ML20214P240

Discusses 870217-18 Meetings W/Nrc Re Request for Addl Info Concerning Fire Protection.Slide Presentation,List of Attendees & Documentation of Util Response to NRC Questions encl.W/11 Oversize Drawings

ML20214P240
Person / Time
Site:	Davis Besse
Issue date:	05/27/1987
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20214P242	List: ML20214P240 ML20266H069 ML20266H073 ML20266H077 ML20266H081 ML20266H086 ML20266H093 ML20266H097 ML20266H102 ML20266H107 ML20266H112
References
1361, TAC-60994, TAC-60995, TAC-61745, NUDOCS 8706030265
Download: ML20214P240 (200)

Text

{{#Wiki_filter:---- --- TOLEDO Docket No. 50-346 EDISON License No. NPF-3 DONALD C. SHELiON v..n e = 3erial No. 1361 M'H m m May 27, 1987 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

Subject:

Fire Protection - Request For Additional Information (TAC Nos. 60994, 60995, and 61745) Gentlemen: In letter dated December 17, 1986 (Log No. 2166), the NRC transmitted a Request for Additional Information (RAI) regarding Fire Protection and requested a meeting to discuss the issues. A meeting was held on February 17 and 18, 1987. Meeting representatives from Toledo Edison and the NRC are listed in Attachment 1. The uiceting began with an introduction and with Toledo Edison briefly discussing the Davis-Ilesse Fire Protection Program, its fire protection modifications and enhancements, and its commitment to resolve the NRC's concerns. The NRC stated that it would not re-open issues previously reviewed and closed in the Davis-Ilease Fire Protection Safety Evaluation Report (SER) dated July 26, 1979 (Log No. 409). The NRC also advised Toledo Edison that. It would be advantageous to document any deviations f rom NRC guidance contained in Appendix A to IITP APCSB 9.5-1. During the two days of discussions Toledo Edison presented its responses to cach question in the RAI and responded to additional NRC questions on certain Change Notices to the Davis-Desse Fire llazard Analysis Report, the exempt. ion requests as amended in Toledo Edison's letter dated January 12, 1987 (Scrial No. 1327), and penetration seals as discussed in Toledo y Edison's letter dated February 12, 1987 (Scrial No. 1352). A copy of the A slides presented to the NRC during the meeting is provided as Attachment 2. At the conclusion of the meeting, the NRC requested Toledo Edison to vs document. Its response to the NRC's quest.fons. provides such Q a response to cach of the 48 questions of the RAI and to the additional Q l*4 NRC questions. For those quest. ions Toledo Edison felt were not resolved K si by the enclosed response, discussions of the actions to resolve the NRC's

• Q questions and completion schedules have been provided. These resolutions were discussed between representatives of Toledo Edison and the NRC o

g during the February meeting and in a subsequent. telephone conversat. ion on q' N.iy 1, 1987. Additionally, in letter dated January 21, 1987 (Scrial No. 1340), Toledo Edison stated that the current Davis-Ilesse Fire Protect.lon N Program is in conformance with Appendix A to IITP APCSB 9.5-1 as accepted by the NRC SER. 3. THr int rno rninnN COMPANY EDIGON PL AZA 300 MADISON AVENUE TOLEDO. OHto 43052 k 0706030265 070527 PDH ADOCK 05000346 F PDR

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Page 2 In summary, Toledo Edison believes that the meeting has proven to be a heneficial means to document the capabilities of the Davis-llesse Fire Protection Program and to respond to the NHC's questions. Toledo Edison would be pleased to meet again and further discuss any additional NRC questions if desired by the NRC. Toledo Edison will continue to keep the Davis-llesse NRR Project Manager, Mr. A. W. dea,;azio, abreast of the progress of the Davis-liesse Fire Protection Program. Very L-

yours, DCS:,L:plf cc Dll-1 NRC Resident inspector A. B. Davis, Regional Administrator (2 copies)

Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 I Attachment I l ATTACHHENT 1 i HEETING REPRESENTATIVES The following representativen from Toledo Edison and the NRC attended the Fire Protection meeting on February 17 and 18, 1987. Toledo Edison NRC l J. DeConta J. Fay J. Grundman A. DeAgazio J. Haverly D. Kubicki N. Lalor H. Hurtha H. Peters, Jr. l

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I i CUESTION F2 CUESTIGN: AhhutGS FIRE BARRIER EESFCASE: EXEMPTION REQUEST WITiiDPJn1 ANNULUS CONSIDEEED PART OF CONTAINMENT TOLEDO EDISON LETTER DATED JANUARY 12, 1987 (SERIAL NO. 1327) DOCUMENTS EXEEPTION DELETION JUSTIFICATION e

l QUESTION #3 00ESTI0!i: CONTE 0L ROOM EFERGENCY VENTILATION (CREV) SEPARATION RESP 0 HSE: NOT PRACTICABLE TO SEPARATE CREVS EQUIPMENT SEPARATION PROBLEMS INCLUDE REDUNDANT CABLES, FAN UNITS, CHILLERS

FILTERS, ETC.

FIRE AREA HH DESCRIBED IN FHAR (5.HH-2) AND CAR (4.HH-5)

1 QUESTION #4 QUESTION: HAND HELD LIGHTS JUSTIFICATION

RESPONSE

HAND HELD LIGHTS ARE INTERIM ACTION NRC ACCEPTED THIS POSITION IN IR 83-16 PART 2 ITEM 83-16-05 FINAL PLAN IS FOR HAND HELD LIGHTS FOR OUTDOOR ACCESS / EGRESS ONLY ACCESS / EGRESS OUTD0 ORS IS OVER LEVEL GROUND OBSTRUCTIONS ARE APPROPRIATELY LIT BY HAND HELD, BATTERY POWERED OR AC & DC HARD WIRED LIGHTS HAND HELD LIGHTS INCLUDED IN SURVEILLANCE PROCEDURES

9 00ESTION #5 00ESTION: DIFFERENCE BETWEEN " COMPLY" AND " POSITION (COMPLY)"

RESPONSE

NO DIFFERENCE BETWEEN " COMPLY" AND " POSITION (COMPLY)" - FHAR WILL BE REVISED BTP APPENDIX A NFPA CODE, AND OTHER NRC GUIDANCE DEVIATIONS ARE BEING SUMMARIZED FOR NRC INSPECTION AS THEY ARE COMPLETED

QUESTION #6 QUESTION: INDEPENDENT SPRINKLERS AND HOSE STATIONS

RESPONSE

THERE ARE 5 SPRINKLER / STANDPIPE SYSTEMS ON A SINGLE SUPPLY PIPE IN FIRE AREAS WITH REDUNDANT CAR SAFE SHUTDOWN EQUIPMENT ALTERNATE BACKUP SUPPRESSION IS AVAILABLE IN ALL CASES PER TECHNICAL SPECIFICATION REQUIREMENTS

QUESTION 7# QUESTION: AUDIT FINDINGS IN PRE-FIRE PLANS

RESPONSE

TASK #8 - FIRE PROTECTION MANUAL PREPLANS REVIEW AS DESCRIBED IN A LETTER DATED SEPTEMBER 13, 1983 (SERIAL NO. 986) WAS COMPLETED BY AUGUST, 1985 CURRENTLY ADDITIONAL REVISIONS ARE BEING MADE TO FURTHER ENHANCE THE PRE-FIRE PLANS

OUESTION #8 QUESTION: OA COMPLIANCE WITH FUNCTIONAL RESPONSIBILITIES

RESPONSE

THE SPECIFIC QA DEVIATION FROM THE NRC STAFF GUIDANCE ON FIRE PROTECTION FUNCTIONAL RESPONSIBILITIES WAS DOCUMENTED IN FHAR REVISION 4, SUPPLEMENTAL QUESTION 2 (SERIAL NO. 468) DEVIATION INVOLVES INABILITY TO BACKFIT QA STANDARDS TO EXISTING EQUIPMENT

QUESTION #9 QUESTION: BUS DUCT, SEISMIC GAP, CONDUIT SLEEVE FIRE SEALS

RESPONSE

BUS DUCTS - FIRE STOP INTERNALLY WHERE REQUIRED - UNDER ASSESSMENT SEISMIC GAPS - MATERIAL UNDER EVALUATION FOR ACCEPTABILITY SPARE CONDUIT SLEEVE DETAILS ARE COVERED IN THE FEBRUARY 12, 1987 i SUBMITTAL (SERIAL NO. 1352) TO NRC i i 1

1 s 1 QUESTION #10 QUESTION: IMPACT OF SECURITY MODS ON FIRE D0 ORS

RESPONSE

NO DEGRADATION OF FIRE DOORS BY SECURITY MODIFICATIONS DOCUMENTED BY NFPA 80 CODE EXPERT (0UTSIDE CONSULTANT) LER 86-27 REVISION 1 DOCUMENTS FIRE D00R EVALUATION L

~ .e QUESTION #11 QUESTION: HFSPOND TO PENETRATION SEAL TESTS

RESPONSE

TOLED0 EDIS0N LETTER DATED FEBRUARY 12, 1987 (SERIAL NO. 1352) RESPONDS TO NRC QUESTIONS ON FIRE BARRIER PENETRATION SEAL TESTS

3 QUESTION #12 QUESTION: 1)FSCRIBE KA0 WOOL FIRE TEST RESULTS

RESPONSE

NECESSARY KA0 WOOL FIRE WRAPS WILL BE REPLACED THE NEW MATERIAL WILL BE INSTALLED TO ADEQUATELY ACCOUNT FOR SUPPORT STEEL OR OTHER POTENTIAL HEAT SINKS O e

1 QUESTION #13 QUESTION: FIRE SEAL PROTECTED SIDE TEMPERATURE LIMITS

RESPONSE

TOLEDO EDISON LETTER FEBRUARY 12, 1987 (SERIAL N0. 1352) PROVIDES A RESPONSE ON THE TEMPERATURE LIMITS AROUND METAL PENETRATIONS

l QUESTION #14-QUESTION: SM0KE DAMAGE TO UNEXPOSED REDUNDANT SHUTDOWN SYSTEMS

RESPONSE

9 FHAR DESCRIBES SM0KE REMOVAL UTILIZING: VENTILATION SYSTEM REMOVAL PORTABLE FANS WITH ELEPHANT TRUNKS SM0KE IS ROUTED OUTSIDE OR TO A ROOM WITH OPERABLE VENTILATION

4 QUESTION #15 av Q!!ESTION: DAMPER CLOSURE UNDER AMBIENT AIR CONDITIONS

RESPONSE

APPENDIX R BARRIER FIRE DAMPERS TO BE REPLACED THE PROCUREMENT DOCUMENTATION REQUIRES CERTIFICATION OF OPERABILITY UNDER SPECIFIED AIR FLOW CONDITIONS VISUAL INSPECTIONS-PER TECHNICAL SPECIFICATTON PERFORMED

QUESTION #16 QUESTION: CONFIRM UNSPRINKLERED CHARC0AL IS CONSIDERED IN FHAR

RESPONSE

FHAR INCLUDES CHARC0AL IN FIRE LOADS - EXAMPLE FIRE AREA EE

QUESTION #17 QUESTION: ADEQUACY OF RADIO COMMUNICATION

RESPONSE

FIXED REPEATER ON AUXILIARY BUILDING ROOF WITH PASSIVE ANTENNA SYSTEM IN AUXILIARY BUILDING SOUND-POWERED PHONES ADDED TO SUPPLEMENT RADIOS (FCR 83-129) COMMITMENT TO VERIFY RADIO COMMUNICATION PART OF INSPECTION REPORT 85-28, DATED NOVEMBER 22, 1985 (SERIAL NO. 1-1280) COMMUNICATION SYSTEM TEST RUN 2/86 (PT 5108.01) ADDITIONAL TESTS WILL BE SCHEDULED AFTER RETURN TO FULL POWER SINGLE SYSTEM ALLOWS SHIFT SUPERVISOR TO COMMUNICATE WITH OPERATORS AND FIRE BRIGADE

t OUESTION #18 QUESTION: VISUAL AND AUDIBLE ALARMS TO CONTROL ROOM

RESPONSE

FIRE DETECTORS ALARM IN THE CONTROL ROOM BY VISUAL AND AUDIBLE MEANS FHAR TABLE 4-1 (SHEET 55) PROVIDES A MORE DETAILED DESCRIPTION THAN SHEET 49 REFERENCED IN THE QUESTION

