ML20151H856
| ML20151H856 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Davis Besse |
| Issue date: | 09/19/1983 |
| From: | Johnston W Office of Nuclear Reactor Regulation |
| To: | Lainas G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082321542 | List: |
| References | |
| FOIA-88-92 TAC-52156, NUDOCS 8309270357 | |
| Download: ML20151H856 (6) | |
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SEP 19193 5
MEMORANDtN FOR: Gus Lafnas, Assistant Of rector for Operating Reactors Olvision of Licensing FRQ1:
Wl11 tam Y. Johnston Asststant Director Materials, Chemical,& Enyfrorvoental Technology Division of Engineering
SUBJECT:
REGION !!! REQUEST FOR TECHNICAL ASSISTANCE - DAVIS-BESSE PLM/ SAFE SHUTDOWW/ FIRE PROTECTION DEFICIENCIES
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(TAC f52156) j By memorande dated August 12,1983 (R. L. Spessard to D. G. Eisenhut),
Regfon !!! requested technical assistance concerning the recent findings of the NRC inspection tems at the Davis Beste plant in the area of safe shutdown / fire protection.
By letter dated September 13, 1983 the Itcensee has suhnf tted infor-mation on the short-tem and long,em ections that will be taken to t
bring the plant into compliance with Section !!!.G. !!!.J. and !!!.0 of Appendfx R.
This letter also provides the Ifeensee's basis for startup and operation of the plant following the current refueling outage.
We have reviewed the safety significance of the inspection findings and the Ifeensee's proposed remedfal actions.
Our review is based on the audit findings orally presented at the audit extt interview and subsequent meetings with the Ifcensee on August 16 1983 and Septem-ber 14,1983 The findings are summartzed in the Ifeensee's letter of September 13, 1983.
It is our opinion that the short-tem cepen-t satory actions to be taken prior to startup after the current refueling outage provide an acceptable level of fire rotection safety to pemf t continued operation pending completfon of tw long-tem actions.
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1.
.Eneroency Lighting Desfon The emergency ifghting does not meet the requirements of Appendfx R with respect to equipment operation, access and egrecs routes, testing, Ifghting intensity, positioning and installation.
The Itcensee has developed an interfa procedure for rostoring nomal plant Ifghting in the event of a fire in the control room or cable spreading rom. Portable Ifghting units have also been
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e Gus Lainas i purchased and stored in & convenient locatfor, and reserved solely for the control roon operators. We find this addf tional energency ifghting capability an acceptable interim neasure untti the Itcensee can perforts the proposed long-tersi correttive actions.
2.
Fire Doors Two fire doors, designated as doors 215 and 217, are not labeled as UL approved.
The itcensee has reviewed the available doctrientation and detemined that of the two deficient fire doors, one is a 3-hour rated assembly, and the other is part of a two-door airlock where the outer door is a 3-hour rated essembly.
We find this acceptable as ineeting our guidelines.
3.
_ Reactor Coolant Pump Oil Collection System The reactor coolant purnp oil collection holdup capacity cannot accomodate the entire lubricating oil system inventory as required by Section III.0 of Appendix R.
The licensee has reviewed drawings and concluded that any overflow from the RCP oil collection system tank will flow to a location in the contain-1 A review of as-built conditions will be made to confirm that ment sump.
the overflow from this tank presents no safety problen. An exeeption from our requirecent will be requested in the future.
Based on the configuration of overflow ifnes, we find the pre:ent RCP oil co11cetion system an acceptable derivation from our requirement, pending verification of as-built conditions and evaluation of the future exemption request.
4.
Fousekeeping
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Wooden scaffolding was found stored in Mechanical Penetration
' Room 3 since April 30, IM3, and scrap wood and sawdust were i
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present in the room.
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The licensee has developed a maintenance procedure which addresses tighter control on the use and storage of transient combustible materials in the plant. Pending acceptance of the procedure by Region !!!, we find this an acceptable corrective action.
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Fire Damper Inoperability Three dampers wre inoperable with no fire watch for a period of approximately two to three renths due to personnel error and an inadequate test procedure.
