April 29, 1982 (Serial No. 815).
This report specifically addresses these two issues and attempts to demonstrate that:
(1)
Davis-Besse's historical commitment to an effective fire pro-tection program is well documented and demonstrates adequate protection from existing and anticipated fire hazards.
(2)
TED's activities to the present in response to Appendix R were made in good faith based upon our interpretation of the rule.
Section II of this report provides a historical record of the fire protec-l tion program at DB-1.
This section is relevant to our response to Appendix R since TED had completed most of its fire protection modifications prior to the issuance of Appendix R.
Section III details I
TED's activities since the issuance of, Appendix R.
The response requested by the NRC for the component cooling water pump room vraps is presented in Section IV.
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?cchet Nc. 50-3!.6 License Ne. N77-3 Scrial Sc. 1-396 Page 4 II.
FIRE PROTECTION PROGRAM TED's com=itment to the NRC's upgrading of fire protection programs cxtends back to February,1976 with the receipt of the Brown's Ferry Report, the fire protection criteria of Branch Technical Position APCSB 9.5-1 (May 1976), the Standard Review Plan 9.5.1 (May 1976), and the Regulatory Guide 1.120 (June 1976).
In response to the NRC's request for cn evaluation of the fire protection features at Davis-Besse TED forwarded its Fire Ba:ards Analysis Report (FEAR) on February 11, 1977.
Subsequent to the subcittal of TED's FRAR, a large amount of infor=ation was transmitted between the Regional and Bethesda NRC offices and Toledo Edison.
Toledo Edison aggressively pursued a clear understanding of the fire protection require =ents.
This can be borne out by the amount of docketed caterial on the subject of fire protection for DE-1.
A chronology of some of the fire protection events is included in.
This aggressive approach was tnken to ensure adequate fire protection systems and programs were identified at the time of and subsequent to the receipt of the DB-1 Facility Operating License, April 22, 1977.
The FEAR and the dialog with the NRC cencerning fire protectien catters led te the is.euance of the Fire Trotection Safety Evaluatics Repert on July 26, 1979.
In the SER, the NRC noted its approval of the plant and operaticnal codifications proposed for DB-1.
Additionally, the SER
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confir=ed the ability to achieve the requisite level of fire protection safety including the adequacy of the safe shutdown capability for a fire in the Centrol and Cable Spreading Roces.
An additienal acend:ent to the DB-1 license was subsequently issued on Neve:ber 18, 1980, reflecting changes to the plant's fire detection cystes.
No other design changes to its approved fire protecticn syste=
vere proposed by TED nor was there any identification that this program was deficient.
In approving the Davis-Besse fire protection program as meeting the General Design Criterion 3 provided in Appendix A to 10 CFR 50, the NRC sought to enhance the plant's ability to withstand the da aging affects of fire.
The progra: vas cocprehensive in scope and required additienal fire protection i=provecents in a large nu=ber of areas including:
1.
Service water pump and valve room fire protection system modifications; 2.
Procedures which evaluate shutdown capability by identifying the potentially lost redundant safety related equipment and identifying alternate equipment; 3.
_ Fire fighting procedures; and
, liccke t Nc. 50-346 Licinse No. NPF-3 Serial No. 1-396 Pege 5 A variety of other specific measures, consisting of significant 4.
additions and/or modifications such as:
new fire extinguishers, sprinkler systems, water curtains, concrete curbing, hose stations, battery room alarms, fire rated doors and dampers, cable tray protection, structural steel coatings, automatic detection, radio communication, 8-hour emergency lighting, Kaovool vraps around conduits, and administrative controls.
These measures were implemented on a schedule approved by the NRC.
In the letter from D. Eisenhut dated' August 9, 1979 (Log No. 415), TED was urEed to apply its "best efforts" to maintain schedules for completion of all fire protection codifications.
TED did so by ccepleting its scheduled fire protection program codifications during the 1980 extended refueling cutage.
Many of the details of the DE-1 Fire Protection Program were specifically developed through NRC discussions and meetings that led to mutually acceptable resolutions.
Two such examples in which TED implemented plant changes as a result of this close dialog vere:
- 1) the DB-1 fire suppression system design and, 2) the ccepletion and imple=entation of procedures to achieve hot and cold shutdcen in response to a fire.