QUESTION #19 QUESTION: CONFIRM FIRE DETECTORS SATISFY NFPA 72E

RESPONSE

DETECTOR SPACING ADDRESSED BY SER AS DOCUMENTED IN FHAR, REV. 2 (0UESTION #17) INSTALLED DETECTION COMPLIES WITH COMITMENTS SOME DEVIATIONS FROM NFPA 72E SPACIAL CRITERIA ARE EXPECTED - JUSTIFICATION WILL BE AVAILABLE FOR NRC INSPECTION I

1 I QUESTION #20 l QUESTION: LONFIRM SPRINKLERS CONFORM TO NFPA 13-i

RESPONSE

j SPRINKLER SYSTEMS ADDRESSED BY SER AS DOCUMENTED IN FHAR, REV 2-5 (0UESTION 4, 8, 11, 13, 19, 21, 22, 26, 27, 29 AND 35) INSTALLED SUPPRESSION COMPLIES WITH COMMITMENTS SOME DEVIATIONS FROM THE GUIDANCE OF NFPA 13 ARE EXPECTED - JUSTIFICATION l WILL BE AVAILABLE FOR NRC INSPECTION i I l i 4 i i

l QUESTION #21 QUESTION: IIMITED FIRE DAMAGE TO CONTROL ROOM

RESPONSE

COMPLETE LOSS OF CONTROL ROOM IS ASSUMED IN THE CAR FHAR TABLE 4-1 (SHEET 74) PROVIDES A REALISTIC DISCUSSION OF CONTROL ROOM FIRE SPREAD / DAMAGE CLARIFICATION HAS BEEN MADE TO FHAR

. QUESTION #22 QUESTION: SIMPLIFIED FLOW CHART

RESPONSE

-+ SECTION 7 0F THE CAR PROVIDES ALTERNATIVE SHUTDOWN SYSTEM FLOW DIAGRAMS (PSID'S) PRID'S HAVE BEEN SUBMITTED TO OUR NRC PROJECT MANAGER ADDITIONAL SIMPLIFIED FLOW DIAGRAMS WILL BE SUBMITTED IF NEEDED

QUESTION #23 QUESTION: COMPONENTS FAIL TO MOST DETRIMENTAL POSITION

RESPONSE

MOST DETRIMENTAL POSITION ASSUMED IN PROCEDURES ONLY CREDIBLE FAILURES DISCUSSED IN PROCEDURES

4 QUESTION #24 QUESTION: f(EACTOR COOLANT PUMP SEAL INJECTION

RESPONSE

TEST RESULTS SHOW NO NEED FOR RCP SEAL COOLING FOR 39 HOURS PROCEDURES AND CAR WILL BE REVISED UPON LOSS OF SEAL COOLING, OPERATOR ACTIONS WOULD BE INITIATED i l l I A

QUESTION #25 QUESTION: SilllTDOWN TIME OF 193 HOURS (EXEMPTION) OR 277 HOURS (CAR)

RESPONSE

193 HOURS TO ACHIEVE COLD SHUTDOWN IS CORRECT CAR HAS BEEN REVISED

QUESTION #26 0UESTION: 11~ NOTICE 86-79 FIRE PROTECTION IMPLICATIONS

RESPONSE

ISSUE IS UNDER EVALUATION EVALUATION RESULTS WILL BE PROVIDED TO NRC WHEN COMPLETED

i J l QUESTION #27 i 4 QUESTION: CONFIRM ANALYSIS OF ALL AUXILIARY SYSTEMS l

RESPONSE

i i EVALUATED SAFE SHUTDOWN SYSTEMS ARE IDENTIFIED IN CAR APPENDIX A J i 1 4 i 4 I

QUESTION #28 QUESTION: I'l'OTECTION OF VALVE OPERATORS

RESPONSE

NO PROTECTION NEEDED FOR VALVE OPERATORS MANUAL ACTIONS REQUIRED ASSUMED NO MANUAL VALVE ACTIONS WITHIN ONE HOUR INSIDE FIRE AREAS OTHER THAN TURBINE BUILDING CAR HAS BEEN REVISED TO REFLECT THIS ASSUMPTION i

e 4 00ESTION #29 OUESTION: lilGH-LOW PRESSURE INTERFACE ASSUMPTION

RESPONSE

HIGH-LOM PRFSSilRE EVALUATION REVISED CAR WILL BE REVISED NO MODIFICATIONS OR PROCEDURE CHANGES REQUIRED 9

) QUESTION #30 OUESTION: BASIS FOR NO SPURIOUS ACTUATION OF " REPRESENTATIVE" CIRCUITS

RESPONSE

CIRCUITS EVALUATED FOR SPURIOUS POTENTIAL FROM: OPEN CIRCUIT HOT SHORTS SHORT TO GROUND CIRCUITS NOT CAPABLE OF CAUSING SPURIOUS ACTUATION EXCLUDED FROM FURTHER ANALYSIS l

m QUESTION #31 QUESTION: Al> DRESS ASSOCIATED CIRCUIT CONCERN OF IR 83-016

RESPONSE

MODIFICATIONS / PROCEDURAL CHANGES IDENTIFIED IN RESPONSE TO IR 83-016 DATED NOVEMBER 7, 1986 COMMITMENTS COMPLETED REVISED ANALYSIS UNDER REVIEW FOR IMPACT ON CAR /

1 QUESTION #32 QUESTION: SIATUS OF TECH SPEC REVISIONS

RESPONSE

DRAFT TECH SPEC REVISIONS PRESENTED TO ONSITE AND OFFSITE SAFETY REVIEW BOARDS DRAFT TECH SPEC REVISIONS UNDER FURTHER REVIEW BACKUP SERVICE WATER PUMP NOT CONSISTENT WITH SCOPE OF TECHNICAL SPECIFICATIONS CAR HAS BEEN REVISED

a QUESTION #33 QUESTION: ADDRESS ALTERNATIVE SHUTDOWN CONCERNS IN IR 83-016

RESPONSE

CAR PROVIDES COMMITMENTS TO ESTABLISH ALTERNATIVE SHUTDOWN ADDITIONAL DISCUSSION IN A RESPONSE TO IR 83-016 LETTER DATED NOVEMBER 7, 1986

9 ) QUESTION #3f4 l QUESTION: ilSI' 0F PROCEDURE FOR FIRE AREA A

RESPONSE

i l PROCEDURE INFORMS OPERATOR OF POSSIBLE ALTERNATIVES PROCEDURE REQUIRES SYMPTOM BASED ACTIONS l OPERATORS MUST MAKE FINAL DECISION l I l i i I i i

QUESTION #35 QUESTION: ARE ALL SAFE SHUTDOWN CIRCUITS LOCATED IN ROOM 12f4

RESPONSE

ROOM 124 NOT ONLY LOCATION OF SAFE SHUTDOWN CIRCUITS I PROTECTION OF SAFE SHUTDOWN CIRCUITS PROVIDED BY FIRE BARRIER OR BY SEPARATION WITH SPRINKLERS AND DETECTORS i I 1 I 9 e

s l QUESTION #36 QUESTION: JUSTIFY SG 1-1 OUTPUT ADEQUATE WITH MS107A OPEN

RESPONSE

CAPABILITY PART OF ORIGINAL DESIGN BASIS I I CONFIRMED BY TEST IN RECENT OUTAGE 4 1 i I l

QUESTION #37 QUESTION: 1uCATION OF CIRCUIT FOR S33-1, CONTROL ROOM EMERGENCY A/C UNIT

RESPONSE

COMPONENT S33-1 CIRCUIT LOCATED IN MANY AREAS INCLUDING FIRE AREA A CAR IS CONSISTENT IN DESCRIBING CIRCUIT LOCATION

QUESTION.#38 QUESTION: CONFIRM PROCEDURES SPECIFY USE OF HPI FOR FIRE AREA A

RESPONSE

HPI IS NOT USED FOR FIRE AREA A PROCEDURES AND CAR SPECIFY USE OF MAKEUP PUMP

.-. _ = .~ QUESTION #39 QUESTION: NEED FOR SPRINKLERS IN FIRE AREA A CABLE CHASE

RESPONSE

HIGH FIRE LOADING DUE TO UNIQUE CONFIGURATION PROTECTION OF SAFE SHUTDOWN CIRCUITS PROVIDED BY FIRE BARRIERS OR BY SEPARATION WITH SPRINKLERS AND DETECTORS

,o e QUESTION #40 QUESTION: DFDICATED ALTERNATE SHUTDOWN FANS

RESPONSE

FANS DEDICATED TO SAFE SHUTDOWN USE SEPARATE FANS FOR SM0KE REMOVAL e m,. m. e- =

. ~ QUESTION #41 OUESTION: 11FSCRIBE GROUND-FAULT MODS

RESPONSE

DAVIS-BESSE HAS 2 LEVELS OF GROUND-FAULT PROTECTION 1) GROUND OVERCURRENT RELAYS ON THE UNIT SUBSTATION 2) SOLID-STATE OVERCURRENT TRIP DEVICES ON DOWNSTREAM MCC FEEDER BREAKERS FED FROM ESSENTIAL 480VAC SWITCHGEAR GROUND-FAULT MODS ADDED TO CERTAIN BREAKERS TO LIMIT NUMBER OF MCCS AFFECTED BY DOWNSTREAM FAULT GROUND-FAULT MODS WILL MINIMIZE P0TENTIAL LOSS OF ESSENTIAL POWER

m ,e QUESTION #112 QUESTION: OFFSITE SUPPLY OF DIESEL GENERATOR FUEL OIL

RESPONSE

59 HOUR SUPPLY WITH DAY TANKS AND MANUAL ACTION SUPPLY TIME BASED ON ACTUAL TEST AND TANK LEVELS ADDITIONAL SUPPLY BEYOND 59 HOURS FROM 0FFSITE IS REASONABLE O

l f QUESTION #143 i. i QUESTION: DESCRIBE RADIANT ENERGY SHIELD DETAILS

RESPONSE

1 i RADIANT ENERGY SHIELD FOR CONTAINMENT AND ANNULUS ONLY j CIRCUIT WRAP FOR 20 FOOT SEPARATION j RADIANT ENERGY SHIELD FOR TRANSMITTER PROTECTION i } 1 l i l i l 4 I I

o QUESTION #44 QUESTION: COPY OF AB 1203.26, " SERIOUS CONTROL ROOM FIRE"

RESPONSE

UNCONTROLLED /UNDOCKETED PROCEDURE WILL BE SUPPLIED CONTROLLED PROCEDURE AVAILABLE AT DAVIS-BESSE

4 QUESTION #45 0UESTION: ISOLATION SWITCHES AND REDUNDANT FUSES CONFORM TO GL 81-12

RESPONSE

GL 81-12 CRITERIA FOLLOWED IN DESIGN AND INSTALLATION IE NOTICE 85-09 ADDRESSED IN DESIGN PROCESS REDUNDANT FUSING PROVIDED O

, 7. ', QUESTION #46 0UESTION: CIRCUIT ICAC103A NOT PROVIDED WITH ISOLATION DEVICE

RESPONSE

CAR CHANGED TO INCLUDE CIRCUIT ICAC103A TYP0 SINCE CIRCUIT LISTED EARLIER FOR ISOLATION

QUESTION #117 QUESTION: 1ACK OF RCS COLD LEG TEMPERATURE INDICATION

RESPONSE

DIGITAL V0LT-OHM METER DESCRIBED IN CAR IS INTERIM DIGITAL TEMPERATURE READ 00TS WILL BE INSTALLED PER RESPONSE TO IR 83-016 DATED NOVEMBER 7, 1986

7 ,?.*S* QUESTION #48 QUESTION: 1)ESCRIBE CONTROL ROOM ACTIONS FOR A FIRE

RESPONSE

11 ACTIONS INCLUDED IN PROCEDURE REACTOR TRIP - MINIMUM ACTION l i l

e Dockst Ns. 50-346 License No. NPF-3 Serial No. 1361 ATTACHMENT 3 RESPONSE TO NRC QUESTIONS ON THE DAVIS-BESSE FIRE PROTECTION PROGRAM i 9 i

c Dockat Ns. 50-346 License No. NPF-3 Serial No. 1361 INTRODUCTION On February 17 and 18, 1987, representatives of Toledo Edison and the NRC met to discuss certain aspects of the Davis-Besse Fire Protection Program. During this meeting, Toledo Edison responded to the NRC's questions regarding: 1. The NRC's Request for Additional Information (RAI) transmitted in letter dated December 17, 1986 (Log No. 2166), 2. Certain Change Notices to the Davis-Besse Fire !!azards Analysis

Mcport, 3.

