ML20203D766
| ML20203D766 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/10/1986 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 1285, NUDOCS 8607210280 | |
| Download: ML20203D766 (4) | |
Text
TOLEDO EDISON Docket No. 50-346 JOE WlLUAMS. JR Serwr Wa Pret.dsnt - Nudear
[419)249 2300 License No. NPF-3 I4' S124"223 Serial No. 1285 July 10, 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:
In our letter of June 3, 1986, (Serial No. 1253), Toledo Edison committed to provide the NRC with a status of our major Fire Protection program activities. This letter presents a summary description and identifies the overall status of these Fire Protection program activities. As indicated in our June 3, 1986 letter, we are prepared to discuss all of these activities with the NRC at a meeting in the near future.
Toledo Edison's Fire Protection program is multifaceted aad includes the following major areas of activity:
(1) Achievement of Ccempliance with 10CFR50, Appendix R:
(2) Assessment of the installation adequacy of fire dampers in accordance with the manufacturer's recommendations; (3) Verifi-cation of Fire Penetration Seal Configurations to specific test documentation; (4) Verification of the design adequacy of fire barrier penetration seals installed throughout the plant; and (5) Review of the design of the fire suppression system at Davis-Besse.
1.
Achievement of Compliance with 10CFR50, Appendix R On June 3, 1986, Toledo Edison (TED) submitted Revision I to the Appendix R Compliance Assessment Report (CAR) (Serial No. 1253) as part of our response to the deficiencies identified during the July 25-29, 1983 NRC audit of Davis-Besse compliance to 10CFR50 Appendix R.
The CAR detailed the Davis-Besse level of compliance with respect to the requirements of 10CFR50 Appendix R Sections III.G, J. L, and O.
The finalization of the revised CAR, with the identification of the physical modifications required to meet Appendix R requirements, was affected by the completion of the Auxiliary Feedwater Reliability study and resulting modifications as well as the change in Toledo Edison's philosophy related to previous exemption requests.
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' Docket No. 50-346 License No. NPF-3 Serial No. 1285 July 10, 1986 Page 2 Within the Appendix R safe shutdown analysis, eleven instances were identified in which plant modifications required to meet the requirements of Appendix R would not provide a significant increase in Fire Protection.
In these instances, exemptions vere requested from the requirements of Appendix R,Section III G.2, III G.3, or III J.
The physical modifications identified within the CAR have been prioritized and will be implemented in phases, prior to the end of the sixth refueling outage, as committed to in our letter dated September 26,1985 (Serial No.
1186). Procedural revisions required by the CAR will be completed prior to plant restart from the current outage.
2.
Assessment of Fire Damper Installations With regard to fire damper installations, a recent walkdown identified installation deficiencies that may impact damper operability in the event of a design basis fire. As a result of these deficiencies, LER 86-10 has been developed and submitted. The LER discusses compensatory measures, in the form of hourly fire watches, in place and the plans being implemented to adequately resolve the damper operability concerns and therefore the fire barrier adequacy.
The installation deficiencies for fire dampers required in barriers providing redundant train separation to meet the requirements of Appendix R will be corrected by the completion of the fifth refueling outage. Fire damper installation deficiencies in the remaining fire barriers will be corrected prior to completion of the sixth refueling outage.
3.
Verification of Seal Configuration to Specific Test Documentation In response to NRC Inspection Report No. 50-346/86006 (Log No. 1-1342),
Toledo Edison submitted a letter dated June 23, 1986 (Serial No. 1267) to the NRC providing detailed test documentation supporting Davis-Besse fire barrier penetration seal configurations.
Based upon the submission of this documentation, we believe the NRC Region III restart item 346/85028-01 associated with this issue has been adequately addressed.
4.
Fire Barrier Penetration Seals In order to verify penetration seal adequacy, multiple activities are being implemented with regard to fire barrier penetration seals including; the reinstallation of all boot seals, a design verification effort of penetration seal installations against barrier functional requirements, and the performance of a surveillance test (ST) to ensure penetration seal degradation is within acceptance criteria.
- *Dockst No. 50-346 License No. NPF-3 Serial No. 1285 July 10, 1986 Page 3 With regard to boot seals, Toledo Edison actions have been detailed in our response to NRC Inspection Report No. 50-346/85028 by letter dated December 26, 1985 (Serial No. 1-600) and LER 86-005. Our current status is.that all boot seals required to support the negative pressure barrier requirements and the flood requirements have been reinstalled. Boot seals necessary for fire barrier requirements are being expeditiously reinstalled in an-attempt'to complete as many as possible prior to restart. Compensatory measures in the form of hourly roving fire watches have been implemented until seal operability is restored.
Special Report 86-017 concerning penetration seal installation deficiencies provide additional explanatory information with regard to penetration seal deficiencies identified thus far. The planned barrier verification activities are intended to, upon their completion, demonstrate the accept-ability of fire area boundaries throughout the Davis-Besse Nuclear Power Station. A completion schedule can not be determined for these-activities at this time. We will keep you informed of the surveillance test and design verification program results with periodic updates of Special Report 86-017.
5.
Fire Suppression System NRC concerns with regard to NFPA Code deviations were identified during the July 25-29, 1983 Fire Protection Appendix R inspection of fire suppression systems installed at Davis-Besse. This inspection is docketed in Inspection Report No. 50-346/83016, dated August 30, 1984, (Log No. 1-1024). As a result of the NRC concerns, TED commissioned a design review of the fire suppression system installations. This review resulted in recommendations for certain upgrades to specific fire suppression systems. To address those deficiencies, Toledo Edison has committed to upgrade those suppression systems to the requisite NFPA Codes in eight fire areas requiring suppression to meet the requirements of Appendix R.
This action will be completed prior to the completion of the sixth refueling outage. Specific minor code deviations which may be necessary due to interferences, etc. will be justified. As part of the longer term plant upgrade program, the non-Appendix R required fire suppression systems will be assessed against the fire hazards of concerns and necessary upgrades to code requirements will be made. These upgrades will take place subsequent to the Appendix R suppression system upgrades.
As part of the ongoing Toledo Edison Fire Protection Improvement effort, reviews may uncover the need for additional corrective measures within the-Fire Protection Program. Your office will continue to be notified of such measures within the normal reporting process.
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- 'Docket No. 50-346 License No. NPF-3 Serial No. 1285 July 10, 1986 Page 4 In recognition of the analysis completed, the low probability of a fire, the fire protection features and controls existing ~in the plant and the compensatory measures instituted, Toledo Edison believes that the Fire Protection Program at Davis-Besse is adequate to protect the health and safety of the public.
Very truly yours, Joe LtfdLQ M, Tr. Q JW:TJB:p1f cc:
DB-1 NRC Resident Inspector NRR Project Manager Region III - J. Ulie f
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