The procedural issue, reopened during the Fire Protection - Appendix R is detailed here to de=custrate the TED understanding that the fire
- Audit,
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protection issue had been identified, jointly discussed, resclved, i=ple ented, and acceptably closed out with NRC ccncurrence.
In response to ec= ittents cade during the fire protection reviev ceeting held on October 25, 1978 with NRC persennel, and documented in the Fire Protection SER of July 26,1979 (Log No. 409), TED established a program of fire pre-plans, within Administrative Procedure AD 1810.03, approved on Feb ruary 27, 1979.
These coc=itments were docucented in NRC letter dated 27,1978 (Log No. 362).
The fire pre-plans describe the actions Neve=ber required to cinimize the effects of a fire on the safe operation and chutdown of the plant, in the event that hot and/or cold shutdown safety related equipment or viring is involved in the fire (i.e. bypass available, uneffected redundant safety related equipment, ncn-safety related equipment, fire suppression capabilities, etc.).
Development cf this safe shutdown support inforcation, ccupied with the existing TED emergency procedures, was to ensure the DE-l's ability to achieve safe shutdown.
An inspection of the DE-1 Fire Protectico Program was perfor=ed by NRC Region III and documented in the NRC letter of July 30, 1979, (Log No.
1-217).
concluded that TED had provided an adequate The inspection report description of its current developed procedures, and those planned to be developed in the near future.
Fire fighting pre-plans were developed to fire emergency procedures, and strategies for fighting fires in supplement
Docket 50.50-34f L5'ccnst Nc. NTT-3 Sc rit.I ' Fe. 1-396 Attachment,1 Page 6 all safety-related areas and areas presenting a hazard to safety-related squipment.
The inspection revealed that, subject to implementation of certain recommendations, the fire fighting procedures conform to the provisicas of eupplemental guidance of Appendix A to BTP 9.5-1 and were, therefore, ccceptable and would resolve the safe shutdown procedures item in the July 1979 SER.
As committed to at the Inspection Exit Meeting, corrections and appropriate procedural approvals were completed by October 25, 1979.
Therefore, without further Euidance concerning required procedural format or content, this Eeneric issue of providing safe shutdown procedures in the event of a plant fire was considered to be satisfactorily resolved.
This jointly resolved issue, the fire suppression system design, and other issues such as circuit evaluation, control of cocbustibles, fire docrs, offsite fire training, and control of ignition sources can be similarly detailed in the TED response to the Appendix R Audit Inspection Report when issued.
TED feels, hevever, that this documented effort is indicative of the overall pre-Appendix R effort.
It is this effort which led to the Toledo Edison Cetpany's assesscent that it co= plied with the applicable portictr of Apper. dix R when viewed in light of the TED interpretatien discussed in Section III of this report.
1 The post Erewns Ferry Tire Protection Program of modificatiens was i=ple=ented by TED at a cost of over $20 tillion to meet the regulatory requitecents and the NRC's schedule for co:pletion prior to the Fove:ber 1980, deadline.
In retrespect, this deadline coincided with the NRC's cwn schedule for issuing Appendix R.
In response to the new rule, specifically the require:ents of 10 CTR 50.48, TED accelerated its icple:entation of the only re=aining codificatien, the backup service water syste= frc: what was deter =ined previously justifiable by the NRC.
Thus, to the present date, Davis-Besse's fire protection program has been based en a ce=pletely closed out SER and a good faith coccitment to support the objectives of nuclear power plant fire protection.
Docket Nc. 50-34(
Licenst,No. NTT-3 Serici Ne. 1-391 Page 7 III. RESPONSE TO APP'ENDIX R On December 2,1980, TED formally received 10 CFR 50.48 and Appendix R to 10 CFR 50 in the NRC transmittal dated November 24, 1980 (Log No. 686).
On December 3, 1980, the Vice President, Nuclear, of the Toledo Edison Company, initiated an internal review of the major issues raised by Appendix R (Intra-co=pany cemorandu: R. P. Crouse to J. E. Shortt).
Based on a review of 10 CFR 50.48 and Appendix R. TED's previous fire protection submittals and the NRC's Fire Protection Safety Evaluation Report, TED concluded that it met the requirements of Appendix R made specifically applicable to our operating facility by 10 CFR 50.48 with the exception of the preposed modification to the service water system.
TED recognized the need to accelerate its ori inal 1984 com:iteent to modify the service E
water system due to the change in the regulations.
