ML20137Z543
| ML20137Z543 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/06/1986 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 1255, NUDOCS 8603130066 | |
| Download: ML20137Z543 (32) | |
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- . 1 TOLEDO h EDISON JOE VVLUAMS. Jn Docket No. 50-346 s-- vu n m_
tats) 249 e300 License No. NFP-3 14'91 P49 sm Serial No. 1255 March 6, 1986 Mr. John F. Stolz, Director PWR Project Directorate No. 6 Division of PWR Licensing-B United States Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Stolz:
Toledo Edison (TED) submitted Revision 0 of the Appendix R Compliance Assessment Report (CAR) as part of our response to the deficiencies identified during the July 25-29, 1983 NRC audit of Davis-Besse Unit No.
I compliance to 10CFR 50 Appendix R.
Revision 0 of the CAR contained twenty-nine (29) exemption requests related to Appendix R noncompliances As a result of Toledo Edison's desire to resolve Appendix R noncompliances through physical modification rather than by exemption request, we have reduced the number of requests associated with the current Appendix R analysis to eleven (11).
Toledo Edison hereby submits eleven exemption requests from the requirements of Appendix R of Title 10, Part 50, Sections III.G.2 and III.G.3 of the Code of Federal Regulations. These cleven exemption requests supercede those listed in Revision 0 of the CAR (Serial No.
1076) in their entirety. Toledo Edison considers these eleven exemption requests as supplemental to the exemption requested in Serial No. 981 on August 26, 1983.
A check for $4,350.00 was provided on September 6, 1984 with Serial No. 1076 for twenty-nine exemption requests as required by 10CFR170.12(c). Since none of these exemption requests were formally reviewed, we request that the check for $4,350.00 be applied toward the eleven exemption requests being submitted and the balance be applied towards your review of the CAR Revision 1.
DOC W
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THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEOO. OHIO 43652 l 'Q
T e
Dock;t No. 50-346 License No. NFP-3 Serial No. 1255 March 6, 1986 Page 2 We will be available to discuss these exemption requests at your convenience.
Very truly yours,
/$ : - ^ m JW:TJB:plf f
Enclosures (4 copies - Exemption Requests) cc: NRR Project Manager (4 copies)
DB-1 NRC Resident Inspector (1 copy)
W. Guldemand (1 copy)
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.l TOLEDO EDISON COMPANY DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 I
APPENDIX R EXEMPTION REQUESTS MARCH 6, 1986 I
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f l EXEMPTION REQUESTS FIRE AREA R ROOM #324 I
Exemption Requested An exemption is requested from Section Ill.G.3 of Appendix R to 10 CFR 50 to the extent it requires fixed fire suppression in on crea where alternate shutdown copobility is provided. Specifically, alternate shutdown capability is provided for the Service Water System and the Turbine Driven Auxiliary Feedwater Pumps I
Governor Control Valves within Fire Arco R. The alternate shutdown capability is physically and electrically independent of Fire Area R.
Discussion Fire Area R is the Auxilicry Shutdown Panel and Transfer Switch Room #324.
The crea consists of 350.quare feet of floor crea with on in-situ combustible I
loading consisting primarily of cable insulation and incidental lubricants. The total combustible looding in the crea is opproximately 5,000 BTU /FT2, which equates to on equivalent fire severity of 4 minutes. The fire crea is bounded by 3-hour fire rated concrete and concrete-block walls with a minimum thickness of I foot, and 3-hour fire rated ceiling and floor constructed of I foot thick reinforced concrete.
E Existing fire protection copobility in the area consists of an oreo-wide, early warning fire detection system which alarms locally and in the Control Roorn.
Manual fire suppression capability in the form of portable fire extinguishers and standpipe hose stations is readily available in the creo.
For o fire in Room #324, both Train I and Train 2 are used to ensure safe shu tdown.
The Compliance Assessment Report describes in detail, the safe I
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shutdown analysis and consequent modifications performed to bring this fire arco into compliance with Section Ill.G of Appendix R.
In addition to these modifications, fire damage to the circuits for the three Service Water Pumps I
could disable a_Il three pumps. One Service Water Pump is required for safe shu tdown. Alternate shutdown capability is provided by manually aligning and starting the Backup Service Water Pump, located in. Fire Area BD. Adequate time exists for the operators to perform these actions following a fire in Fire Area R.
Fire damage to circuits for the Auxiliary Feedwater Pumps' Governor Control Valves ICS038A and ICS038B could disable their remote operability. Alternate shutdown capability is provided by manually aligning and starting the Motor I
Driven Feedwater Pump P-241 in Fire Area II. Adequate time exists for the operators to perform these actions fo!!owing a fire in Fire Area R.
Toledo Edison procedures include instructions for performing these manual actions, if the aforementioned circuits are damaged by a fire in Room //324.
I Evaluation An exemption from the requirements of Section Ill.G.3 to provide fixed fire suppression in Fire Area R is requested, based upon the following evaluation:
The equivalent fire severity in Fire Area R is approximately 4 minutes, which consists of widely dispersed cable insulation and incidental lubricants. A fire originating in these materials or a postulated transient combustible is not expected to produce a fire of significant extent or duration. The installed early warning detection system will alert the Control Room operators to summon the plant fire brigade, which will respond and manually extinguish the fire. If the I
fire causes damage to the Service Water System prior to intervention by the fire brigade, alternate shutdown capability is provided. This capability consists of I
manual operator actions to manually start the Backup Service Water Pump.