The Toledo Edison exemption requests as amended in letter dated January 12, 1987 (Serial No. 1327), and 4. The Davis-Besse Penetration Seal Program as discussed in Toledo Edison's letter dated February 12, 1987 (Serial No. 1352). At the conclusion of the meeting, the NRC requested Toledo Edison to document its response to each of the NRC's question. This attachment provides such a response to each of the 48 questions of the RAI and to the additional NRC questions. For those questions Toledo Edison felt were not resolved by the enclosed response, discussions of the actions anticipated to resolve the NRC's questions and completion schedules have been

provided, i

i

r e Docket No. 50-346 + License No. NPF-3 Serial No. 1361 The following is a summary of the need for further response to each NRC question: Further Scheduled NRC Question

Response

Response Date 1. Time for Manual Operator Actions Yes December 15, 1987 2. Annulus Fire Barrier No 3. Separation of Control Room Emergency Ventilation Equipment No 4. Hand-Held Lights Yes December 15, 1987 5. Deviation from BTP Appendix A Yes December 15, 1987 6. Independent Sprinklers and Hose Stations Yes July 31, 1987 7. Audit Findings Regarding Pre-fire Plans No 8. Compliance with QA Functional Responsibilities No 9. Bus Duct, Seismic Cap, Conduit Sleeve Fire Seals No

10. Impact of Security Mods on Fire Doors No

11. Response to Penetration Seal Tests No

12. Kaowool Fire Test Results No

13. Fire Seal Protected Side Temperature Limits No

14. Smoke Damage to Redundant Shutdown Systems No

15. Damper Closure Under Ambient Air Conditions No

16. Consideration of Unsprinklered Charcoal Combustible Loading No

17. Adequacy of Radio Communication No

18. Visual and Audible Alarms in Control Room No

19. Compliance of Fire Detectors with NFPA 72E Yes December 15, 1987

20. Compliance of Sprinklers with NFPA 13 Yes December 15, 1987

21. Limited Fire Damage to Control Room No

22. Simplified Flow Chart No

23. Assumption of Component Failure to Most Detrimental Position No

24. Reactor Coolant Pump Seal Injection Yes December 15, 1987

25. Cold Shutdown Time No 11

(

r Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 Further Scheduled NRC Question

Response

Response Date

26. IE Information Notice 86-79 Yes July 31, 1987

27. Analysis of Diesel Generator Auxiliary Systems No

28. Protection of Valve Operators No

29. High-Low Pressure Interface Yes December 15, 1987

30. Spurious Actuation Assumptions No

31. Associated Circuits per Inspection Report No. 83-016 No

32. Status of Technical Specification Revisions No

33. Alternative Shutdown per Inspection Report No. 86-016 No

34. Use of Shutdown Procedure for Fire Area A No

35. Location of Safe Shutdown Circuits in Fire Area A Yes December 15, 1987

36. Two Auxiliary Feedwater Pumps Driven by One Steam Generator No

37. Location of Certain Circuit No

38. Use of HPI for Fire Area A No

39. Sprinklers for Cable Chase in Fire Area A No

40. Dedicated Alternative Shutdown Fans No

41. Multiple High-Impedence Faults Yes December 15, 1987

42. Offsite Supply of Diesel Generator Fuel Oil Yes December 15, 1987

43. Description of Radiant Energy Shields No

44. Copy of Shutdown Procedures No

45. Isolation Switches and Redundant Fuses No

46. Isolation Switch for Certain Circuit No

47. RCS Cold Leg Temperature Indication Yes December 15, 1987

48. Operator Actions for a Control Room Fire No 111

D:ckat No. 50-346 License No. NPF-3 Serial No. 1361 1 4-Further Scheduled I Additional NRC Questions

Response

_ Completion Date 4 A. Amended Exemption Request Yes December 15, 1987 B. FHAR Change Notice 90 No C. FRAR Change Notice 93 No D. FHAR Chance Notice 100 No E. CAR and FHAR Change Notices No F. Cable Ignitibility Yes December 15, 1987 j. G. ' Administrative controls'for Transient Combustibles No H. Conduit Seals No i i l i I t e ) i, t ( iv

Dockst No. 50-346 ~ License No. NPF-3 Serial No. 1361 Question 1 - Time for Manual Operator Actions Where credit is taken for manual actions to achieve safe shutdown, provide the time limit and basis to accomplish the action before an unrecoverable plant condition occurs.

Response

Davis-Besse has two safe shutdown procedures for a fire which are AB 1203.02, " Serious Station Fire," and AB 1203.26, " Serious Control Room Fire." Procedure AB 1203.02 specifies the procedure actions necessary to achieve and maintain safe shutdown for a fire outside the Control Room / Cable Spreading Room, and Procedure AB 1203.26 specifies those actions for a fire in the Control Room / Cable Spreading Room. The operator actions contained in these procedures are based on the evaluation documented in the Davis-Besse Appendix R Compliance Assessment Report (CAR). As discussed in Toledo Edison letter dated September 13, 1983 (Serial No. 986), Abnormal Procedure AB 1203.26, " Serious Control Room Fire," was initially developed in response to the results of the NRC special safety inspections conducted at Davis-Besse on July 11-13 and July 25-29, 1983. This procedure was reviewed by the NRR and Region III staff and determined to be acceptable as documented by Inspection Report No. 83-16 dated August 30, 1984 (Log No. 1-1024) and the Safety Evaluation Report for the Davis-Besse Fire Protection Program Corrective Action Plan dated September 23, 1983 (Log No. 1375). A walkdown of this procedure by the NRC staff verified that the minimum manpower required by the procedure was capable of performing the identified tasks in the necessary time frame. This procedure has been subsequently revised to improve its effectiveness. Toledo Edison believes that the previous NRC acceptance of the timely actions taken is sufficient to resolve this question for Abnormal Procedure AB 1203.26. Toledo Edison, however, will provide documentation of the acceptability of Abnormal Procedure AB 1203.02, " Serious Station Fire" by December 15, 1987. This documentation will consist of the: 1. Identification of manual operator action required outside the Control Room for a fire in areas other than the Control Room. 2. Determination of the time before an unrecoverable plant condition would occur for each of the above operator actions. 3. Determination of the time required to implement the above operator actions based on a trial run of Procedure AB 1203.02. This trial run will include those operator actions required to preclude an unrecover-able plant condition. The time to implement these actions may be con-servatively determined based on similar or more complex actions whose time has been measured. I 1-1 l

r. -

Dockat No. 50-346 ~ License No. NPF-3 Serial No. 1361 Justification for those manual operator actions identified in Item 1 that could not be completed: a) Inside the area of the fire, within one hour before an unrecoverable plant condition occurs, and b) Outside the area of the fire, within 30 minutes before an unrecover-able plant condition occurs. Further Response 'The aforementioned documentation for Abnormal Procedure AB 1203.02, " Serious Station Fire," will be provided to the NRC by December 15, 1987. { l 1-2 1

7 Dockst No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 2 - Annulus Fire Barrier Provide justification for the contention that a standard fire-rated barrier cannot be installed to separate redundant circuits in Fire Area DA.

Response

In letter dated January 12, 1987 (Serial No. 1327), Toledo Edison withdrew the requested exemption for Fire Area DA, the Containment Annulus. This previous exemption request was intended to obviate the need for an auto-matic fire suppression system where redundant safe shutdown circuits are separated by 20 feet without intervening combustibles as required by 10CFRSO, Appendix R, III.G.2.b. However, the Containment Annulus is similar to the Containment from a fire protection standpoint in that they both are locked, negative pressure, high radiation, limited access areas with limited ignition sources and high segregation of redundant train cables. For fire protection, the Containment Annulus has been determined to be part of the Containment and, as such, is subject to the requirements of Appendix R, III.G.2.d and f, rather than II.G.2.b, and does not require an automatic fire suppression system. Consequently, in accordance with the requirements of Appendix R, III.G.2.d and f, those redundant safe shutdown circuits required in the event of a fire located in the Contain-ment Annulus will be either provided with a noncombustible radiant energy shield or separated by a horizontal distance of 20 feet with no intervening combustibles or fire hazards. The necessary modification will be implemented prior to the return to power from the sixth refueling outage. Further Response Toledo Edison believes no further response is necessary to resolve this NRC question. 4 1 2-1 l l l L

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 3 - Separation of Control Room Emergency Ventilation Equipment 1 Justify why one train of control room emergency ventilation system cables cannot be protected in lieu of evacuating the control room for a fire in area liH.

Response

l In letter dated March 6,1986 (Serial No.1255), Toledo Edison requested an exemption from 10CFR50, Appendix R to the extent it requires fire detection and fixed fire suppression in Fire Area Kil. This fire area contains safe shutdown equipment required in the event of a fire for which alternate shutdown capability will be provided. Fire Area till consists of the Control Room A/C Equipment Room #603 and the Records and Storage Area

1. 603A and contains equipment and circuits for the Control Room Emergency Ventilation System (CREVS).

Loss of this system in a fire may necessitate the evacuation of the Control Room and the utilization of the alternate shutdown capability discussed in the Davis-Besse Appendix R Compliance Assessment Report (CAR). It should be noted that CREVS equipment located in Fire Area Kit includes fan units, chillers, and filters and not just cables. The location of this equipment is discussed in the Davis-Besse Fire llazard Analysis Report. Toledo Edison has reviewed the location of these components as discussed in the CAR and determined that it is not practical to separate equipment such as fan units, chillers and filters to satiaff Appendix R. Toledo Edison believes that the requested exemption is justified since equipment other than cables would require relocation. Further Response Toledo Edison believes that no further response is necessary to resolve this question. I 3-1 i

r Dockst Ns. 50-346 License No NPF-3 Serial No. 1361 Question No. 4 - Iland-Held Lights Justify the use of hand-held lights for accomplishing safe s.hutdown. Such use is not consistent with staf f guidance or past precedent excrpt for access and egress routes in outdoor areas.

Response

In letter dated March 6, 1986 (Serial No. 1255), as amended in letter dated January 12, 1987 (Serial No. 1327), Toledo Edison requested an exemption from 10CFR50, Appendix R in order to use hand-held lights as emergency lights in outside plant areas, lland-held lights currently would be used by the operators, for indoor plant areas and access and egress in outside plant areas in accordance with the current Fire Protection Program. This use is an interim measure taken by Toledo Edison pending the implementation of the necessary perma-nent 8-hour batter powered emergency lights. This interim measure was accepted by the NRC as documented in the NRC Safety Evaluation Report for the Davis-Besse Fire Protection Corrective Action Plan dated September 23, 1983 (Log No. 1375). In letter dated August 30, 1984 (Log No. 1-1024), the NRC documented that I&E inspectors had verified the availability of the ten portable hand-held " Captains" lanterns for the sole use of the operating staff. The operability of those hand held lights is assured by surveillance and maintenance procedures. Upon implementation of the permanent 8-hour battery-powered emergency lights, Toledo Edison would utilize these hand-held lights for access and egress routes in outside plant areas. These outside access and caress routes are paved or covered with gravel and do not have obstructions that require the use of both operator's hands to traverse, such as ladders. One fire area, the BWST Pipe Trench, Fire Area AC, is an underground concrete structure that is reached by an outside route. This fire area would be entered by descending a permanent ladder, lloth the ladder and the interior of this fire area will be lit by a permanent emergency light to be installed as discussed above. Certain outside access and egress routes may be crossed by a radiological posting or terminate at doors. An operator carrying a hand-held light is capable of opening the door or cronning the postings. Regardless of the existence of the permanent emergency lighting units, hand-held lights would be provided in accordance with current procedure practices to cach operator impicmenting manual actions in indoor areas, including those areas exposed to a fire that would be entered to perform manual actions after the fire is extinguished. These hand-held lights are provided for indoor use as a precautionary / backup measure in the case the permanent emergency lighting would not be available as anticipated. 4-1

r-Dockst No. 50-346 ^ License No. NPF-3 Serial No. 1361 The use of the hand-held lights will be clarified in a revision of the CAR to be issued by December 15, 1987. Further Response Toledo Edison will. issue a revision of the CAR by December 15, 1987 to clarify the une of hand-held lights. 42

Dockat No. 50-346 License No. NPF-3 Serial No. 1361 i 4 Question No. 5 - Deviation from BTP Appendix A Regarding [FRAR). Table 4-1, Sheet 1, explain the difference between the response " Comply" and " Position (comply)." It appears that the latter response signifies nonconformance. This table should be revised to c1carly specify where deviations from our guidelines exist. Appropriate justification for such deviations should be provided in the filar.