It should be pointed out that this schedule revision required substantial engineering effort since the original ce==ittent was based on cross-connecting Unit 2 or 3 service water system to Unit 1.
As a result of the cancellation of Units 2 and 3, a new design was initiated by TED.
Prior to submitting its response to Appendix R, and as part of its ongoing engineering audit progra=, TED ccnducted an audit of Bechtel's Facility Change Request (FCR) verk package review and adequacy as it addressed the fire protectics pretrat.
Th: audit noted the need to perform and docu=ent a fire hazards review for each TCR package.
Bechtel agreed to initiate a review of each FCR to be closed out and to accccpany that review with a
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standard closecut letter.
A copy of this generic closecut letter is included as Enclosure 2 to this report.
The letter states that both APCSE ETF 9.5-1, Appendix A and 10 CFR 50, Appendix R require =ents were cet in the FCR.
This ef fort verifies TED's e=phasis to maintain the statien's conformance to the ETF 9.5-1 Fire Protection Prograc including the interpretatiens of Appendix R throughout the life of DB-1.
k*hile TED was preparing its March 19, 1981 respense to the regulation, the NRC issued the Generic Letter 81-12 to licensees.
Eased on TED's under-standing of Appendix R and the detail to which the coordination, separ-otion, and interaction of circuits was designed into the DE-1 Facility, no detailed docucented review vas dee:ed necessary at that time.
Approxicately one year followinE the date cf the required response to Appendix R, a Clarification Letter to the Generic Letter 81-12 was f orwarded to cost utilities. The Clarification Letter atte:pted to recove ccbiguities and reword specific requirements within the Generic Letter, scLth regard to alternative shutdown inforcation and associated circuits.
The Clarification Letter was not formally transmitted to TED.
A full associated circuit review to the requirements of the Appendix R.
Generic Letter 81-12 and its Clarification Letter is now being performed.
The nonexistence of the Appendix R audit findings relative to associated circuits, however, can be interpreted to confirm the adequacy of the original station design criteria.
l e
Yu. 50-346
- eguet
.' i ct n n Mc. NTT-1 Scrial Mc. 1-39t Page E On March 19, 1981 TED sub=i cited the NRC letter of Novembwith respect of App n
- o. 697) to the NRC no "open items" remaining from th er 25, 1980 In t. hat Appendix A te BTP 9.5-1 e NRC reviewwhich verified th t response TED protection syste:
modifications had been ccepletTED noted in a
alternative capability for th completing these modificationse service water system.ed except for the at the fire to meet descriptien was provided forthe requirements of Appendiwas schedule fo The x R.
In that to February, r Less Centrol, Incin July,1951, an independ the alternate service watsubmittal, the design 1982 ent audit of DB-1 was er capability, protectien program. to assess the overall effecti conducted by Professienal Certain aspects of Appendix R areas of Appendix R non-conf veness of the plant's fire service water 28,1981 (Seri l er ance were neted in the audi vere addressed.
On Dece:ber No t.
a No. 764 and the need to perfor= cthesystem codification of equipment modificatica vould still be the cocpleted, however,t-TMI modifications.e a cents of Appendix R.
r pos fire protection inspecticn15, 1982, NRC I within the time require-The On January nspectors J. Grebe non-co:pliance noted by the i cf DB-1.
In that and R. Mctdec, cer. ducted a the audit.autecatic fire suppressics sy
- audit, stem for the Centrcl Roccnspectors was for the Centrcl Roes.TED i::ediately initiated a e:ent for an As ction to sub it a result of On January 19, 1982 an exceptien request infer atice with resp (ectLeg Nc. 850), the NRC reque t The NRC letter suggested th t to DE-1 ceeting the req is ed additienal requests for information.
a a ceeting be held tc facilitatu rements ef Appendix R.
Bechtel generally describedAt the meeting held cc Mar h e these c
3, 1982, in Gaithersburg DB-1 and discussed with the NRC, the fire protecti, Maryland, TED and the Fire Eacards Analysis R scthodology used in its devel centurrence frc:
testing the NRC Prcject Manastr eport including theon activities at eptent.
Eevever,was to discuss the Alternate Service wit var TED
, that TED vas prepared tc, and did d the initial intent of th
, with used by TED to address its inter iscuss Appendix R and the cethater TED's and Eechtel's understa di e
pretations of those requirement during the =eeting, that a f n
ng based en the information e ods be written to concluds the st s.