I DC-8S-176 2-2
I It is, therefore, Toledo Edison's position that a level of protection equivalent to 1
Section Ill.G.3 of Appendix R to 10 CFR 50 is provided for Fire Area R, the Auxiliary Shutdown Panel and Transfer Switch Room //32'4. The addition of a fixed fire suppression system to this area would not significantly enhance the level of fire protection provided for safe shutdown equipment.
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i FIRE AREA DA - ROOM #I27 h
Exemption Requested j
An exemption is requested from Section ll!.C.2 of Appendix R to IO CFR 50 to the extent it requires the Installation of an Automatic Suppression System where redundant safe shutdown cables are separated by 20 feet free of intervening combustibles. Specifically, redundant trains of safe shutdown cables in the Containment Annulus are separated by greater than 100 feet free of intervening l
combustibles and are protected by a detection system, but automatic fire suppression is not provided in this creo.
Discussion Fire Area DA, Room #127, is the Containment Annulus. The crea consists of 1905 square feet of floor crea with on in-situ combustible fooding consisting primarily of cable insulation and small quantities of tube oil.
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combustible loading in the arco is approximately 15,000 BTU /FT2 which equates to an equivalent fire severity of 12 minutes. The fire crea is bounded by the steel containment, and the reinforced concrete walls of the penetration rooms.
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These walls are heavy concrete, but are not fire-rated, except for the portion of the annulus between the redundant penetration rooms. Existing fire protection capability in the creo consists of an crea-wide, early warning fire detection system which alarms locally and in the Control Room. Manual fire suppression copobility in the form of portable fire extinguishers and standpipe hose stations is available in the creo. Access to the annulus area is restricted during plant operation due to health physics reasons.
Redundant circuits pass through the annulus into containment from the Train I and Train 2 Penetration Rooms.
The penetration areas are separated by approximately 90 degrees around the containment. This separation distance of over 100 feet is free of intervening combustibles. Each cable possing through the annulus is installed with a sufficient length to permit thermal expansion and DC-85-176 2-4
contraction of the containment to occur without comaging the cable.
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redundant cables are separated by greater than 100 feei, with the exception of
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circuits IPBEl40lC and IPBEl40lD and 3P8EFl5C and 3PBEFl5D for the f
Train t and Train 3 Containment Air Coolers, which pass through the Train 2 Penetration Area. Due to the need for these cables to expand or contract, o 3-hour fire rated enclosure could not physically be installed around them. Due to the low risk of fire in the Containment Annulus area, o multiple segment heat shield consisting of a non-cornbustible material will be placed between the redundant circuits, in lieu of a rated fire barrier.
1 Portions of the exterior walls of the Containment Annulus which adjoin the penetration areas do not contain fire rated penetration seals, however the portion of the annulus wall between the redundant trains is of 3-hour fire rated i
construction.
r Evaluation An exemption from the requirements of Section Ill.C.2 to provide Automatic
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Fire Suppression in the containment annulus is requested, based upon the following evaluation:
The equivalent fire severity in Fire Area DA is approximately 12 minutes, which consists primarily of the Train I and Train 2 exposed cables possing through the Containment Annulus. The combustibles are localized in the vicinity of the penetration areas and are not widely dispersed throughout the fire area. A fire f
originating in one train of these cables could potentially destroy that safe shutdown division, however due to the intervening separation distance of greater than 100 feet free of Intervening combustibles it is unlikely that a fire could spread to the redundant train. Due to the restricted occess to the Containment Annulus during operation of the plant, the occumulation of transient combusti-bles is not postulated. Any occurrence of fire will be detected by the installed early warning fire detection system, which will ofert the Control Room operators to summon the fire brigade to respond and manually extinguish the fire. Any 4
delays in the arrival of the fire' brigade will be compensated for, by the DC-85-176 2-5 I
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separation distance of greater than 100 feet free of Intervening combustibles between redundant trains.
The redundant cables which are located in close proximity cannot be enclosed within a rated fire barrier. A heat shield will be installed for their protection.
Due to the limited combustible loading and high celling in the Containment l
Annulus, the heat shields will provide odequate protection of the cohles until the fire brigade con extinguish the fire.
1 It is, therefore, Toledo Edison's position that with the proposed installation of a f
heat shield, a level of protection equivalent to Section Ill.G.2 of Appendix R to 10 CFR 50 will be provided in the Containment Annulus (Fire Area DA). The addition of on Automatic Fire Suppression System in this area would not significontly enhance the level of fire protection provided for safe shutdown
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DC-85-176 2-6 i
FIRE ARE A EE l
Exemptio, Requested An exemption is requested from Section Ill.G.3 of Appendix R to 10 CFR 50 to the extent it requires area-wide fixed fire suppression in on crea where alternate shutdown capability is provided. Specifically, alternate shutdown capability is provided for circuits and electrical components for the Main Steam inlet isolation Valve MSiO6 for the Auxiliary Feedwater Pump Turbine I.
The alternate shutdown copobility is physically and electrically independent of Fire Area EE.