Response

Table 4-1 of the Davis-Besse Fire llazard Analysis Report (filar) provides a discussion of the Davis-Besse Fire Protection Program relative to the NRC guidance contained in Appendix A to BTP APCSB 9.5-1. In certain cases, this discussion documents full compliance with the NRC guidance and adequate justification for certain deviations, llowever, Table 4-1 does not represent a complete listing of all deviations with justification from this NRC guidance. 4 Toledo Edison is currently preparing a single document that will identify Davis-Besse compliance with each section of BTP APCSB 9.5-1, Appendix A { and will provide an adequate justification for any deviations. This j document will be incorporated in the filar as a replacement for the current i Table 4-1. This FRAR revision will be issued by December 15, 1987. Further Response Toledo Edison will revise the FIIAR to identify and justify each deviation from the NRC guidance in Appendix A to BTP APCSB 9.5-1 and will issue this revision to the NRC by December 15, 1987. I l t 9 i l 5-1 1

Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 6 - Independent Sprinklers and llose Stations Regarding [ filar) Table 4-1, Sheet 4, except for the Turbine Building, identify any location (s) where sprinkler systems and standpipe systems are supplied from a single water supply pipe and describe how "back-up" fire fighting capability will be provided if a failure in this pipe occurs?

Response

The Davis-Besse Fire llazard Analysis Report (filar), Table 4-1, Sheet 4 states that hose lines have been provided as a backup to automatic sprinkler systems. For those fire areas containing safe shutdown equipment required in the event of a fire, 11 sprinkler systems share the same supply piping with its backup hose station (s). liowever, only 6 of those sprinkler systems are located in fire areas containing redundant safe shutdown equipment required in the event of a fire and are necessary to satisfy 10CFR50, Appendix R, Section III.G.2.b. Toledo Edison has initiated a review of the 11 sprinkler systems without independence from their backup hose station. This review will determine a resolution to the lack of independence by: 1. Identifying an alternative hose station (s) that is independent from its associated sprinkler system and capable of providing the necessary suppression, 2. Identifying a modification (s) to supply the sprinkler system (s) and its backup hose station (s) from separate supply piping, or 3. Identifying alternative means of fire sprinkler as a backup to the sprinkler system and associated hose station (s). Adequate justifi-cation for such an alternative would be developed. Toledo Edison anticipates that the results of this review will be provided to the NRC by July 31, 1987. Further Response By July 31, 1987, Toledo Edison will provide the NRC with the results of the review to ensure that sprinkler systems in fire areas containing safe shutdown equipment required in the event of a fire have an independent means of backup suppression. 6-1 ~

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 7 - Audit Findings Regarding Pre-fire Plans Regarding [FHAR] Table 4-1, Sheet 8, describe how pre-fire plans have been modified to incorporate audit findings. (Reference meeting summary dated February 1,1984).

Response

In letter dated September 13, 1983 (Serial No. 986), Toledo Edison commit-ted to review the Fire Protection Manual Pre plans and make any necessary revisions. This commitment was identified as Task 8 of Toledo Edison's long-term program in response to the NRC fire protection audit findings documented in Inspection Report No. 83-16, dated August 30, 1984 (Log No. 1-1024). On January 25, 1984, representatives of the NRC and Toledo Edison met to review the progress and the adequacy of the approach to resolve the fire protection issues. The status of the Fire Protection Manual Pre plans Review was discussed as documented in the NRC-issued meeting minutes dated February 1, 1984 (Log No. 1620). In letter dated February 28, 1985 (Serial No. 1128), Toledo Edison docu-mented that the Appendix R reassessment was completed in September 1984 and committed to complete the revisions to the Pre-plans by August 1, 1985. The Pre-plan revisions in accordance with the commitments of Task 8 were completed in August 1985. Additional revisions to the Pre plans have occurred since August 1985. The Pre plans were subsequently developed into Fire Protection Strategy Procedures. The Fire Protection Strategy Procedures were stream-lined to facilitate operator use and include descriptions of fire hazards and maps delineating the floor layout. These revisions were made to further enhance their effectiveness. Further Response Toledo Edison believes that no further response is necessary to resolve this NRC question. 7-1

Dockot No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 8 - Compliance with QA Functional Responsibilities Regarding [FHAR] Table 4-1, Sheet 15, confirm that you comply with the referenced staff guidance on fire protection program functional responsibilities.

Response

The Davis-Besse Fire Hazard Analysis Report (FHAR), Revision 7, Table 4-1, Sheet 15 refers to the NRC quality assurance guidance for fire protection consisting of Section C of Appendix A to BTP APCSB 9.5-1 and the Vassallo letter dated August 29, 1977. Toledo Edison is committed to implement the referenced NRC guidance with the exception of backfitting this guidance to the design, procurement, construction and pre-operational testing of previously installed fire protection systems. This commitment was originally included in FHAR, Revision 3, Table 4-1, Sheet 10 and was specifically referenced in Toledo Edison letters dated September 25, 1978 (Serial No. 460) and November 25, 1978 (Serial' t No. 468). This commitment was generated to address the NRC Request for Additional Information, Question 2, transmitted in letter dated August 21, 1978. The NRC issued the Davis-Besse Fire Protection Safety Evaluation Report (SER) and the associated License Amendment No. 18 in letter dated July 26, 1979. The SER and License Amendment specifically reference the two aforementioned Toledo Edison letters and FHAR, Revision 3 and deter-J mined that the Davis-Besse Fire Protection Program was acceptable. This commitment, therefore, was reviewed and accepted by the NRC as documented 3 by the SER. Further Response i Toledo Edison believes no further response is necessary to resolve this question. I i 8-1

g% D:ck:t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 9 - Bus Duct, Seismic Gap, Conduit Sleeve Fire Seals Regarding [FHAR} Table 4-1, Sheet 24, confirm that bus ducts, seismic gaps and spare conduit sleeves are sealed with fire-rated material equivalent to the rating of the fire barrier in which they are located.

Response

Table 4-1, Sheet 24 of the Davis-Besse Fire Hazard Analysis Report (FHAR) discusses certain aspects of the design of the fire barriers relative to the guidance contained in Appendix A to BTP APCSB 9.5-1. Toledo Edison subsequently provided a submittal dated February 12, 1987 (Serial No. 1352) regarding the adequacy of the Davis-Besse penetration seals. During the fire protection meeting of February 17 and 18,1987, the NRC requested Toledo Edison to document the evaluation to be conducted for bus ducts, seismic gaps and spare conduit sleeves. For seismic gaps and bus ducts, Toledo Edison will: 1. Establish seal details for seismic gaps and bus ducts. 'l _2. Inspect seismic gaps and bus ducts against the seal details. The inspection will include those seismic gaps and bus duct in fire barriers protecting redundant safe shutdown components required in the event of a fire. 2. Assess any identified degradation of the fire protection seals provid-ed in the seismic gaps and bus ducts. 3. Eepair those seismic gap and bus duct seals that are not in accordance with the seal details or are unacceptably degraded; otherwise, justify their current installation. Toledo Edison has' inspected the internal seals of spare conduit sleeves penetrating fire barriers that separate redundant safe shutdown components required in the event of a fire. An evaluation based on the inspection results has begun and will: 1. Assess the adequacy of the installed internal spare conduit sleeve seal configurations and any identified degradation against qualified seal details establishing proper fire protection. 2. Identify repairs to those internal spare conduit sleeve seals that l are not in accordance with the seal details or are unacceptably degraded; otherwise,-j sstify the current installation. l l 9-1

Docket No. 50-346 License No. NPF-3 Serial No. 1361 The aforementioned evaluations and physical modifications are being imple-mented as part of the Fire Barrier Seal Inspection Program currently being implemented and will be completed prior to the return to power operation from the sixth refueling outage. Further Response Toledo Edison believes that no further response is necessary to resolve this question. l l l l l l i l 9-2 l

T Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 10 - Impact of Security Mods on Fire Doors Describe how security modifications have affected the rating of fire doors.

Response

Toledo Edison has determined that the security modifications have not affected the fire rating of the fire doors at Davis-Besse. This includes fire doors within the scope of the Technical Specifications and those considered to form a rated fire barrier as documented in the Davis-Besse Fire Hazards Analysis Report. This determination is based upon an evaluation by Factory Mutual Research dated December 19, 1986. The Factory Mutual Research Inspector has served on the National Fire Protection Association Committee, NFPA 80, for 20 years and is considered by Toledo Edison to be eminently qualified to evaluate the effect of modifications on fire doors. The status of the Davis-Besse fire doors and their evaluation by an NFPA Code 80 board member was addressed by LER 86-27, Revision 1, dated October 29, 1986. The Factory Mutual Research evaluation made 55 recommendations. However, none of these recommendations were to resolve any concerns associated with a security modification. Toledo Edison has reviewed these recommendations and will implement them prior to the return to power from the sixth refueling outage. Further Response Toledo Edison believes that no further response is necessary to resolve this question. l i l l 10-1

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 11 - Response to Penetration Seal Tests Regarding [FHAR] Table 4-1, Sheet 25, provide your response to the September 9, 1986 telecon concerning the adequacy of fire barrier penetra-tion seal tests.

Response

Table 4-1, Sheet 25 of the Davis-Besse Fire Hazard Analysis Report (FHAR) discusses the design of certain aspects of fire barriers relative to the NRC guidance contained in Appendix A to BTP APCSB 9.5-1. In a letter dated December 31, 1986 (Log No. 2171), the NRC provided its evaluation of the penetration seal fire test reports that were submitted by Toledo Edison in letter dated June 26, 1986 (Serial No. 1267) and discussed in a telephone conversation on September 9, 1986 between representatives of the NRC and Toledo Edison. In response to the December NRC letter and this question, Toledo Edison provided an additional submittal dated February 12, 1987 (Serial No. 1352) regarding_the adequacy of the Davis-Besse penetration seals. This submittal included typical fire barrier penetration seal details and, for each of these details, a copy of the qualifying fire test reports and a summary of these test reports as applicable to the associated detail. This submittal was discussed in the fire protection meeting held on February 17 and 18, 1987. No additional NRC questions requiring further Toledo Edison response regarding the penetration seal tests were generated at the meeting. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 11-1

- Docket No.~50-346 License No.'NPF-3 Serial No. 1361 Question No. 12 - Kaowool Fire Test Results Regarding [FHAR] Table 4-1, Sheet 32, provide the results of the Kaowool qualification fire test. Provide a discussion / description as to how cable tray / conduit support steel as well as other metal features which are framed into the fire barrier are protected.

Response

Toledo Edison will replace fire wraps constructed of Kaowool that are necessary to satisfy 10CFR50, Appendix R and Appendix A to BTP APCSB 9.5-1 with another fire resistant material (s). At this time, Toledo Edison has reviewed the qualifications of certain commercially available materials and has selected a fire resistant material called Thermn-Lag, manufactured by Thermo Science Incorporated. The fire resistance of the selected replacement material is documented'by qualification test reports, which were reviewed for acceptability and installation requirements by Toledo Edison. The protection of cable tray / conduit support steel and other metal features will be consistent with the installation requirements established by the qualification test reports'and vendor recommendations. The replacement of Kaowool will be implemented prior to the return to power from the sixth refueling outage. Further Response Toledo Edison believes that no further response is necessary to resolve this question. I l l l 12-1 L l

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 13 - Fire Seal Protected Side Temperature Limits Regarding [FRAR) Table 4-1, Page 33, describe how seals around metal penetrations of fire barriers conform with the protected side temperature limits of ASTM E-119.