It vac avorable Safety Evaluatien Rep infor=ation en April 29 aff review xchanged also high/ low pressure interfaceclarification with res of Appendix R.
ort (SER) vculd e backup service water capabiling additional vare frem 20 feet separation in thexemption requests from autom ti s at DB-1.
c suppression in the Control RAlso in ties and a
e component cooling water roo er oce and m.
In the
Decket Sc. 50-346 Licenst Nc. NPT-3 Serial Ne. 1-396 Page 9 letter. TED offered to meet with the NRC to discuss the information provided in this response.
The proposed alternative system for the service water system va's approved by the NRC in an SER issued on June 2, 1982.
As part of this SER, the NRC listed the docu=ents that they reviewed as part of the SER.
These documents included not only the March 19, 1981 and April 29, 1982 cubmittals, but also TED's submittals prior to issuance of Appendix R.
The exe=ption requests for the Control Room and component cooling water room were subsequently approved in an SER issued on Nove=ber 23, 1982.
In early July, 1983 TED contracted with General Physics Corporation to perform the annual audit of DB-l's fire protection program.
This included its ccepliance to certain aspects of Appendix R.
Based on the results of this audit. TED was reassured that DB-1 had an adequate fire protectico progra= and appeared to be in cecpliance with Appendix R.
Until the arrival of the NRC audit team at DB-1 in late July, TED had received no for=al direction from any of its contracters or the NRC that it was not in ec=pliance with Appendix R.
Cenclusion To Section III The historic develeptent and specific activities of the Tcledo Edisco
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Cc=pany and the Nuclear Regulatory Commission presented above, recreate the regulatory envirennent that resulted in TED's assesscent of co:pliance with 10 CTR 50.48 and Appendix R.
Although it may not be centistent with todays regulatory evaluation, this does net detract from the effort put forward by TED to ce= ply and TED's belief that such cerpliance had been achieved.
Decket Ne. 50-340 ticense No. NTF-3 Scrial No. 1-396 Page 10 i
IV.
COMTONENT COOLING WATER ROOM As part of its April 29, 1982 letter (Serial No. 815) to the NRC.-TED requested an exemption from the separation criteria between redundant cystem equipment in the Component Cooling Water Pump (CCW) Room (Room No.
328).
This exemption from adding a one hour fire barrier around one of the CCW pumps was granted on November 23, 1982 by the NRC.
The basis for the exemption request and the subsequent SER - re as follows:
1.
Lov in-situ cochustible fire lead of 392 BTU /FT.
This fire lead is significantly less than that needed for a fire of one hour duration.
2.
Horizontal separation of pu=ps No. I and 2 by 22 feet.
CCW pucp No.
3, located between these two pu=ps, contains only 2 gallons of lubricating oil enciesed in a self contained, non-pressuri:ed system, which is the only significant intervening ce=bustible.
3.
Operation of pu=p No. 3 which occurs infrequently, provides 11 feet of separatien between redundant pumps with no intervening ec=bustibles.
4 A curb is provided areund cach pucp to contain potential leakage of
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oil.
5.
Aute=atic fire detectico system capability consisting cf 9 ceiling l
counted spot-type teni:ation and 3 ceiling counted photc-electric s=oke detectors.
4 6.
Autc=atic vet-type sprinkler systec for the CCW heat exchanger and pucp roce enciesure.
7.
Protection by two 1 inch thick Kaevoel blankets wrapped arcund and banded by h inch vide bands and buckles installed on those cenduits and valves required for safe shutdown (a specific list was included in the fer=al subeittal).
The abeve fire protection features were specifically desi ned, reviewed E
j cod installed with NRC concurrence.
All of the abeve fire protection features had been installed prior to the exemption request submittal.
FCR 79-032 was the work package ieptemented to install the fire protection vrapping configurations where required throughout the plant. The wraps in the CCW room were installed and inspector verified as installed on October 9, 1980 in accordance with FCR 79-032.
A re-verification has been recently performed to compare those cenduits identified to be vrapped in the exe=ption request with those wrapped per FCR 79-032.
Within the Exemption Request, 42 conduits and/or valves were identified to be wrapped.
Of the 42 items, four conduits were i= properly
Decket Ne. 50-346 license No. NPT-3 Scrial No. 1-396 Page 11 identified through typographical errors and one conduit was
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unintentionally omitted.
Per the FCR, however, all vraps required in the CCW room were properly installed.