Discussion Fire Area EE consists of three fire zones Zone EE-2 (Room # SIS) - Purge Exhaust Equipment Room Zone EE-3 (Room #501) - Rodwoste Exhaust Equipment and
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l Main Steam Exhaust Fan Room Zone EE-4 (Room #500) - Rodwoste Fuel Handling Areas Air Supply Equipment Area The three zones have a combined total floor area of 11,572 square feet. The In-situ combustible fooding consists primarily of cable insulation and small quantitles of grease, lube oil, and other miscelloneous combustibles. The total combustible looding in the creo is opproximately 10,000 GTU/FT2, which equates to on equivalent fire severity of 8 minutes. The fire area is bounded by 3. hour fire rated reinforced concrete walls with a minimum thickness of 18: feet, and 3-hour rated ceiling and floor constructed of a minimum of I-foot thick reinforced concrete.
l Existing fire protection capability in the area consists of on oreo-wide, early warning fire detection system which alarms locally and in the Control Room.
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Manual fire suppression copobility in the form of portable fire extinguishers and standpipe hose stations is readily available in the area. In addition, on automatic wet-pipe sprinkler system is installed in Room /1501 (Fire Zone EE-3).
f For a fire in Fire Area EE, Train 2 of the safe shutdown systems is assumed to be lost, and Train I is used to ensure safe shutdown. The Compliance Assessment Report describes in detail, the safe shutdown analysis and consequent modifico-tions performed to bring this fire crea into compliance with Section Ill.G of
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Appendix R. In addition to these modifications, fire damage to the circuits or electrical components for the MSl06 Main Steam Inlet Isolation Volve for the //l Turbine Driven Auxiliary Feedwater Pump could prevent opening this volve from I
the Control Room.
Alternate shutdown capability is provided by manually I
oligning and starting the Motor Driven Feedwater Pump P-241 and its associated support equipment. The pump is located outside of Fire Area E in Fire Areo ll.
Adequate time is evolloble for the operators to perform this manvol action.
Toledo Edison procedures include instructions for aligning and starting the Motor Driven Feedwater Pump.
Evaluation An exemption from the requirements of Section Ill.G.3 to provide crea-wide fixed fire suppression in Fire Area EE is requested, based upon the following evaluation:
The equivalent fire severity in Fire Area EE is 8 minutes. The combustible materials consist primarily of widely dispersed cable insulation and small quantities of grease and lube oil.
A fire originating in these combustibles plus on assumed transient is expected to produce a fire of insignificant mognitude.
The installed early warning fire i
detection system will alert the Control Room operators to summon the fire brigade, which will respond and manually extinguish the fire, if the Installed partial sprinkler system has not already done so. If the fire causes damoge to i
the MSl06 volve power circuits, alternate shutdown capability is provided. This
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capability consists of manual operator octions to align and monvolly stort the Motor-Driven Feedwater Pump.
It is, therefore, Toledo Edison's position that a level of protection equivalent to
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' Section Ill.G.3 of Appendix R to 10 CFR 50 is provided for Fire Area EE. The addition of an oreo-wide fire suppression system would not significantly enhance
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the level of fire protection provided for safe shutdown equipment.
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b FIRE AREA HH - ROOMS #603 AND #603A Exemption Requested 5
An exemption is requested from Section Ill.G.3 of Appendix R to 10 CFR 50 to
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the extent it requires area-wide fixed fire suppression and detection in on area where alternate shutdown capability is provided. Specifically, alternate shut-
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down capability is provided for the Control Room Emergency Ventilation System circuits routed through Fire Area HH. The alternate shutdown capability is physically and electrically independent of Fire Area HH.
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Discussion 1
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Fire Area HH consists of the A/C Equipment Room #603 and the Records and Storage Area #603A. The area consists of 3,090 square feet of floor area, with an in-situ combustible looding consisting of cable insulation, HVAC duct insula-tion, and small quantities of grease, lube oil, and miscellaneous combustibles.
2 The total combustible loading in the area is opproximately 13,000 BTU /FT,
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which equates to on equivalent fire severity of 10 minutes.
Existing fire protection capability in the area consists of a portial detection system, protect-ing Room #603 and manual fire suppression capability consisting of portable fire extinguishers and standpipe hose stations for the protection of the entire area.
For a fire in this crea, Train 2 of the safe shutdown systems is assumed to be lost, and Train l Is used to ensure safe shutdown. The Compliance Assessment Report describes in detall, the safe shutdown analysis and consequent modifica.
tions performed to bring this fire crea into compliance with Section lll.C of Appendix R. In addition to these modifications, fire demoge to the circuits for the Control Room Emergency Ventilation System requires that alternate actions be token to ensure safe shutdown capability. Fire domoge to these circuits could disable the Control Room HVAC. Alternate shutdown capability con be provided by evacuating the Control Room and shutting down the plant from the remote shutdown panel. Toledo Edison procedures include instructions for these manual j
operator octions lf Control Room cooling is disabled.
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Evoluotion f
An exemption from the requirements of Section Ill.G.3 to provide fixed fire suppression in Fire Area HH is requested, based upon the following evoluotton The equivalent fire severity in Fire Area HH is approximately 10 minutes,
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primarily consisting of cable insulation and HVAC duct insulation.
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originating in these materials plus cn assumed transient is not expected to
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produce o fire of significant magnitude. The Installed partial detection system will clert the Control Room operators to summon the fire brigade to respond and manually extinguish the fire. If demoge occurs to the Control Room Emergency Ventilation System, safe shutdown of the unit con be performed at the Remote Shutdown Panel.