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The Ifeensee has revised the surveillance test procedure for fire derers to provide explicit guidance on the testing of fire dar-pers to insure their operability. All dampers tested and found inoperable will be rotested prior to startup.
we find this an acceptable corrective action.Pending acceptance of the proced 6
Service Water Of scharce Valve Room i
Otscharge valves and local controllers are exposed to a sfnole disabling fire in violation of Section III.G of Appendix p.
One hour wrap deffcfencies exist and there is partial versus full suppression capability in the room.
The Ifcensee has modifled the plant operating procedures to allow de-energizing the motor operator for one of the service water discherge valves. Therefore a fire involving the valve will cause t c to fail in the as-is (open) po,sition thereby ensuring service water flow.
A lonq-tem review will be conducted to assess Appendfx R compliance. We find thf s to be an acceptable interim solution.
7.
_One Hour Fire Barriers The adequacy of the Kaowool wraps was lef t as an open item with the following cuents:
The test report in support of credtting the wraps as one-hour a.
barriers was inconsistent and inadequate.
b.
The test report did not address configurations existing at Davi s-Be.e se.
The one hour wraps are incomplete, poorly installed, and c.
not in accordance with the test installation.
Prior to startup, the ifcensee will correct the deffetenctes in the installation and will provide a roving fire watch patrol in areas protected, in part, by these fire barriers, and which have a combustible loading exceeding 20,000 BTUs/FT2.
A long-tem study will be made to substantiate the fire resisting cap-ability of the fire barrier.
corrective action.
We find this to be an acceptable interim 8.
Fire in the Auxiliary Shutdown Panel A fire in the auxfitary shutdom panel can cause a loss of both trains of the auxiliary feedwater pump governor control circuttry.
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Gus Lainas The licensee has perforued an analysis of the possibility of losing all auxiliary feedwater turbine controls due to a fire at the auxiliary shutdown panel. The control would only be lost if a fire occurred in the panel, concurrent vith the loss of offsf te power.
The startup feed pump could then be utfitzed with existing procedures.
will be made to consider rerouting cables in the panel. A loag-tem steady We find this an acceptable interim corrective 6etion for fire protection.
The inspection team also identiffed a number of deffefencies relateri to the plant's routine fire protection program, including:
j Diesel Fire Pump Test Procedure The diesel fire pump test procedure was not written nor the test perfonned in accordance wf th !FPA 20 reoufrements.
Fire Hose Stations Fire tose sutions are not in accordance with IFPA 14 require.
monts to hr <e pressure reducers on standpipes.
Fire Doce Hodt fications Modifications were ciado to the fire tfoor to roori 320 wf th no documentation.
Sprfntler Systeci Routing of water suppression below cable trays located near the ceiling is in violation of WPA STD-13 and.16 and license Amendnent 18 Yard Hydrants and Yalves i
No physical barriers exist around sone yard hydrants / valves.
Fire Ptrip Test The fire pump test is not in accordance with 5FPA as stated in the FSAR.
Control of Coebustibles A proceduro does not exist for control of combustibles.
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Fire Protection System Flush The fire protection system flush and valve operation is perfomed 3
every three years instead of every year as required by WPA.
u4 Fire Detector Maintenance k
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,i Dust acctmulation requires photoelectric detector adjustment.
Procedurts do not address this.
Fire Door and Damper Mainterar,ce b
t Procedures for fire door ar.d damper maintenance identified no survol11ance from 1978 until recently. WPA requires a monthly
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visual check as a afnfatss.
n Emereeney Lfghtfr,g. Surveillance Procedures should be revised to pe-fom survef11ance quarterly X
instead of semi-annually.
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Off-Site Fire Department Training
{gl-The level of trafning, knowledge and responsibility for off-site fire departmnt assistance is inadequate.
yelding Pemits
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Welding pemits are not to be fssued for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Davisquired in WPA 51 and 518. Weekly pemtts are allowed at as re Besse.
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Sprinkler Tests I h-The 1980-1983 sprinkler tests are inadeguate relative to WPA.
_Off-Site Contractors Fire Watch Trainin }
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Off-$f te contractors are inadequately trained as fire watches.
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The fire protection effort appears understaffed relative to Admint-strative Procedure AD 1810.00 and License keeneent 18.
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1 The ahove listed deffctencies n nomal fire prouction progran.oted by the audit team concern the plant's It is our concern that these deffefencies
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.I be corrected as trt of the defense-in-depth concept of the plant's fire
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SEP I S 19 s Gus Lainas (
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.l protection program.