During the audit conducted by the NRC on July 25-29, 1983, the audit team identified that certain one hour wraps were incomplete, poorly installed.
and not in accordance with the test installation.
In its letters of l
August 26, 1983 and September 13, 1983 TED established a program to identify any deficient cable tray and conduit wraps.
Prior to restart from the 1983 refueling outage. TED had inspected, documented, and j
repaired the deficiencies discovered in the audit and its review process.
Also, TED has issued a Preventive Maintenance entry, PM No.1941, requiring post outage inspections to ensure all required wraps are properly maintained.
At the Dececher 1, 1983 zeeting in Glen Ellyn, Illinois, the NRC indicated that with respect to the CCW vraps, more wrapping was expected to be ceepleted based upon the April, 1982 exemption request.
Eased on the l
review done to date. TED believes that the submittal was accurate at the time since TED had previously installed and inspected the Kaevoel vraps as stated within the detailed inforestion provided in its exemption request.
TED believes that the wrappang deficiencies identified during the KRC 4
audit try have been the result cf maintenance activities cenducted in the C C*=* r o om.
Due to the large nueber of maintenance work activities since installation it is impossible to identify the specific work itec that i
resulted in the deficiency.
How ver, by the issuance of PM No. 1941. TED has ensured that future maintenance activities throughout the plant vill not degrade the fire protection program.
JSH:Irh j
i dicket Nc. 50-346 i
Licenst. No. NPT-3 Seris.1 No.1-396 i
l Fage 1 CERONOLOCICAL LIST OF FIRE PROTECTION EVENTS
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l September 30, 1976 TED receives NRC Branch Technical l
Position 9.5-1.
NRC requests TED to j
reevaluate its Tire Protection l
provisions at Davis-Besse.
(Log No. 123) j.
October 29, 1976 TED notifies the NRC that the infor-mation' requested (Log No. 123) shall i
be transmitted February 11, 1977.
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(Serial No.140)
December 17, 1976 NRC requests submittal of proposed 1
j Tire Protection Technical Specifica-i tions.
j (Los No. 156) 1 i
Teb ruary 11, 1977 TED submits Tire Hazard Analysis l
Report (THAR) for NRC review.
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(Serial No. 212)
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April 7,1977 TED submits TSAR changes, regarding photoelectric smoke detectors.
i reflected under Serial No. 257.
I j
(Serial No. 264) l i
j May 25, 1977 TED subtits documentation of Tire Barrier Testing in accordance with l.
ASTM E 119-73.
(Serial No. 284)
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May 31, 1977
~NRC acknowledges TED commitment for installing fire seals prior to i
performing T.P. f110.01 " Emergency Ventilation System Test".
t (Log No. 249)
August 29, 1977 TED receives "buclear Plant Fire i)
Protection Tunctional Responsibili-ties Administrative Controls and t
Quality Assurance".
(Log No. 280)
August 30, 1977 TED receives summary of August 16, 1977 meeting with NRC on the capa-i bility of installed fire penetration seals and fire barrier testing at l
DB-1.
i (Log No. 289)
.=.
L b'cket No. 50-340 i
o Licensc No. NPF-3 Serial No. 1-396 Page 2 September 9. 1977 NRC requests, from an August 25, 1977
)
meeting, additional documentation and confirmatory fire tests of electrical I
j (Los No. 292)
September 30, 1977 NRC acknowledges confirmatory testing of fire retardant seals for electri-
)
cal penetrations through fire barri-era installed at DB-1.
(Log No. 299)
November 17, 1977 NRC acknowledges TED's request for an additional meeting to discuss summary of plans for increasing the level of fire protection for the cable spreading room.
i (Log No. 302) 4 Dece=ber 5, 1977 TED receives NRC proposed Interim i
Tire Trotection Technical Specifications.
(Log No. 303) 4
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1 Dece:bar 5, 1977 TED confirms a 12/6/77 resting with the NRC to discuss (in detail) the existing design and ad inistrative controls relating to the cable spreading roce.
I (Serial No. 403)
Dece:bar 12, 1977 TED submits draf t Interim Tire Protection Technical Specifications.
These specifications commit to the NRC letter dated December $,1977 (Log No. 303), modified as aPrropriate, l
vith discussion where considered ne c e s sa ry.
(Serial No. 406) i j
Decacher 29, 1977 TED receives suc=ary of the Dececber 6 j
1977 testing regarding Fire Protection i
capabilities in the cable spreading Toot.