It is, therefore, Toledo Edison's position that a level of protection equivalent to I
Section Ill.G.3 of Appendix R to 10 CFR 50 is provided for Fire Area HH. The addition of a complete fixed fire suppression system to this crea would not significantly enhance the level of fire protection provided for safe shutdown equipment.
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I FIRE AREA E - ROOM #237 FIRE AREA F - ROOM #238 Exemption Requested
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An exemption is requested from Section Ill.G.2 of Appendix R to 10 CFR 50 to the extent it requires the separation of redundant safe shutdown cables and
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equipment by 20 feet free of intervening combustibles and protection by complete arco-wide automatic suppression and detection systems. Specifically, Auxiliary Feedwater Pump Rooms #237 and #238 have on unprotected vent I
opening in their ceilings, leading to a common area obove. This area obove the pump rooms is also common to the third Motor Driven Auxiliary Feedwater Pump.
Discussion Fire Areas E and F ore the redundant turbine driven Auxiliary Feedwater Pump Rooms #237 and #238, located on elevation 565'.
The creas consist of 464 square feet and 624 square feet of floor oreo, f
respectively, with in-situ combustible loods consisting primarily of cable insula-tion and lube oil. The total combustible loading in Pump Room #237 is approxi-
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mately 21,000 BTU /f t, which equates to on equivalent fire severity of 2
16 minutes. The total combustible fooding in Pump Room #239 is approximately 2
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18,000 BTU /f t, which equates to on equivalent fire severity of 14 minutes. The fire creas are bounded by 3-hour rated reinforced concrete walls with a minimum thickness of 2 feet, reinforced concrete ceilings with a minimum thickness of 2 feet, and reinforced concrete floors with a minimum thickness of I foot.
Existing fire protection capability in the areas consist of an area-wide, early warning fire detection system which alarms locally and in the Control Room.
Manual fire suppression capability in the form of portable fire extinguishers and i
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standpipe hose stations is readily available in the creo. The Heater Gay Area, Fire Areo II, elevation 585 f t, above the Auxiliary Feedwater Pump Rooms is protected on all floor levels by on automatic pre-oction type sprinkler system.
g For a fire in Pump Room #237, the redundant safe-shutdown equipment is located in Room #238. In addition, Room #238 contains circuits for the third, s
Motor-Driven Auxiliary Feedwater Pump which is located on elevation 565' in i
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the main feedpump arco. An 18 square foot vent opening is provided in the ceiling of Pump Room #237. A 62.5 square foot vent opening /occess stairwell is provided in the ceiling of Pump Room #238. Both vent openings are required to be open at all times for pressure relief in the event of a steam line rupture in either of the pump rooms. Consequently, protection of the openings by rated fire doors or fire dampers could impair the capability to vent steam in the event of a piping rupture and could potentially lead to on overpressurization of the AFW Pump Rooms. The two ceiling penetrations open into a common crea in the l
heater boy above. The horizontal separation between the openings is approxi-mately 24 feet. The separation between the Motor-Driven Auxiliary Feedwater Pump and Pump Room #237 is opproximately 75 feet, while the separation l
between the motor-driven pump and Pump Room #238 Is opproximately 99 feet.
Both openings in the pump room ceilings are proteced by 8-inch high concrete curbs to prevent a flammable liquid spill from spreading to either room.
Intervening combustibles between the vent openings consist of cables in cable trays, opproximately 10 feet above the~ vent openings.
1 Evoluotion An exemption from the requirements of Section Ill.G.2 to provide 20 feet free of intervening combustibles between the vent openings in Dump Rooms #237 and
- 238 is requested, based upon the following evaluation The access to each pump room consists of a stairway through the ceiling penetrations. This, in conjunction with the limited floor creo of the pump rooms makes it unlikely that a significant omount of transient combustibles would be l
Introduced to the area. The in-situ combustible loading in each pump room is less than 16 minutes. A fire of significant mognitude is, therefore, considered i
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I unlikely. If a fire were to occur in one of the pump rooms, the installed early warning fire detection system will ciert the Control Room operators to summon the plant fire brigade, which will respond and monvolly extinguish the fire, if g
the fire were to spread through the ceiling vent opening into the Heater Gay Area, prior to intervention by the fire brigade, the Automatic Sprinkler System s
in the Heater Boy Area above is expected to control the fire, and prevent it from
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spreading horizontally and down to the redundant Pump Room or Motor Oriven Pump. The location of the pumps, one floor level beneath the vent openings, in f
conjunction with the horizontal separation distances provide additional assurance that one train of Auxiliary Feedwater Pumps will remain free of fire domoge.
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It is, therefore, Toledo Edison's position that a level of protection equivalent to Section Ill.C.2 of Appendix R to 10 CFR 50 is provided for Pump Rooms #237 and #238. The removal of the Intervening cable trays above the pump room vent i
openings would not significantly enhance the level of fire protection provided for f
safe shutdown equipment.
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FIRE ARE A U - ROOMS #310, /1312. #313 Exemption Recuested p
1 An exemption is requested from Section Ill.G.3 of Appendix R to 10 CFR 50 to
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the extent it requires fixed fire suppression in on area where alternate shutdown capability is provided. Specifically, alternate shutdown capability is provided for P
circuits for the CCW Pump Room Vent Fan and Louvers within Fire Area U. The alternate shutdown capability is physicc 9 and electrically independent of Fire 4
Areo U.