Response

Table 4-1, Sheet 33 of the Davis-Besse Fire Hazard Analysis Report (FHAR) discusses certain aspects of the testing for penetration seals relative to the NRC guidance contained in Appendix A to BTP APCSB 9.5-1. The NRC provided in a letter dated December 31, 1986 (Log No. 21711 an evaluation of the penetration seal fire test reports submitted by Toledo Edison in letter dated June 26, 1986 (Serial No. 1267). In response to the December NRC letter and this question, Toledo Edison provided a submittal dated February 12, 1987 (Serial No. 1352) regarding the adequacy of the Davis-Besse penetration seals. This submittal includ-ed typical fire barrier penetration seal details and, for each of these details, a copy of the qualifying fire test reports and a summary of these test reports as applicable to the associated detail. These qualifying test reports were performed to satisfy the thermocouple placement guidance of ASTM E-119. As part of the acceptance criteria, ASTM E-119 requires that measurements be taken on the unexposed surface of the test assembly (i.e. protected side), but does not specify the location of thermocouples relative to a penetrant or sleeve forming the perimeter of the penetration. Consequently, Toledo Edison's review of the qualifying test reports considered only those thermocouples actually on the unexposed surface of the seal. Any thermocouples not on the unexposed side of the seal material were disregarded by Toledo Edison or identified on the test report summaries as not applicable. l Several of the qualifying test reports were performed to satisfy IEEE 634 as well. IEEE 634 specifies thermocouples to be placed at the interfaces of the j seal and metal penetrants and on the penetrants themselves. The thermocouple locations and temperature results for those tests that were conducted in accordance with IEEE 634 and included in the February submittal are also l discussed in the test report summaries. The highest temperature reading for the tests conducted in accordance with ASTM E-119 and IEEE 634 was 652 F from a thermocouple placed on a cable inside a conduit having only 9 inches of low density silicone foam as a seal. l This temperature reading is conservatively high with respect to that ex-l pected at Davis-Besse since its fire-rated penetration seals have no less I than 11 inches of low density silicone foam. Additionally, this conservatively l high temperature of 652 F is below the 700 F maximum temperature limit of l IEEE 634. Consequently, Toledo Edison believes that the test reports l l 13-1

Docket No. 50-346 License No. NPF-3 Serial No. 1361 demonstrate that the unexposed side (i.e. protected side) temperature of penetration seals in fire barriers would be sufficiently below that required to cause self-ignition of cables at Davis-Besse. Further Response Toledo Edison believes that no further response is necessary to resolve this question. i 13-2 }

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 14 - Smoke Damage to Redundant Shutdown Systems Regarding [FHAR] Table 4-1, Page 35, describe how smoke is vented from a fire area so as to avoid damaging unexposed redundant shutdown systems.

Response

Table 4-1, Sheet 35 of the the Davis-Besse Fire Hazard Analysis Report (FHAR) provides a general discussion of the method of smoke venting and isolation relative to the NRC guidance contained in Appendix A to BTP APCSB 9.5-1. The FHAR states that, when available, the installed ventil-ation systems would be used to evacuate smoke from a fire zone. Because of the design of these systems, this may not always be possible and portable ventilation equipment would be utilized to evacuate smoke and heat to the atmosphere or to an area where the installed ventilation system would still be available. The ventilation of smoke would be controlled through the Fire Protection Strategy Procedures (FPSP). In order to minimize the impact of smoke on sensitive electrical equipment, the FPSP will be revised to prioritize the methods of smoke venting as follows: 1. Use of the normal ventilation system within the area of the fire, if available. 2. Use of portable ventilation equipment to vent smoke directly from the area of the fire to the atmosphere. 3. Use of portable ventilation equipment to evacuate smoke directly from the area of the fire to a stairwell or elevator shaft. This smoke venting would occur subsequent to evacuation of non-essential plant personnel from the fire region. 4. Use of portable ventilation equipment to vent smoke to the atmosphere or to an operable normal ventilation system via the shortest, most direct route of surrounding plant rooms. This revision to the FPSP will be completed at the next general revision which will occur no later than the return to power operation from the sixth refueling outage. This method of smoke venting would minimize the potential for inadvertent damage to sensitive electrical equipment not exposed to the fire. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 14-1

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 15 - Damper Closure Under Ambient Air Conditions Describe how you have confirmed that fire dampers will close under ambient air conditions (reference 10CFR21 notification concerning Ruskin dampers).

Response

.In LER 86-010 dated January 6, 1986, Toledo Edison stated that the fire dampers installed in Technical Specification-related fire barriers were declared inoperable. In general, the fire dampers were not installed in accordance with manufacturer's recommendations for annular thermal expan-sion space, retaining angles and proper sleeve lengths. If improperly installed, the fire damper could potentially fail under a fire condition and allow passage of fire from one area to another. Additionally, in letter dated November 6, 1984, Ruskin notified the NRC pursuant to 10CFR21 that certain Ruskin dampers may not close under ambient air flow conditions. To resolve the above concerns, Toledo Edison initiated a Fire Damper Upgrade Program. This program is intended to identify, procure, install and test those dampers that are not installed in accordance with the vendor's tested configuration. At this time, Toledo Edison has determined that 99 Technical Specification-related fire dampers will require re-ins-tallation or replacement. These dampers will be installed prior to the return to power from the sixth refueling outage. As discussed in LER 86-010, the Technical Specification ACTION statements for fire dampers will remain in place as compensatory measures until the dampers are returned to an operable status. Two manufacturers have been selected to provide fire dampers: Ruskin and Pullman. Both manufacturers are providing curtain-type fire dampers. Of the 99 fire dampers to be installed at Davis-Besse, 61 dampers will be procured from Pullman and the remaining 38 from Ruskin. The Pullman dam-pers will be installed in ducts expected to have high air flow and in ducts requiring dampers with internal expansion gaps. The Ruskin dampers will otherwise be installed in low air flow ducts allowing external expansion gaps. Both manufacturers have tested fire dampers under various air flow conditions. Based on this testing, the manufacturers are required by the Toledo Edison purchase documents to certify that each fire damper has been tested for closure under specified design air-flow conditions. For each damper, the purchase documents specify the worst-case air flow conditions for its indivi-dual installation configuration. The worst-case air flows are determined by an engineering review of the ventilation system layout with respect to the i fire area boundaries. Unique fire damper serial numbers are used to track the fire dampers from manufacturing through installation. Installation and testing procedures have been developed based on the manufacturer's recommendations. The testing will include drop testing, under static air flow upon onsite receipt and after installation as part 15-1 I

Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 of the modification operability testing. Subsequent visual inspections of the fire dampers will be conducted in accordance with Technical Specifi-cation surveillance requirements to verify the as-built condition has not degraded. In summary, the aforementioned Davis-Besse fire dampers will be: Re-installed or replaced with fire dampers certified by the manufacturer to a worst-case air flow uniquely determined for each damper Installed in accordance with procedures based on vendor recommendations Drop tested under static air flow conditions upon onsite receipt and after installation Visually inspected in accordance with Technical Specifications Ruskin dampers will be installed only in ducts allowing external expansion gaps and having low air flow conditions Consequently, testing of fire dampers under worst-case air flow conditions after installation is not warranted. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 15-2

D2cket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 16 - Consideration of Unsprinklered Charcoal Combustible Loading Regarding [FHAR] Table 4-1, Page 39, confirm that charcoal in unsprink-1ered filter units has been considered in the fire hazards analysis.

Response

The Davis-Besse charcoal filters are not provided with sprinkler systems. The systems equipped with charcoal filters, their locations and approximate available heat energy of these charcoal filters are as follows: Available Fire Heat Energy System Area Room (BTUs) Radwaste Equipment DB No. 2 Mechanical Penetration 2,558,784 Ventilation Room Waste Gas Decay and EE Purge Exhaust Equipment Room, 75,147,660 Exhaust Rad Exhaust Equipment and Hydrogen Purge Main Station Exhaust Fan Room Fuel Handling Exhaust Filter Emergency Ventilation Containment Purge Control Room Emergency HH AC Equipment Room 21,470,760 Ventilation Condensate Demineralizer II Condensate Demineralizer Hold-up 1,705,856 Hold-up Tank Filter Tank Room In all cases, the fire loadings for these charcoal filters have been included as Type A Class Combustible Material in the assessment of the combustible loading for their corresponding fire areas as documented in the Davis-Besse Fire Hazard Analysis Report (FHAR). Further Response Toledo Edison believes no further response is necessary to resolve this question. 16-1

D:ck t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 17 - Adequacy of Radio Communication Regarding [FHAR] Table 4-1, Page 46, describe how the adequacy of radio communication has been verified with regard to structural interference and joint use by the fire brigade.

Response

Sheet 46 of Table 4-1 of the Davis-Besse Fire Hazard Analysis Report states that fixed and portable emergency lighting and communication devices are available relative to the NRC guidance of Appendix A to BTP APCSB 9.5-1. The Davis-Besse Compliance Assessment Report (CAR) discusses the four diverse communication systems available at Davis-Besse consisting of the Tele-phones, Gai-Tronics, UHF radios and sound-powered phones. The Gai-Tronics and telephone systems are the main communication system available in the administrative and plant areas. However, the Gai-Tronics System may be impaired by a fire and has been supplemented by the UHF radios and sound-powered phones. The Davis-Besse UHF radio system consists of 1) the two-way mobile radio with page; 2) the security radio system with intercom; 3) the maintenance radio system; and 4) the operations radio system with intercom. In the event of the loss of the Gai-Tronics System due to a fire, the operations radio system would be used by the Shift Supervisor to keep in contact with the plant operators and the Fire Brigade. This system has direct connection between seven remote consoles which are connected to a fixed repeater located on the roof of the Auxiliary Building and powered from an uninterruptable power supply backed by the station batteries. Additionally, a passive antenna system is installed in the Auxiliary Building and Containment and would be used to facilitate transmission and reception in the reinforced concrete structure. The portable radios are capable of operating in two modes. The first mode would be used to communicate from one portable radio to the repeater and then to another portable radio or to a base station. The second mode would be used to communicate from portable radio to another portable radio. The portable radios have their own internal rechargeable batteries which are kept constantly charged. The sound-powered phones were installed in May 1984. These phones are to supplement the Gai-Tronics System which may be lost due to a fire in the Control Room. These phones are hard-wired independent of the Control Room and are provided with headsets that would be plugged in at key locations, including the Auxiliary Shutdown Panel. The headsets are maintained at the key locations and in the Fire Emergency Cabinet. The phones utilize the human voice to generate the electric current to ensure communication, and no external power source is required. To ensure that adequate communication systems are available for implemen-tation of safe shutdown procedures, Toledo Edison will perform and docu-ment a formal verification test of the radio and sound-powered phone com-munication systems in those plant areas requiring manual operator actions 17-1

Dockst No. 50-346 License No. NPF-3 Serial No. 1361 by December 15, 1987. The commitment for such a test is discussed in NRC Inspection Report 85-28 dated November 22, 1985 (Log No. 1-1280). The use of a single radio system allows the Shift Supervisor to keep in contact with both the plant operators and fire brigade. It should also be noted that the Fire Brigade consists of members from the operations staff. Therefore, the use of a single radio system allows the operators implement-ing the safe shutdown procedures and those on the Fire Brigade simultaneously to be kept abreast of the fire fighting and shutdown activities. Communica-tion using the radio system would be controlled by the Shift Supervisor to ensure orderly communication. Toledo Edison believes the diverse communication systems at Davis-Besse are adequate to facilitate safe shutdown in the event of a fire. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 17-2 L

Dock t Ns. 50-346 License No. NPF-3 Serial No. 1361 Question No. 18 - Visual and Audible Alarms to Control Room Regarding [FHAR] Table 4-1, Page 49, confirm that visual and audible alarm are transmitted to the control room from every fire / smoke alarm initiating device.