(Los No. 309) 1 i
January 11, 1978 TED submits to the NRC Revision 1 to j
the Fire Hazard Analysis Report i
i (THAR).
i (Serial No. 411) i k
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i l
O l
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D6cket No. 50-346 License No. NFF-3 Serial No. 1-396 Page 3 March 31, 1978 TED receives NRC review of Emergency Plan and the FEAR, stating it does not fully conform to the Fire Protection elements found in Reg. Cuide 1.101.
(Log No. 323)
April 11, 1976 TED submits an objection to the NRC's safety evaluation concerning their position of a 5-man brigade, as a minimum.
(Serial No. 427)
May 3, 1978 TED submits response to NRC letter (Log No. 323) dated March 31, 1978, concerning Reg. Guide 1.101 and Emergency Planning.
(Serial No. 433)
May 16, 1978 NRC notifies TED of site visit scheduled for May 23-25, 1978.
(LoE No. 330)
June 22, 1976 TED subcits its position en the adequacy of using 3-can fire brigades in lieu of a 5-man brigade.
(Serial No. 449)
June 22, 1976 TED sub=1ts two (2) copies of their report entitled " Tire Confircation Testing of Cable Tray Fenetration Seals in Concrete k' alls Utilizing Silicone Elastomers", in response to NRC's September 30, 1977 request (Log No. 299).
(Serial No. 450)
July (,
1978 TED receives NRC request for additional infor:ation f or TRAE review, based upon Revision 1 submittal, and the May 23-25, 1978 site visit.
(Log No. 340)
July 27, 1978 TED submits the additional informa-tion concerning the July 6,1978 NRC request (Log No. 340).
(Serial No. 453)
docketNo.50-340 License Nc. NFT-3 j
Serial No. 1-396 Page 4 August 4, 1978 TED receives NRC invitation to attend a meeting of the NRC Fire Protection Research Review Group.
(Log No. 345)
August 21, 1978 TED receives results of NRC review of Sections A-1 (Personnel), and C (Quality Assurance Program), for Table 4-1 of the TRAR, Revision 1.
(Log No. 350)
September 7, 1978 TED submits responses to NRC ques-tions 11, 21, 23, 25, 26, 27 and 29 1
as requested by NRC 3etter (Los i
i No. 340) dated July 6, 1978.
Revi-i sien 2 of the THAR is also transmitted.
l j
(Serial No. 457) j September 25, 1978 TED submits the remainder of the responses to the NRC's request for
]
additional information under NRC l
letter (Los No. 340) dated July 6 j
1978.
Revision 3 of the THAR is also i
transmitted.
i t
(Serial No. 460) i l
October 3, 197E TED receives results of the KRC Fire Protection site visit - i.e., Trip i
j Report.
(Los No. 358) j October 25, 1978 1978 TED/NRC Meeting regarding the a
NRC's review of the Davis-Besse Tire
{
Protection Program.
)
November 25, 1978 TED submits to the NRC Revision 4 to the TRAR.
(Serial No. 468)
{
November 27, 1978 TED receives minutes from the NRC for i
the October 25, 1978 TED/NRC seeting.
l regarding the NRC's review of the Davis-Besse Fire Protection Program.
(Log No. 362) 4 1
December 12, 1978 TED identifies to the NRC plant
[
nodifications being made to implement the THAR.
(Serial No. 473) 4 I
e i
m
Docket No. 50.146 Liccnse No. NPF-3 Serial No. 1-396 Page 5 January 10, 1979 TED submAts schedule and~ confirmation of dates for implementing the modifica-tions beint made under the FRAR.
(Serial No. 480)
February 28, 1979 TED submits Revision 5 of the FHAR.
(Serial No. 486)
April 12,1979 TED notifies NRC of completion of procedures which utilize alternate equipment to achieve hot shutdovn in the event of a single fire.
(Serial No. 495)
July 9, 1979 TED subeits a co==itment date of July,1984 to have the Service k'ater backup system independent of offsite power.
(Serial No. 526)
July 17, 1979 TED receives NRC resolution of DB-1 Tire Protection Progra: issues.
(Log No. 405)
July 30, 1979 TED rsceives NRC License Amendment (received)
No. 18 and Tire Protection Safety Evaluation.
(Log No. 409)
August 1, 1979 TED receives NRC Region III Inspection Report 79-15, which acknowledges the use of fire preplans to equate to shutdown procedures.