Olscussion
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Fire Area U consists of the Passage Hatch Area, Rooms #310 and #313, and the Spent Fuel Pool Pump Room #312. The area consists of 2,527 square feet of l
floor area with an in-situ combustible loading consisting primortly of cable
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insulation, lube oil, and other incidentals. The total combustible fooding In the 2
area is approximately 3?,000 BTU /FT, which equates to on equivalent fire
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severity of 30 minutes. The area is bounded by 3-hour fire rated reinforced concrete walls with a minimum thickness of 2 feet, and 3. hour rated celling and floor of at least 2-feet thick reinforced concrete.
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Existing fire protection capability in the area consists of on crea-wide early warning fire detection system which alarms locally and in the Control Room.
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Manual fire suppression capability in the form of portable fire extinguishers and standpipe hose stations is readily avalloble in the creo. In addition, a wet pipe sprinkler system 1s Installed in Rc. oms #310 and #313. For a fire in Fire Areo U, Train I of the sofe shutdown systems is assumed to be lost, and Train 2 is used to ensure safe shutdown. The Corr.plionce Assessment Report describes in detall the safe shutdown onolysis and consequent modification performed to bring this fire area into compliance with Section Ill.C of Appendix R. In oddition to these
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modifications, fire damoge to circuits for the CCW Pump Room Vent Fan C75-2 or Louvers MV5444 A, B, and C could result in the loss of CCW Pump Room DC-85-176 2-15 r
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cooling. Adequate cooling is required to achieve cod maintain hot standby and for going to cold shutdown. Alternate shutdown capability is provided by the use of portable fans placed in the pump room doorways. An evaluation has been performed to show that odequate time exists for the operators to establish temporary room cooling prior to exceeding critical temperatures.
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Toledo Edison procedures include Instructions for performing these manual ac tions.
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Evoluotton An exemption from the requirements of Section Ill.G.3 to provide fixed fire
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suppression in Fire Area U is requested, based upon the following evaluation:
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The equivalent fire se"erity in Fire Area U ls approximately 30 minutes, which consists of widely dispersed cable Insulation, and small amounts of lube oil and other incidentals.
A fire originating in these combustibles plus an assumed transient combustible is not expected to produce a fire of significant mognitude.
The installed early warning fire detection system will olert the Control Room operators to summon the plant fire brigade, which will respond and manually extinguish the fire, If the installed portial sprint <ler system hos not already done f
so. If the fire causes damage to circuits for Fan C75-2 or Louvers MV5444A,0, and C prior to the arrival of the fire brigade, alternate shutdown copstlity is provided.
This capability consists of manual operator actions to establish temporary room cooling in the CCW Pump Room.
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lt is, therefore, Toledo Edison's position that a level of protection equivalent to Section Ill.G.3 of Appendix R to 10 CFR 50 is provided for Fire Arco U.
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oddition of oreo-wide fixed fire suppression would not significantly enhance the level of fire protection provided for safe shutdown equipment.
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L FIRE AREA AB Exemption Requested l
An exemption is requested from Section Ill.G.3 of Appendix R to 10 CFR 50 to
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the extent it requires fixed fire suppression and detection in on area where alternate shutdown capability is provided.
Specifically, alternate shutdown
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capability is provided for circuits controlling ECCS Room Cooler Fans MC03t l and MC0312 within Fire Area AB.
The alternate shutdown capability is
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physically and electrically independent of Fire Area AB.
Discussion h
Fire Area AB consists of the Decay Heat Coolers Room #113, Hatch Areo
- ll3A, and ECCS Pump Room #105. The area consists of 2,589 square feet of
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floor area, with on in-situ combustible loading consisting primarily of cable insulation, grease, polyethetene, and small quantitles of lobe oil.
The total 2
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combustible loading in the area is approximately 5,000 BTU /FT, which equates to on equivalent fire severity of 4 minutes.
The fire area is bounded by reinforced concrete walls with a minimum thickness of 2 feet, and a reinforced concrete floor with a thickness of 3 feet.
Existing fire protection capability in the area consists of an oreo-wide, early warning fire detection system which alarms locally and in the Control Room.
Manual fire suppression capability in the form of portable fire extinguishers and standpipe hose stations is readily available in the oreo.
C For a fire in Fire Area AB, Train I of the safe shutdown systems is assumed to be lost, and Train 2 is used to ensure safe shutdown.
The Compliance Assessment Report describes in detail the safe shutdown analysis and consequent modificottons performed to bring this fire arco into compliance with Sec-tion Ill G of Appendix R.
In addition to these modifications, fire domoge to circuits 2PDFil92A, B, and C, 2PDFil93A, B, and C requires that alternate C
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oction be taken to ensure safe shutdown copobility.
These circuits are associated with the ECCS Room Cooler Fans C31-1 and C31-2. Fire domoge to
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h the circuits would prevent the fans from operating.
Alterrpte shu tdown f*
I capability is provided by setting up temporary ventilationsin Roorps #ll5 and
- 113. Adequate time exists to set up the portable fans before equipment in the crea exceeds critical temperatures.
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Evoluotion
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An exemption from the requirements of Section Ill.G.3 to provide creo-wide fixed fire suppreofon in Fire Area AB is requested, based upon the folloping I
i evoluotions i
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s The equivalent fire severity in Fire Area AB is approximately 4 minutes, which
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consists of cable Insulation, grease, polyethelene, and small quantitles of lube oil.