Response

Table 4-1, Sheet 49, of the Davis-Besse Fire Hazard Analysis Report (FHAR) discusses the typical mode of operation for the area fire detection system relative to the NRC guidance contained in Appendix A to BTP APCSB 9.5-1. Table 4-1, Sheet 55 states that the fire detection systems annunciate on the Fire Detection System / Radiation Monitor System console in the Control Room. Toledo Edison has verified that those FDZs located in fire areas identified in the FRAR are indicated visually and audibly in the Control Room via this console. In 1986, an audible and visual indication was added to the Main Control Board to indicate an alarm on the console. The local fire alarm panels also have an audible trouble alarm which sounds in the event of a fire alarm. Toledo Edison has reviewed the detector alarms and determined that each detector device activates its associated fire oetection zone (FDZ) local panel, both visually and audibly. The indication in the control room is the affected FDZ and/or the local panel for the affected FDZ. The local panel indicates the affected FDZ. If an alarm for a local panel only is indicated in the control room, plant personnel would proceed to the local panel to identify the affected FDZ. However, Toledo Edison will revise the Control Room console to indicate both the local panel and affected FDZ for those fire areas identified in the FRAR. This console will also be revised to indicate if the FDZ is Technical Specification-related. The revisions to the console are con-sidered enhancements and are not necessary to satisfy Appendix A to BTP APCSB 9.5-1 or 10CFR50, Appendix R. However, these revisions are scheduled to be completed by the sixth refueling outage. Additional control room indications and alarms are provided for certain fire protection components and sprinkler systems. The alarms associated with these fire components and sprinkler systems are visually and audibly indicated in the Control Room. Water flow alarms due to actuation of certain sprinkler systems are indicated on the local fire alarm panels and the Fire Detection System / Radiation Monitor System Console in the Control Room. The Control Room console also provides tamper alarms for isolation valves on certain sprinklers. These fire sprinkler and tamper alarms include, at a minimum, those associated with sprinklers relied upon to satisfy the requirements of III.G.2 of 10CFR50, Appendix R. identifies the annunciator windows and main control board indications for certain fire protection equipment. Further Response Toledo Edison believes no further response is necessary to resolve this question. 18-1

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 19 - Compliance of Fire Detectors with NFPA 72E Confirm that fire detectors are installed per the guidelines of NFPA Standard No. 72E.

Response

Table 4-1 of the Davis-Besse Fire Hazard Analysis Report (FHAR) discusses the design of the fire detectors relative to the NRC guidance contained in Appendix A to BTP APCSB 9.5-1. Additionally, the spacing of certain detectors was addressed by Toledo Edison's response to NRC Question No. 17 transmitted in FHAR, Revision 1. The detectors installed at Davis-Besse comply with these commitments. Toledo Edison will satisfy the intent of NFPA Standard No. 72E-1978. However, certain deviations from this standard are expected due to plant-specific configurations and operation not anticipated by the general guidelines of the standard. Toledo Edison is currently preparing a single document that will identify the Davis-Besse compliance with each section of NFPA Standard No. 72E-1978 and will provide adequate justification for any identified deviations. This document will be incorporated into the Davis-Besse Fire Protection Program and will be issued by December 15, 1987. Further Response Toledo Edison will identify and justify each deviation from NFPA Standard No. 72E-1978 by December 15, 1987. l 19-1 l L

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 20 - Compliance of Sprinklers with NFPA 13 Regarding [FHAR] Table 4-1, Page 61, provide justification for the sprin-kler system installation deviations from the guidelines in NFPA Standard No. 13. (Reference IE Inspection Report 50-346/83-16 (DE))

Response

Table 4-1 of the Davis-Besse Fire Hazard Analysis Report (FHAR) discusses the design of the fixed water sprinkler systems relative to the NRC guidance contained in Appendix A to BTP APCSB 9.5-1. In summary, these sprinkler systems were designed and positioned to control and/or extin-guish fires that could damage safe shutdown equipment required in the event of a fire. Such fires are considered to originate on the floor from transient combustible or external ignition sources. Fires originat-ing electrically from overloaded cables were not considered to be credi-ble. The design and installation of certain sprinklers are addressed by Toledo' Edison's responses to NRC Questions transmitted in FHAR Revisions 2 through 5 (Ref. NRC Questions: 4, 8, 11, 13, 19, 21, 22, 26, 27, 29 and 35). The sprinklers installed at Davis-Besse comply with these commitments. Certain deviations from NFPA Standard No. 13 exist due to the intended function of the sprinklers and to the plant-specific configurations and operation not anticipated by the general guidelines of the standard. Toledo Edison is currently preparing a single document that will identify the Davis-Besse compliance with each section of NFPA Standard No. 13 and will provide adequate justification for any identified deviations. This document will be incorporated into the Davis-Besse Fire Protection Program and will be issued by December 15, 1987. Further Response Toledo Edison will identify and justify each deviation from NFPA Standard No. 13 by December 15, 1987. 20-1

Dockrt No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 21 - Limited Fire Damage to Control Room Regarding [FHAR] Table 4-1, Page 74, the licensee's assumption of limited fire spread / damage in the control room does not conform with the criteria of Appendix R to 10CFR50. In all areas including the control room, the licensee should assess the adequacy of fire protection on the basis that all cables and components within the fire area are damaged, except where systems within the fire area are protected per Section III.G.2 of Appendix R or by an alternate level of protection that the Staff has specifically reviewed and approved.

Response

Revision 7 of the Davis-Besse Fire Hazard Analysis Report (FHAR) states that the design of the Control Room is such that a fire would be contained from spreading from one essential cabinet to the redundant cabinet. This statement is considered to reflect the realistic response of the Davis-Besse Control Room to a fire and was intended to address Appendix A to BTP APCSB 9.5-1, not 10CFR50, Appendix R. An assessment of the Davis-Besse fire pro-tection features assuming a total loss of the Control Room has been con-ducted and discussed in the Davis-Besse Appendix R Compliance Assessment Report (CAR). To avoid future misunderstandings, Revision 8 of the FHAR, transmitted in letter dated May 22, 1987 (Serial No. 1391) reflects that the total loss of the Control Room was assumed as discussed in the CAR. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 21-1

Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 22 - Simplified Flow Chart Provide a " simplified" flow chart which shows the interrelationships of identified components necessary to achieve safe shutdown.

Response

The Davis-Besse Appendix R Compliance Assessment Report (CAR) provides drawings of the alternate shutdown systems which interface with normal shutdown systems. These drawings were provided in response to the NRC Clarification to Generic Letter 81-12, dated March 1982. These drawings, however, do not show all safe shutdown components required in the event of a fire. to this letter provides drawings including simplified training figures for these systems that would be used to achieve and maintain a safe shutdown condition in the event of a fire. These drawings were reviewed to ensure that each safe shutdown component identified in the Safe Shutdown Component List (Appendix A) of the CAR is shown. As a result, these simplified drawings were marked up to show certain safe shutdown components. It should be noted that these drawings are not controlled or issued through the standard drawing review process. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 22-1

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 23 - Assumption of Component Failure to Most Detrimental Position Regarding [ CAR] Page 3-6, confirm that shutdown procedures are based on the assumption that fire-induced failures cause components to assume their most detrimental position.

Response

Davis-Besse safe shutdown procedures for a fire are AB 1203.02, " Serious Station Fire," and AB 1203.26, " Serious Control Room Fire." The operator actions contained in these procedures are based on the evaluation docu-mented in the Davis-Besse Appendix R Compliance Assessment Report (CAR). This evaluation is based on the assumption that safe shutdown components assume their most detrimental positions due to a credible fire-induced failure. A credible fire-induced failure is assumed if a mechanism of failure is identified that could reasonably be expected to occur. As an example, the position of a de-energized valve is not assumed to change since there is no fire-induced mechanism of failure that could reasonably be expected to occur. However, the position of an energized valve could be expected to assume the most detrimental position if a hot short or other such fire-induced mechanism of failure was identified. This evaluation methodology was applied to safe shutdown components identified in Appendix A of the CAR, except for high/ low interface components which are addressed in response to Question No. 29. For those components for which a credible fire-induced failure was identi-fied, the most detrimental position was determined and evaluated for its affect on achieving and maintaining safe shutdown. If safe shutdown would be affected, than a resolution was identified as documented in the CAR. These resolutions include operator actions which have been incorporated l into the aforementioned Davis-Besse shutdown procedures. The shutdown procedures further reflect this evaluation by stating that a fire has the capability ta place control circuits in the least desirable position. Further Response j Toledo Edison believes that no further response is necessary to resolve this question. i I i l 23-1 l l l

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 24 - Reactor Coolant Pump Seal Injection Regarding [ CAR] Page 3-12, provide justification that reactor coolant pump seal injection and cooling via the component cooling water system is not necessa ry.

Response

Page 3-12 of the Davis-Besse Appendix R Compliance Assessment Report (CAR) states: "In a post-fire scenario, it has been determined that Makeup System RCS seal injection and seal cooling via the [ Component Cooling Water System] CCWS is not required to be maintained in order to preserve the integrity of the [ Reactor Coolant Pump] RCP seals, if controlled seal staging is isolated." Toledo Edison believes that the lack of provisions to ensure cooling water to the RCP seals via the Makeup System or CCWS for up to 39 hours is justified by test information provided by Byron-Jackson. Davis-Besse RCPs are equipped with Bryon-Jackson SU Nuclear Mechanical Seals. In August 1980, this type of seal was tested in a test rig with water at 550 F and pressure of 2250 psig, which was circulated to dupli-cate the RCP system. The test was begun and stable temperature and pressure expected for normal operating conditions were achieved at hour 13. At hour 18, the cooling water was shut off and remained off for 39 hours. Cooling water was then restored and cooldown continued for 14 1/2 hours. Maximum temperature at the lower seal was recorded 3 hours before cooldown as 516'F. The maximum seal leakage was 0.27 gpm after 37 hours into the test. The test of the seal was not performed in an operating pump, but in a test rig duplicating operating conditions. The test was static and the seal was not installed against a rotating shaft. In this regard, the test more nearly duplicated the loss of power to the RCPs that would be postulated in conjunction with a fire. The conclusion of this test was that no seal failure or excessive leakage was experienced without seal cooling for 39 hours or from the restoration of cooling water. The results of this test are applicable to this type of seal installed at Davis-Besse. l Toledo Edison, however, will provide means to ensure that cooling water to the RCP seals would be available well within 39 hours of its loss. It is expected that the most probable source of RCP seal cooling would either be from the High Pressure Injection pumps through a cross-connection to the Makeup System Seal Injection flow path or directly from the Makeup System. The method selected to provide cooling water will be evaluated for compliance with 10CFR50, Appendix R and documented in a revision of the CAR. Plant procedures will also be revised to implement the selected method of alternative cooling water supply to the RCP seals. The CAR and procedure revisions will be implemented by December 15, 1987. l 24-1 l L

~Dockat No. S'0-346 .~ License No.~NPF-3 -Serial No. 1361 Further Response By December 15, 1987, Toledo Edison will provide the NRC with a revision to the CAR documenting the method selected to ensure cooling water to the RCP seals within 39 hours after its loss, i l r i 24-2

Dockst No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 25 - Cold Shutdown Time Your current [ CAR] submittal states that it will take "approximately 277 hours" to reach cold shutdown. This appears to be a change from previous statements that predicted 193 hours as indicated in your letter No. 1124, dated February 4, 1985 regarding natural circulation cooldown. Provide justification for this change. Describe any changes in the equipment needed for safe shutdown, safe shutdown procedures, and methods of computation.

Response

In letter dated September 30, 1983 (Serial No. 991), Toledo Edison re-quested an exemption from 10CFR50, Appendix R in order to extend the allowable time to achieve cold shutdown from 72 hours to 193 hours. The NRC granted this exemption in letter dated August 20, 1984 (Log No. 1586). However, page 3-12 of the Davis-Besse Appendix R Compliance Assessment Report (CAR), Revision 1 stated that the reactor could be in hot standby for approximately 277 hours. The allowable time to achieve cold shutdown is 193 hours consistent with the aforementioned NRC-granted exemption. Revision 1 of the CAR inadver-tently stated that the allowable cold shutdown time would be greater than 193 hours based on more conservative assumptions than those used in the NRC granted exemption. Revision 2 of the CAR transmitted to the NRC in letter dated May 14, 1987 (Serial No. 1386) states that the allowable cold shutdown time is 193 hours. In letter dated April 23, 1984 (Log No. 1497), the NRC requested Toledo Edison to review GPU's analysis for Generic Letter 81-21, " Natural Circulation Cooldown." In letter dated February 4,1985 (Serial No. 1124), Toledo Edison stated that the GPU analysis, which demonstrated the ability to increase the cooldown rates in order to achieve cold shutdown more quickly, is applicable to Davis-Besse. However, the revised cool-down rates to be used at Davis-Besse have not been determined at this time. The revised cooldown rate selected from the Generic Letter 81-21 effort will be reflected in the Davis-Besse Fire Protection Program. Consequent-ly, the current allowable time to achieve cold shutdown after a fire at Davis-Besse remains 193 hours. Further Response Toledo Edison believes that no further response is necessary to resolve this response. i 25-1

j Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 26 - IE Information Notice 86-79 Provide a discussion regarding how you are addressing the concerns ex-pressed in IE Information Notice 86-79.