(Log No. 1-217)
August 9, 1979 NRC issues letter advising of NRC Coc-issioner's direction to use best ef forts to taintain fire protection schedule of October, 1980 for ccepletion.
All utilities urged to caintain this schedule.
(Log No. 415, dated August 9, 1979)
August 14, 1979 TED revises the schedule for service water pump and valve rooms to December 31, 1979 for completion.
(Serial No. 535)
docket No. 50-346 Licensc hc. NPF-3 4
Serial No. 1-396 Page 6
)
August 28, 1979 TED receives extension for service l
water pump and valve room modifica-tion until December 31, 19.79.
(Log No. 425)
April 22, 1980 NRC issues License Amendment No. 24 extending fire protection completion date to end of outage that was unde rway.
i Log No. 546)
April 29, 1980 NRC issues letter discussing final i
action on License Amendment No. 24 of i
April 22, 1980.
l (Log No. 547)
I May 12, 1980 TED receives waiver of fees for Fire j
Protection License Amendeent.
(Log No. 553) 1 l
May 15, 1980 TED submits Revision 6 to the FHAR.
(Serial No. 617) l May 19, 1960 TED receives proposed rule which adds
)
new Section 50.48 and Appendix R to l
10 CFR Part 50 for review and com=ent.
(Log No. 561, dated May 19, 1980) 1
)
July 1, 1980 TED request an extension to the Tire Protection modificaticns until i
September 30, 1980.
(Serial No. 625) i i
j July 17, 1980 TED receives approval of changes to Tire Protection methods (use of sprinklers in lieu of fireproofing) i for Room Nos. 208, 236, 303, 402, 405
}
and 427.
(Log No. 582) i September 5, 1980 TED subcits an updated program
+
schedule for the Tire Protection Modifications.
j (Serial No. 647)
September 23, 1980 TED receives NRC request for Techni-cal Specification revision, to 575.
(Log No. 609) 8 l
4 R
e I
DFckat No. 50-3/.6 l
'Liccuse No. NPT-3 Serial No. 1-396 i
{
Page 7 l
}
september 30, 1980 TED submits letter for withdrawal of
{
f j
extension request to the fire protection i
modifications.
Extension-raquest was no longer needed due to increased effort.
(Serial No. 654)
I October 7, 1980 TED submits Technical Specification i
changes for Fire Detection upgrade.
l (Serial No. 655) j November 18, 1980 TED receives License Amendment No. 34 i
incorporating the new Fire Detection i
system, and deletion of the old Fire l
Detection system.
j (Log No. 634) i l
November 24, 1980 TED receives copy of 10 CFR Part 50 j
Appendix R published November 19 1980.
)j (Los No. 636)
[
i l
Teb rua ry 20, 1981 TED receives Tire Protection rvle (Ceneric Letter 81-12) requiring 1
Davis-Besse to meet requirements of 10 CTR Part 50 Appendix R.
Sections 111.C. 111.J and 111.0.
l (LoS No. 664)
March 19. 1981 TED submits plans, schedules, and l
~
design description of backup service water system modification advances date from mid-1964 to 1985.
This submittal considered responsive to l
j j
Appendix R.
j (Serial No. 697) 1 June 10. 19El TED subtits fear for proposed alter-nate Service Water capability.
(Serial No. 721) t j.
July 20-22. 1981 Fire Protection Audit performed by Professional Loss Control, Inc.
1 i
December 28, 1981 TED submits revised Fire Protection i
Schedule for the Service Water alternate shutdown capability.
l (Serial No. 764) i 1
2 D$ckct K:. 50-346 Lice:st !.c. NTF-3 Serial No. 1-396 Page 8 1
January 15, 1982 NRC Region III Fire Proteition Audit of DB-1.
Exit interview.
Janua ry 19, 1982 NRC submits Safe Shutdown Capability 10 CTR 50 Appendix R - Fire Protection.
l (Log No. 880) l March 23, 1982 Meeting with NRC/TED/Bechtel to i
discuss Backup Service Water Modification.
Various Appendix R issues also discussed.
l 4
April 8, 1982 KRC requests additional drawings in regard to 10 CTR 50 Appendix R.
i i
111.C.3 (" Tire Protection of Safe Shutdown Capability") Exemption Request.