A fire originating in these combustibles plus on assumed transient is
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expected to produce a fire of insignificant magnitude.
The Installed early warning fire detection system will ciert the Control Room operators to summon the fire brigade, which will respond and manually extinguirh the fire. If the fire causes domoge to the ECCS Room Coolers alternate shutdown copobility is provided. This capability consists of monval operator actions.
It is, therefore, Toledo Edison's position that a level of protection equivalent to
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Section Ill.G.3 of Appendix R to 10 CFR 50 is provided for Fire Area AB. The oddition of a complete creo-wide fixed fire suppressloa system to this crea would
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. not significantly enhance the level of fire protection provided for safe shutdown equipment.
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FIRE AREA A Exemption Requested An exemption is requested from Section ill.G.2 of Appendix R to 10 CFR 50 to
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the extent it requires the separation of redundant safe shutdown components by 3-hour rated fire barriers. Specifically, Train I circuits in Room #124 are not separated from Train 2 circuits in Room #ll5 by a complete 3-hour rated barrier.
I Discussion Fire Area A consists of the following rooms:
Room No.
Room Description Cable Chase ll0 Passage
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l10A Passage 112 Decontamination Area ll4 Miscellaneous Waste Moniter Tank / Pump r
IIS ECCS Pump Room I-2
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l16 Miscellaneous Waste Evaporator Room i17 A Condensate Tank & Pump Room i19 Degosifier Room
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120 Valve Room 121 Waste Gas Surge Tank Room l
122 Valve Access Room
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123 Clean Waste Receiver Tank Room 124 Clean Waste Receiver Tank Room 125 Det Waste Drain Tank Room 126 Miscellaneous Waste Tank Room C
The area consists of 7,766 square feet of floor area, with an in-situ combustible
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load consisting primarily of cable insulation, grease, and small quantities of luhe
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oil. The total combustible loading in the area is approximately 8,220 BTU /FT,
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which equates to an equivalent fire severity of 7 minutes. The fire area is bounded by 3-hour fire rated reinforced concrete walls with a minimum l
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thickness of 2 feet, and 3-hour fire rated ceiling and flocr of at least (5-foot thick reinforced concrete.
Existing fire protection capability in the area consists of a partial, early woming fire detection system which alarms locally and in the Control Room. Manual fire suppression capability in the form of portable fire extinguishers and standpipe
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hose stations is readily available in the area. In addition, an automatic sprinkler system is installed in Room #124 For a fire in this area, either Train I or Train 2 are used to ensure safe shutdown, that is, Train I circuits are separated from Train 2 circuits by
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approximately 25 feet. It is expected that a fire could domoge either train, but not both. The Train I circuits are located in Rooms #123 and #124. Room #124 L
is provided with automatic suppression and detection. The Train 2 circuits are located in Room #115 which is provided with detection only. The common north-south wall between Rooms #115, #123, and #l24 will be 3-hour rated; however, a non-rated watertight door and non-rated HVAC penetrations provide access to an east-west corridor odjacent to Room #124. The wall between this corridor and Room #124 is not rated due to the need to maintain HVAC flow. Additionally, fire extension between Room #115 and Room #123 could potentially occur via non-rated walls in Room #ll6, #l l7A, and # 122.
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Evaluation An exemption from the requirements of Section Ill.G.2 of Appendix R to
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10 CFR 50 is requested, based upon the following evaluation:
The combustible loading in Fire Area A is approximately 12 minutes, which consists of widely dispersed cable insulation, grease, and lube oil.
A fire originating in these combustibles is expected to produce a fire of limited severity. For a fire occurring in Room #123, the early warning detection system will alert the Control Room operators to summon the plant fire brigade. The
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upgraded 3-hour barrier wall between Rooms #123 and #115 and sprinkler system in Room #124 is expected to prevent the fire from damaging redundant c
L DC-85-l 76 2-20
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equipment and cables in Room #115. There is a possibility that a fire in Room
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- 123 could spread to Room #122 via a non-rated wall, which could then extend into Rooms #ll7A and #ll6 through non-rated walls, and then expose redundant cables in Room #I15. The arrival of the fire brigade is expected prior to a fire being able to breach four separate, non-rated barriers to extend through these rooms. Damage to redundant circuits in Room #115 is, therefore, considered
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unlikely. If the fire occurs in Room #124, the installed early warning detection system will alert the Control Room operators to summon the plant fire brigade.
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In the interim, the automatic sprinkler system in Room #124 is expected to control or possibly extinguish the fire. This protection in conjunction with the fire brigade response is expected to prevent the fire from damaging redundant cables and equipment in Room #115. If the fire were to occur in Room #115, the detection system would provide early warning of fire conditions; however, the non-rated HVAC penetrations may permit the fire to spread to the east-west corridor adjacent to Room #124. If the fire brigade response is not in time to
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extinguish the fire at this point, it is expected that the fire may spread along the corridor, possibly breaching the wall into Room #124. The automatic sprinkler
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system in Room #124, however, is expected to suppress the fire, thereby precluding damage to the redundant cables and equipment in Room #124.
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lt is, therefore, Toledo Edison's position that a level of protection equivalent to Section Ill.G.2 of Appendix R to 10 CFR 50 is provided for Fire Area A.
The addition of complete 3-hour rated barriers or area-wide automatic suppression would not significantly enhance the level of fire protection provided for safe
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shutdown equipment.