Response

IE Information Notice No. 86-79 (IEN 86-79) dated September 2,1986 (Log No. 1-1461) is entitled " Degradation or Loss of Charging Systems at PWR Nuclear Power Plant Using Swing Pumps Designs." IEN 86-79 discusses how the safety function of charging systems using a swing-pump design can be degraded or lost as the result of design deficiencies in interlocking circuitry or inadequacies in maintenance procedures. Toledo Edison has received IEN 86-79 and has initiated a review to deter-mine the applicability of its issues to Davis-Besse. Toledo Edison has determined that IEN 86-79 is not specifically applicable to Davis-Besse since it is not equipped with charging pumps using a swing pump design. liowever, certain redundant components at Davis-Besse are provided with " swing" features. Consequently, Toledo Edison will review the applicabil-ity of the issues raised in IEN 86-79 to those Davis-Besse components provided with " swing" features. In certain cases, those components provided with " swing" features are considered to be safe shutdown components required in the event of a fire as identified in the Davis-Besse Appendix R Compliance Assessment Report (CAR). The aforementioned review will include those components identified by the CAR and any resulting recommendations will be included in the CAR, as necessary. The results of this review will be transmitted to the NRC by July 31, 1987. Further Response Toledo Edison will transmit the results of the review of IEN 86-79 to the NRC by July 31, 1987. 26-1

.Dockst No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 27 - Analysis of Diesel Generator Auxiliary Systems Regarding [ CAR] Page 3-21, confirm that all emergency diesel engine auxiliary systems have been analyzed for Appendix R conformance.

Response

The Emergency Diesel Generator (EDG) System with its auxiliaries and fuel oil transfer pumps have been analyzed for Appendix R conformance. The safe shutdown systems, components and circuits, including the EDG System, were selected for fire protection evaluation based on 10CFR50, Appendix R; NRC Generic Letter 81-12 dated February 20, 1981 and its clarification dated March 1982; NRC letter dated March 7,1983; and Information Notice 84-09 dated February 13, 1984. Each of the two Davis-Besse EDGs is equipped with its own auxiliaries which include starting air receivers, fuel oil, lube oil, cooling water, intake and exhaust system, voltage regulator and controls. Cooling water is provided from the Component Cooling Water (CCW) System while electric power for each engine's auxiliaries is provided by its own generator and station batteries. The ventilation for the EDGs is provided by the EDG Room Fans and associated dampers. The CCW, Station Battery, and Ventil-ation Systems have also been analyzed for Appendix R conformance as separate systems. There are two fuel oil storage tanks physically separate from one another, each having a 40,000 gallon capacity. Each storage tank supplies fuel to its respective Emergency Diesel Generator Day Tank. The fuel oil trans-fer pump, one per EDG, provides transfer capability from its associated storage tank to the individual diesel generator day tank. Certain components of the EDG Auxiliary Systems are mechanical in nature. These mechanical components were analyzed for Appendix R in conjunction with their corresponding electrical components or were individually analyzed. The electrical components and individual mechanical components are identified by the safe shutdown component list. These mechanical com-ponents, with the exception of the fuel oil storage tanks, are located within the EDG rooms and would not be affected by a fire outside its associated EDG room. The Fuel Oil Transfer Pumps, Air Start Solenoid Valves and EDGs themselves and certain integral components are electrical in nature and could be impaired i by a fire. Consequently, these components and associated circuits were further evaluated for conformance with Appendix R as documented in the Davis-Besse Appendix R Compliance Assessment Report (CAR). This assessment and the resolutions proposed in the CAR demonstrates that at least one EDG with the necessary auxiliary systems would be operable in the event of a fire. 27-1

( Docket No. 50-346 License No. NPF-3 Serial No. 1361 Further Response Toledo Edison believes that no further response is necessary to resolve this questions. 27-2

D:cket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 28 - Protection of Valve Operators Regarding [ CAR] Page 4-2, describe how valve operators have been protected from fire damage.

Response

Page 4-2 of the Davis-Besse Appendix R Compliance Assessment Report (CAR) identifies the assumptions used in the Appendix R analysis. One of these assumptions is that passive mechanical components are assumed to remain functional during and after a fire unless they are ignition sources. These components include heat exchangers, manual and check valves, piping and tanks. The valve operators identified in the CAR have been evaluated and determined not to require a fire-rated wrap. However, these operators have been evaluated to satisfy 10CFR50, Appendix R and adequate fire protection has been identified in the CAR such as separation of redundant counterparts by 3-hour rated fire walls or manual operation of the valve. There are five fire areas in which the motor or air valve operators themselves could be exposed to a fire. Appropriate action would be taken by the Fire Brigade and operations personnel to extinguish the fire and to manually reposition the valve. These fire areas, valves and combustible loading are as follows: Combustible Fire Valve Loading Area ID No. Description (BTU /sq. ft.) AB DH 2734 Decay Heat Pump 2 BWST Suction Valve 4,448 AC Dl! 07A BWST Isolation Valve 655 D CF01A&B Core Flood Isolation Valve 15,981 DB DH 1517 DKR Suction Line 1 Valve 13,886 II SW 1399 TPCW Heat Exchanger Inlet Iso V1v 16,737 SW 630 TPCW Heat Exchanger Outlet Iso Vlv SW 631 TPCW Heat Exchanger Outlet Iso V1v SW 632 TPCW Heat Exchanger Outlet Iso Viv l l l l l 28-1 l

Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 The above valves, except SW630, 631 and 632 are equipped with electrically driven valve operators manufactured by Limitorque. In order to manually operate those valves via their Limitorque valve operator, the external declutch lever is pulled downward which mechanically disconnects the valves stem from the electric motor and connects it to the handwheel. Therefore, when the handwheel is rotated, the valve operator is put into motion, repositioning the valve independent of the electric motor. Toledo Edison considers that the manual operation of the valve via the Limitorque valve operator to be strictly mechanical, similar to the handwheel on a manual valve. Valves SW630, 631 and 632 are each equipped with a pneumatically driven valve operator. In order to manually operate the valves, the instrument air supply would be isolated and the actuators vented. The handwheels would then be rotated to reposition the valves. The manual operation of these valves via the valve operators would also be strictly mechanical, similar to the handwheel on a manual valve. The fire-induced failure mechanisms of a valve operator would be from binding due to heat stress, thermal expansion or lubrication degradation. Such damage would not occur to these valves based on the combustible loading of the fire areas. The full BTU content of the combustibles would not be transmitted to the valve operators since the combustibles in these fire areas are mainly noncombustible cables in cable trays and enclosed charcoal filters which are not located near the valve operators, and include anti-sweat insulation in the vicinity of valve SW1399. Valve SW1399 is redundant to valves SW 630, 631 and 632. These redundant valve groupings are located more than 200 feet from one another, separated by a concrete wall, and each valve grouping is protected by automatic sprinklers. Consequently, these above motor and air driven valve operators would not be mechanically impaired by a fire in such a manner to prevent their sub-sequent mechanical operation consistent with the aforementioned assumption regarding mechanical components. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 28-2

Dockzt No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 29 - High-Low Pressure Interface Regarding [ CAR] Page 5-6, the assumption that fire damage to three phase AC power cables will not result in a spuriously energized cable is unac-ceptable when applied to the analysis of high-low pressure interface. Review your response to address protection of high-low pressure interfaces accordingly.

Response

Page 5-6 of the Davis-Besse Appendix R Compliance Assessment Report (CAR), Revision 1, discusses the assumptions used in the Spurious Actuation Analy-sis. These assumptions include that fire-induced failure of a three-phase AC power cable was determined not to be credible and would not spuriously energize the cable. This assumption was applied to the spurious actuation analysis of circuits including those associated with high-low pressure interface components. An evaluation of the spurious actuation of high-low pressure interface components due to the hot short of three-phase AC power circuits has been perfo rmed. The evaluation is currently under technical, interdisciplinary review. After this review, Toledo Edison will compare this completed eval-uation to the CAR and identify any necessary procedure revisions or physical modifications. By December 15, 1987, Toledo Edison will document this review by revision of.the CAR including the assumptions and basis of the spurious actuation analysis of the high-low pressure interface components. Further Response Toledo Edison will issue a revision to the CAR by December 15, 1987 to reflect the results of the spurious actuation analysis of high-low pressure interface components. .h 29-1

z Dock 2t No. 50-346 + i License No. NPF-3 Serial No. 1361 s Question No. 30 - Spurious Actuation Assumptions Regarding [ CAR] PAge 5-7, provide the basis for concluding that represen-tative circuits will not spuriously actuate.

Response

Page 5-7 of the Davis-Besse Appendix R Compliance Assessment Report (CAR) discusses the methodology and results of the spurious actuation analysis. This analysis was conducted to satisfy the guidelines set forth in the Clarification to NRC Generic Letter 81-12, dated March 1982. While the term " representative circuits" is not used, the CAR indicates that certain fire-induced circuit failures are such a low probability as not to be credible to cause spurious actuation. A systems engineering review was performed on plant systems and equipment to identify those components that had the potential via spurious opera-tion to defeat the safe shutdown functions as discussed in the CAR. These components were included in the Safe Shutdown Component List of the CAR and evaluated to satisfy Appendix R in the same manner as any other safe shutdown component. The notes of Section 4 of the CAR specifically discuss the impact, if any, of these components on the safe shutdown functions and proposes the necessary resolutions to satisfy Appendix R. If spurious actuation was considered not to be credible, the basis for this conclusion was specifically stated in the appropriate note for the corres-ponding circuit and component. To determine the potential for spurious actuation, elementary wiring diagrams were reviewed. This review resulted in a determination that the loss of control power would not result in spurious actuation since the component would not operate. The exception is solenoid valves that are not designed fail-safe and may spuriously actuate from a loss of control power. Consequently, spurious circuits are those circuits connected to an operatiog device (e.g. relay coils, solenoids) that may result in a loss i of power to solenoid valves not designed fail-safe or that may fail in l such a way as to energize the operating device. Further review determined l that fire-induced failure of indication circuits, three-phase AC power l circuits and certain permissive interlocks and auxiliary relay circuits were unlikely to energize their operating device and result in spurious l actuation. l Three-phase AC power circuits are not considered to be spurious circuits due to the low probability of obtaining a hot short on all three phases in the proper sequence. Additionally, there is an even lower probability of getting two three-phase power cables to come in contact with each other l since they are normally routed individually in separate conduits. This position is supported by the NRC in Generic Letter 86-10 dated April 24, 1986 (Log No. 1983) (Ref.: Question 5.3.1). 30-1

o Docket No. 50-346 License No. NPF-3 Serial No. 1361-Attachment.3 Regarding DC permissive interlocks and auxiliary relay circuits, Generic Letter 86-10 states: "for ungrounded DC circuits, if it can be shown that only two hot shorts of the proper polarity without grounding could cause spurious operation, no further evaluation is necessary...." DC circuits of this type are not considered to be spurious circuits since two hot shorts of the proper polarity without grounding is considered to be of such a low probability as not to be a credible fire-induced failure for spurious actuation. Also, certain AC permissive interlocks and auxiliary relay circuits were determined not to be spurious circuits since these circuits are not connected to an operating device or the connected operating device was designed fail-safe. Those AC permissive interlocks and auxiliary relay circuits connected to an operating device that was not designed fail-safe were considered to be spurious circuits and evaluated in the CAR. Indication circuits also are not considered to be spurious circuits. Based on a review of the elementary wiring diagrams, the fire-induced failure of these circuits, at worst, would result in a loss of control power and would not spuriously actuate their associated components since the circuits are not connected, and hence, cannot energize the operating device (e.g. relay coils, solenoids). The above discussion is a sufficient basis to conclude that certain fire-induced circuit failures are such a low probability as not to be credible to cause spurious actuation. It should be noted that high-low interfaces are discussed in Question 29. Further Response Toledo Edison believes that no further respoaae is necessary to resolve this matter. l l [ 30-2

1 Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 31 - Associated Circuits per Inspection Report No. 83-016 The information provided has not specifically addressed the associated circuits concerns / findings of the September 1983, Appendix R audit as detailed in report 50-346/83-16 (DE). Provide a description as to how the associated circuits review methodology, result, and corrective action has responded to these issues. (Reference findings: 346/83-16-01B and 346/83-16-08).