~
(Los No. 960) i i
April 29, 1982 TED submits Exemption Requests to NRC
]
for 10 CTR 50 Appendix R for the CCW s
Pump Room and the Control Room t
I (Serial No. 815).
i i
June 2, 1962 TED receives NRC's acceptance of sodification to comply with r
i Section III.G and III.L of Appendix R I
to 10 CTR 50.
(Log No. 1009)
UcVe htr 23, 1982 TLD submits revised schedule in accordance with 10 CTR 50.48 (C) (4)
I for dedicated alternative shutdown i
- systems, i
(Serial No. 877)
Nove:ber 23, 1962 TED receives exemptions to 10 CTR 50 Appendix R for CCW Pu=p and Centrc1 Roces.
(Log No. 1138) i l
December 14, 1962 TED receives the schedule for com-plating moditications to 10 CTR $0, i
Appendix R.
i (Log No. 1175) i l
March 2, 1983 TED receives NRC staff's positions regarding instrumentation required and allowable repairs for alternative shutdown.
(Log No. 1231)
ocket No.50-34f j
License bo. NTF-3 Serial No. 1-396 Page 9 July 12-14, 1983 Audit performed by General Physics of the Fire Protection Program-including
?
aspects of Appendix R.
July 25-29, 1983 NRC Fire Protection Appendix R Audit.
August 19, 1983 TED receives NRC conformation of requested documentation, committed to l
by TED at an August 16, 1983 TED/NRC meeting.
l j
(Log No. 1351)
)
August 26, 1983 TED submits a list of resolutions j
(coc=itments) to NRC deficiencies noted during the July 25-29, 1983 Appendix R inspection.
j (Serial No. 981)
Septe=ber 13, 1983 TED submits program of short-term, interim and long-term actions; revis-j ing those of previous letters (Serial Nos. 961 and 923).
1 (Serial No. 986) j i
septecher 23, 1983 TED receives restart letter for i
i modifications (i.e., short-term)
L l
cade.
I l
(Log No. 1375)
(
i Scyte:bar 30, 1983 TED submits Exemption Requests for f
I peactor Coolant Pumps tube 011 Collection System, 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> coccitzent, and fire door rating of Door 215 (APP f
j Room due to being a pressure door).
j (Serial No. 991) i i
t 1
l DBP 4918C i
i i
1 o
l'
D.~:). c : 5:. ?J-%e Lietnkt M. !TT-3 SUial'*.e. 1-396 Bechtel Associates Enchrure 2
" 8'
- Professional Corporation (Ohio)
FCR CLOSEOUT LETTER 15740 Shady Grove Road --
)
Gaithersburg, Maryland 20760 la Mr. C. R. Domeek Nuciocr Engineering Manager s
Th3 Toledo Edison Co:pany F. O. Son 929 Tel do. Ohio 43652 Daar Mr. Domecks The Toledo Edison Co=pany Davis-lesse Nuclear Fever Station Eechtel Job 12501 TCR NO.
Subject:
Tile:
0270, 1496 IT-71oase be advised that per 71-(copy attached), the af fected documents for TCF. No.
have/has been revised to refleet the as-built condition. The af fected docu=ents have/has been trans ttted under DBT's
_, copy /ceptes atta:hed.
. n.is TCK (and all cf its supp ::::ts) hava/has tven subjected to a Tire Ha:ard A.alysis Tsevi ew.
This TCR does net adve rsely af fe ct the analysis set forth in the This TCR meets the requirerents Davis-lesse Unit 1 Tire Ma:ard Analysis Report.
set forth in APC51 E P 9.5-1, Appardix A ard 100T7.50, Appendix R, Sectierts 111.C.
2:1.J and 121.0.
on the This eleses Tacility Ch:r e Request No. _ _
If you have any que stions, please cor. tact us.
Very truly yours.
J. V. Tay, Jr.
Project Engineer J.7 /
(0figina to r's na=e ard initials )
Attach =ent:
As stated above beet E. J. Ray w/o cc:
J. Helle v/o T. McDougall w/o C. 7. Datt w/o D. J. Irogdan w/l R. Rosenthat w/o V. D. !;elson w/o R. A. Brown v/l V. A. 5:1th w/o
- 5. Levine v/o Supe rviso r
=
OR. C. Schue rge r Engineer Cievaland Electric 111u:tnating Co.
Others P. C. Rox $000 Cleveland, Chio 44101
- *0utage TCRs only
-