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r DC-85-176 2-21 L
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EMERGENCY LIGHTING FOR A FIRE IN THE CONTROL ROOM OR CABLE SPREADING ROOM Exemption Requested
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An exemption is requested from Section Ill.) of Appendix R to 10 CFR 50 to the extent it requires self-contained emergency lighting units with at least on 8-hour battery power supply in all creas needed for the operation of safe shutdown
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equipment, and in access and egress routes thereto. Specifically, on exemption is requested to utilize existing "hard-wired" AC/DC essential lighting in portions of the Auxiliary and Turbine Buildings, and to utilize hand-held portable units in outside plant areas.
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Discussion For loss of offsite power conditions, plant lighting is provided by three separate
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systems: on essential AC power lighting system, o DC "hard-wired" powered lighting system, and a battery-powered lighting unit system. The essential AC
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power lighting system consists of two divisions of lighting circuits serving the Containment, the Auxiliory Building, and the Control Room.
The lighting
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circuits for the Auxiliary Building and the Control Room are automatically fed from the Diesel Generator. Lighting for containment must be manually acti-(
voted.
The DC-powered "hard-wired" lighting system consists of two divisions of
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lighting circuits serving the Turbine and Auxiliary Buildings and the Control and Cable Spreading Rooms.
The DC-powered "hard-wired" lighting system is
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normally powered from nonessential AC sources with outomatic transfer to essential DC sources.
The essential DC sources are charged by the Diesel
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Generators and would be available ir; excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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The battery-powered lighting unit system consists of numerous self-contained sealed beam units located throughout the plant. The units are rated for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
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DC-85-176 2-22 E
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In addition, a minimum of ten hand-held units are stored in the Fire Srigade
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Emergency Cabinet and are distributed to operators during a fire emergency.
These hand-held units are dedicated for operations. For outside areas, security lighting may be available to provide background lighting.
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Evaluation An exemption from the requirements of Section 111.J to provide self-contained battery-powered lighting units in all areas needed for the operation of safe
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shutdown equipment is requested based upon the following evaluation:
7 For a fire occurring in either the Control Room or Cable Spreading Room that is of sufficient magnitude to require evacuation of the Control Room, Toledo Edison has developed an alternative shutdown procedure to ensure safe shutdown
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of the plant. This procedure may require the Control Room operators to man the alternate shutdown panel as well as several other stations throughout the p' ant.
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A circuit analysis has been performed to show that the essential AC/DC hard-wired lighting system would not be disabled by a fire in either the Control Room
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or Cable Spreading Room. Several modifications were identified and are being implemented to ensure the availability of the "hard-wired" lighting circuits. In addition, the essential AC/DC hard-wired lighting system will provide illumina-
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tion for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Plant walkdowns have been performed to verify that the level of illumination produced by the combination of essential AC/DC hard-wired lighting systems and the battery-powered lighting unit system is adequate for the cperators to perform the activities required by the alternate shutdown
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procedure.
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For several outside plant areas, lighting will be supplied by hand-held units with background lighting supplied by the security lighting. The outside areas include outside area leading from screenwell to Turbine Building, outside wall adjacent to station air compressors (the diesel air compressors area).
The portable lighting can provide an equivalent level of lighting as a fixed lighting system, in
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addition, in outside areas, portable lighting provides greater flexibility than a fixed lighting system.
DC-85-176 2-23
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Testing and maintenance of the essential AC/DC hard-wired lighting system will be performed under controlled procedures to provide a measure of reliability consistent with Appendix R.
For a fire occurring in any plant area other than the Control Room and Cable Spreading Room, emergency lighting is provided by the battery-powered lighting H
system. Plant walkdowns have been performed to verify adequate illumination for all activities that must be performed in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. For outside plant areas,
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lighting will be supplied by hand-held units with background lighting supplied by
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the security lighting.
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lt is, therefore, Toledo Edison's position that a level of protection equivalent to Section Ill.) of Appendix R to 10 CFR 50 is provided by the essential AC/DC L
lighting system, as supplemented by self-contained 8-hour battery-powered lighting units and portable lighting units for outside areas.
The addition of
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8-hour battery-powered lighting units for complete coverage of all areas needed for the operation of safe shutdown equipment would not significantly enhance
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the level of safety provided for safe shutdown equipment.
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DC-85-176 2-24 i
E EMBEDDED CONDUlTS Exemption Requested An exemption is requested from Section Ill.G.2 of Appendix R to 10 CFR 50 to L
the extent it requires the separation of cables and equipment and associated non-safety circuits of redundant trains of safe shutdown equipment by a fire barrier having a 3-hour rating. Specifically, conduits embedded in concrete were not evoluoted in the safe shutdown analysis, although they do not have 3-hour fire rated protection.
The embedded conduit con be shown to be significantly
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protected given the fire loadings in the various areas because it is embedded a minimum of 4 inches in reinforced concrete walls and a minimum of 3-3/8 inches in reinforced concrete ceilings.
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Discussionn The conduit embedment depth at Davis-Sesse station is not specifically dimen-stoned on design drawings; however, the concrete cover depth con be derived as
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follows: The conduit is installed behind the surface rebor mot which is required to have o minimum of 2 inches of concrete cover over the rebars for structures containing conduit. In the cose of reinforced concrete walls, the rebor mot is comprised of two layers of #8 rebor running perpendicular to each other. Since
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the nominal thickness of #8 rebor is I inch, this configuration provides a 2-inch thick rebor mot in addition to the minimum cover of 2 inches of concrete.