As such, the proposed short-term and long-term i
corrective actions appear to provide an acceptable response, provided these actions satisfy the concerns of the Region III Inspectors.
The inpact of these deficiencies on the fire protection for for safe shut-t down is censidered negligible.
Tharefore, we considered the proposed short-term corrective actions and long-term commitments adequate for continued operation of the plant.
/3 William V. Johnston, Assistant Of rector Materials, Chemical & Environmental Technology Division of Engineering cc:
R. Vollmer D. Eisenhut V. Benareya R. Ferguson T. Wambach R. Eberly S. Pawlick!
T. Sullivan
- 0. Parr J. Werrnell J. Taylor J. Stoltz A. Deagazio F. Rosa M. Srinivasan j
S. Ebneter, Reg. 1 T. Conlon, Reg. Il C. Norelius, Reg. 111 G. Madsen, Reg. IV P. Sternberg, Reg. V 55 c.
't DISTRIBUTION Cocket File ~
CHEB Reading CMEBPlant(Davis-Besse)
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OCT 2 4 19 83 HEMORANDUM FOR: Edward L. Jordan, Otractor. Olvision of Emergency Preparedness and Engineering Response FROM:
Darrell G. Eisenhut. Director. Division of Licensing. NRR
SUBJECT:
BULLET RESISTANT FIRE DOORS On November 28 1982 NRC position on, accep, table bullet resistant fire doors in vital areas nuclear power plants. This request was relayed to NRR/DL by TIA 83 02.
t We have completed our reytew of the request and the associated letter from the Underwriters Laboratory dated December NRC position on bullet resistant fire doors is enclosed.20.1962 (copy enclosed). T Guidance on bullet resistant fire doors will be included in a generic letter to all Itcensees which will provide guidance on several recent fire protection issues.
completes our action under TIA No. 83 02.
This f
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. Et ctor Olvision of Licensing Office of Nuclear Reactor Regulation
Enclosures:
As stated cc G. Halohan, ORAB R. Starosteckt. Region !
J. 01shinskt. Region !!
C. Norelius, Region !!!
J. Cagliardo, Region !Y T. Bishop. Region Y V. Benaroya, CHER T. Wambach, ort 5 R. Wessman, AD/SA i
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DUttET RESISTANT FIRE DOORS FOR NUCLEAR POWER PLANTS Branch Technical Position CMEB 9.5.1, paragraph C.S.a(S) describes the Regulatory Guidelines for door openings in fire barriers.
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Fire Protection Association (NFPA), Fire' Protection Handbook, 14th The National Edition, dated 1976, Section 6, Chapter 8, on protection of openings in fire barriers accepted means, states in part, "Fire doors are the most widely used anc*
for protection of both v'ertical and horizontal openings.
Suitability of fire doors is determined by test by nttionally recognized testing laboratcries effective protection., and doors not tested cannot be relied upon fo field."
Only labeled fire doors that have successfully passed fire testing by nationally recognized, or artified (by the Consumer Product Safety Commission ever, in so)me instances. HRC requirements call for dua Fire Testing Laboratories satisfy these requirements.
How-doors for protection of yenings in walls.
In addition to fire protec,-
i tion, the requirements for pressure boundarles water integrity securit or radiological protection must also be satisfhd at :ome instahettons.y Based on the combination of hazards a pa'rticular door is required to protect eghinst, unlabeled multijurpose fire doors have been found accept-able in some instances.
dimensions of standard prototype (tre doorsWre tw opening in a fire barrier e unlabeled doors may be found acceptable due to the commercial unavailability of tested doers of the same dimensions and configuration.
will have no fire resistive rating because their substantial stracturalM char'actoristics are difficult to combine with the construction of fire doors.
NRR's acceptance of these deors is identified in the SER as an
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acceptable deviation from our guidelines.
Where such devietion is not a
b found in the SER, the licertste should have labeled fire rated doors.
Note that only since Janualy 1,1983,to ar dtho Underwriters Labo has authorized several manufacturers o uce UL clasrified fire door assembites that have also been successfully evaluated for bullet res(stant ratings.
combination label on each door which referenc resistant rating, along with sup such as temperature rise rating.plements'. Information for the door assembl-4 e
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