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Assuming the conduit is tied directly beneath the rebor mot, a minimum embedment of 4 inches is achieved.
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In the cose of ceilings, the rebor used has a nominal thickness of 3/4 inches, which provides a rebor mot of IY2 inches for a total minimum embedment of 3Y2 inches.
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The NFPA Handbook, 15th Edition, indicates that 3 inches of concrete is capable of providing opproximately 80 minutes of fire resistance (Figure 5 8F).
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DC-85-176 2-25
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The creas at the Davis-Besse plant where embedded conduits are used were
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surveyed to determine the combustible loading in each crea. With the exception of two creas, all fire areas with embedded safe shutdown conduits are either protected by on Automatic Sprinkler System or have a combustib'e loading of 30 minutes or less equivalent severity. The two creas that are not pcotected are the E ond F Bus Low Voltage Switchgear Rooms, Fire Areas X and Y.
Fire Areo X has a combustible loading of approximately 1.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and Fire Area Y has a combustible loading of oppro):imately 2.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The combustibles consist primarily of cables in cable trays located in the upper levels of the room. The conduits in Fire Areas X and Y ore located in the floor slob only. Early warning
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fire detection is provided in each crea.
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Evaluation An exemption from the requirement to provide separation of cables and equipment and associated non-safety circuits of redundant safe shutdown trains
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with a fire barrier having a rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> is requested based upon the following evaluation: The combustible loading in the creas in question varies
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considerably. Except for Fire Areas X and Y, all areas with a combustible loading greater than 30 minutes are protected by an automatic suppression system. In the event of a fire, the installed early warning detection system will
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ciert the Control Room operators to summon the plant fire brigade.
In the it terirfi, the passive protection provided by the concrete and the active protec-tion provided by the suppression systems, in those creas so equipped, will maintain the embedded conduits free of fire damage. For Fire Areas X and Y,
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the concrete will provide at least I hour of protection. The response of the fire brigade can reasonably be expected within 30 minutes. Although the combustible
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loading in Fire Arcos X and Y exceeds I hour, the fact that the combustibles consist mainly of cable trays near the ceiling makes it unlikely that sufficient heat will be trans4 erred downward to damage the conduits embedded in the floor, prior to the arrival of the fire brigade.
f it is, therefore, Toledo Edison's position that a level of protection equivalent to Section lil.G.2 of Appendix R to 10 CFR 50 is provided by the embedded conduits
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DC-85-176 2-26
r of the Davis-Besse plant. The protection of these conduits by 3-hour rated barriers would not significantly enhance the level of safety provided for safe L
shutdown equipment.
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DC-85-176 2-27 i
E FIRE AREA D F
Exemption Requested An exemption is requested from Section Ill.G.2 of Appendix R to 10 CFR 50 to the extent it requires the separation of redundant safe-shutdown equipment inside non-inerted containments by a horizontal distance of more than 20 feet
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with no intervening combustibles or fire hazards.
Specifically, Redundant
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Containment Air Cooler Fans Cl-1, Cl-2, and Cl-3 ore located within approximately ten feet of each other.
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b Discussion
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Fire Area D is the Containment. The Concinment Air Coolers are located on the 585' elevation in Fire Zone D-15. Fire Zone D-15 consists of 3,410 square feet of w
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floor crea with on in-situ combustible loading consisting primarily of cable insulation and small quantities of grease and lube oil. The total combustible loading in the crea is approximately 5,000 BTU /FT2 which equates to on equivalent fire severity of 4 minutes.
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Existing fire protection capability in the creo consists of ionization type early warning fire detectors throughout Fire Zone D-15.
Manual fire suppression
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capability in the form of portable fire extinguishers and standpipe hose stations is available in the creo. Access to the Containment is restricted during plant
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operation due to high neutron dose levels.
The Redundant Containment Air Cooler Fans Cl-1, Cl-2, and Cl-3 are located side-by-side on the 585' elevation. The minimum separation distance between l
the fans is approximately 10 feet. One Containment Air Cooler Fon is required l
for safe shutdown. The circuits associated with the fans will be protected with radiant energy heat shields.
DC-85-l 76 2-28 i
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Evoluotion I
An exemption from the requirements of Section Ill G.2 to provide 20 feet of separation free of intervening combustibles is requested based upon the following evaluation:
The equivalent fire severity in Fire Zone D-15 is approximately 4 minutes. The Reactor Coolant Pumps located elsewhere in Containment are provided with an
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oil collection system.
Due to the restricted access to Containment during operations, the accumulation of transient combustibles is not postulated. Any fire occurring in the c eo is therefore expected to be of insignificant magnitude, in addition, the metal cabinets enclosing the fans will provide a limited amount of heat shielding. If a fire were to occur in this area, the installed early warning fire detection system will alert the Control Room operators to summon the plant fire brigade. Due to the low combustible loading in the area, fire damage to f
both trains of Containment Air Cooler Fans is considered unlikely.
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lt is therefore Toledo Edison's position that with the proposed installation of radiant energy shields between the redundant air cooler circuits, a level of protection equivalent to Section Ill.G.2 of Appendix R will be provided in Containment. Additional protection for the Containment Air Cooler Fans would not significantly enhance the level of protection provided for safe shutdown equipment.
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DC-85-176 2-29
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