Response

The NRC's Inspection Report No. 50-346/83-16 (Log No. 1-1024) documents the results of the special safety inspections conducted at Davis-Besse on July 11-13 and July 25-29, 1983. The intent of the inspection was to assess the Davis-Besse conformance with 10CFR50, Appendix R (Sections III.G, J, L and 0), including the exemptions approved by the NRC. Non-conformance 83-16-01B which addressed the failure of Toledo Edison to perform a spurious signal analysis for certain motor-operated Service Water Valves, Pressurizer PORV and its Block Valve, and the Letdown Cooler Isolation Valves. Open Item 83-16-08 addressed the failure of Toledo Edison to provide procedures for resolution of the spurious actuation of the Decay Heat Isolation Valves, which are high/ low pressure boundary components. In letter dated November 7, 1986 (Serial No. 1-678), Toledo Edison re-sponded to Inspection Report No. 83-16, including Noncompliance 83-16-01B. This response documents that the spurious actuation analysis of safe shutdown circuits and associated circuits, including circuits for those components addressed by Nonconformance 83-16-01B, was conducted and identified resolution of any deviations as described in the Davis-Besse l Appendix R Compliance Assessment Report (CAR). i The identified resolution, including modifications and procedure l revisions, have been completed in accordance with their schedule identified in the Inspection Report No. 83-16 response. Toledo Edison has not provided a written response to Open Item 83-16-08 since Open Items are normally closed by subsequent NRC inspections. However, Davis-Besse System Procedure SP 1104.04, " Decay Heat and Low Pressure Injection Operating Procedure," was revised to require de-energization of j l the two Decay Heat Isolation Valves during operation at elevated pressures l which will assure maintenance of this high/ low pressure interface. This protection feature is discussed in the CAR. It should be noted that NRC Region III follow-up inspections have reviewed certain actions taken regarding this matter and have closed Noncompliance 83-16-01B and Open Item 83-16-08 as documented in Inspection Report No. 85-028 dated November 22, 1985 (Log No. 1-1280) and Inspection Report No. 86-06 dated February 28, 1986 (Log No. 1-1342). 31-1 l

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Further Response Toledo Edison believes that no further response is necessary to resolve this question. l I l 31-2 i

D:cket No. 50-346 Licente No. NPF-3 Serial No. 1361 Question No. 32 - Status of Technical Specification Revisions Regarding [ CAR] Page 7-6, provide a status of the technical specification revisions referenced on this page.

Response

Page 7-6 of Revision 1 of the Davis-Besse Appendix R Compliance Assessment Report (CAR) discusses that technical specification will be developed to address the alternate shutdown capability provide by the Backup Service Water Pump. Toledo Edison has subsequently reviewed the acceptability of such a technical specification and determined that it would not be consis-tent with the scope of the existing Technical Specifications. Revision 2 of the CAR, transmitted to the NRC in letter dated May 14, 1987 (Serial No. 1386), currently discusses that no technical specifications are necessary to reflect the alternate shutdown capability. Toledo Edison has, however, submitted a proposed technical specification revision relating to fire protection in letter dated May 20, 1987 (Serial No. 1385). This proposed revision is intended to reflect the actual plant configuration and the results of the fire protection evaluations conducted to satisfy 10CFR50, Appendix R and Appendix A to BTP APCSB 9-5.1. Upon NRC approval of this Technical Specification revision, Toledo Edison intends to submit a license request to incorporate the fire protection program and major commitments by reference into the Updated Safety Analysis Report and to delete the fire protection-related Technical Specifications. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 32-1 l l

Dockrt No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 33 - Alternative Shutdown per Inspection Report No. 86-016 Regarding [ CAR] Pages 7-7 and 7-8, the information in this section has not specifically addressed the staff's previous concerns regarding the adequa-cy of the alternate shutdown capability as described in the above refer-enced inspection report and in the safety evaluation pertaining to interim measures, dated September 23, 1983. Provide a response which includes the information required for staff review of alternate shutdown capabilities as delineated in the clarification to Generic Letter 81-12, (Reference findings: 346/83-16-02 and 346/83-16-01A).

Response

Special safety inspections were conducted at Davis-Besse on July 11-13 and July 25-29, 1983 in order to assess the Davis-Besse conformance with 10CFR50, Appendix R (Sections III.G, J, L and 0), including the exemptions approved by the NRC. In response to these inspections, Toledo Edison developed the Davis-Besse Appendix R Compliance Assessment Report (CAR). The CAR presents the evaluation for alternate shutdown capability as required by Appendix R, Sections III.G and III.L. The CAR is based on the NRC clarification letter to Generic Letter 81-12 dated March 1982 and on the results of NRC Inspection Report No. 83-16 dated August 30, 1984 (Log No. 1-1024) and Toledo Edison's commitments thereto, which form the basis of the NRC Safety Evaluation Report dated September 23, 1983 (Log No. 1375). Revision 1 of the CAR was submitted to the NRC in letter dated June 3, 1986 (Serial No. 1253). In letter dated November 7,1986 (Serial No.1-678), Toledo Edison re-sponded to Inspection Report No. 83-16, including Noncompliances 83-16-01A and 83-16-02. This response documents that an analysis of the Davis-Besse alternate shutdown capability, including the availability of one train of hot shutdown systems free from fire damage, was conducted and that resolu-tions of any deviations are identified in the CAR. The response to Inspection Report No. 83-16 also documents that the resolutions of the issues addressed by Noncompliances 83-16-01A and 83-16-02 involve certain modifications, procedure revisions and exemptions, and provides a schedule for their completion. The procedure revisions i have been completed in accordance with that schedule. The physical modifications are scheduled to be completed by the end of the sixth refueling outage. The exemption requests were submitted to the NRC in Toledo Edison letter dated March 6, 1986 (Serial No. 1255) as amended by letter dated January 12, 1987 (Scrial No. 1327). It should be noted that NRC Region III follow-up inspection documented in Inspection Report No. 85-028 dated November 28, 1985 (Log No. 1-1280) has reviewed certain actions taken regarding Noncompliance 83-16-01A and closed that portion of the noncompliance involving the NRC-approved exemption for the time to achieve cold shutdown. While not specifically l l l 33-1 1

Docket No. 50-346 License No. NPF-3 Serial No. 1361 stated in the response to Inspection Report No. 83-16, the CAR documents that Davis-Besse will have the capability of achieving cold shutdown conditions independent of the control room and cable spreading room upon implementation of the identified resolutions. Further Response Toledo Edison believes no further response is necessary to resolve this question. 33-2

~ Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 34 - Use of Shutdown Procedure for Fire Area A Regarding (CAR] Page 4.A-5, we are concerned about potential confusion resulting from the reliance on both Train 1 and Train 2 shutdown systems for a fire in Area-A. Describe how shutdown procedures make it clear to the operators which systems will be available for a fire in this area.

Response

Fire Area A consists of many rooms which contain redundant trains of safe shutdown equipment required in the event of a fire. Each of these safe shutdown components is separated from its redundant counterpart by a 3-hour fire barrier or by a horizontal distar.ce of at least 20 feet. One train of components having 20-foot separation is provided with localized sprinklers and detectors. This protection is discussed in the Davis-Besse Appendix R Compliance Assessment Report (CAR) and Toledo Edison's exemption request dated March 6, 1986 (Serial No. 1255), as amended by letter dated January 12, 1987 (Serial No. 1327). Consequently, for a fire in this fire area, either Train 1 or Train 2 components would be used to ensure safe shutdown. Abnormal Procedure AB1203.02, " Serious Station Fire," would be used to achieve and maintain safe shutdown conditions in the event of a fire in Fire Area A. This procedure informs the operator that a fire has the capability to place control circuits in the least desirable position. The operator is to respond to a failure based on the symptom provided by the failure (e.g. loss of flow). This procedure provides the operator with appropriate actions to ensure one train of safe shutdown equipment required in the event of a fire is available due to the failure of any system to properly actuate. These actions are specified in the attach-ments of the procedure. Attachment 1 of the procedure addresses Fire Area A and informs the operator that either Train 1 or Train 2 would be used to ensure safe shutdown and includes those manual operator actions identified as a result of the evaluation documented in the CAR. The operator actions specified in Procedure AB 1203.02 are adequate to ensure safe shutdown due to a fire in Fire Area A. l Further Response Toledo Edison believes that no further response is necessary to resolve this question. l l 1 34-1

Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 35 - Location of Safe Shutdown Circuits in Fire Area A Regarding [ CAR] Page 4.A-12 (and others), are all of the circuits which are relied upon for safe shutdown located in Room 1247 (Reference Notes: 2, 3, 4, 8, 9, 11, 18, 19, 20, 21, 22, 23, 26, 40, and 42).

Response

Safe shutdown circuits are located in Room 124 and other rooms within Fire Area A. Each of these safe shutdown circuits is separated from its redundant counterpart by a 3-hour fire barrier or by a horizontal distance of at least 20 feet. One train of components having 20-foot separation is provided with localized sprinklers and detectors. This protection is discussed in the Davis-Besse Appendix R Compliance Assess-ment Report (CAR) and Toledo Edison's exemption request dated March 6, 1986 (Serial No. 1255), as amended by letter dated January 12, 1987 (Serial No. 1327). The location of the safe shutdown circuits within Fire Area A are shown on the sketches presented in Enclo. e 3. Additionally, the boundaries of Fire Area A are fire rated for 3-hours. This will be more clearly described in a future revision to of the Davis-Besse Fire Hazard Analysis Report (FHAR) to be submitted to the NRC by December 15, 1987. Further Response By December 15, 1987, a revision to the FHAR will be submitted to the NRC to more clearly describe that the boundaries of Fire Area A are fire rated for 3-hours. I i t l I 35-1 i

Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 36 - Two Auxiliary Feedwater Pumps Driven by One Steam Generator Regarding (CAR) Page 4.A-14, justify the contention that output from SG1-1 is sufficient to run the AFW Pump Turbine 1-1, even if valve MS107A was open.

Response

The Davis-Besse Appendix R Compliance Assessment Report (CAR), page 4.A-14, Note 5, discusses the compliance of circuits for the Auxiliary Feedwater Pump Turbine (AFPT) Main Steam Inlet Cross-Connection Valves MS 106A and MS 107A. These valves are normally open and allow each AFPT to take steam from either Steam Generator. As discussed in the CAR, the availability of valves MS 106A and MS 107A need not be assured since the supply to the AFPTs would be provided by through the AFPT Main Steam Inlet Isolation Valves MS 106 and MS 107. Thus, Cross-Connection Valves MS 106A and MS 107A were evaluated for possible flow diversion paths. This evaluation concluded that one Steam Generator has sufficient output capacity to run its associated AFPT plus the opposite train AFPT through its Cross-Connection Valve, either MS 106A or MS 107A. This capability was demonstrated by performance of Test Procedure TP 850.18, " Integrated SFRCS/AFWS Test," which was completed on December 15, 1986. FUTURE RESPONSE Toledo Edison believes that no further response is necessary to resolve this question. 36-1

Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 ,uestion No. 37 - Location of Certain Circuit Q Regarding [ CAR] Page 4.A-19, state whether the circuit associated with component S33-1 is located outside of the fire area as stated in Appendix B-1 or within the fire area as stated in the narrative.

Response

The Appendix R conformance of Circuit ICCEACIC for the Control Room Emergency Air Conditioning Unit, S33-1, is discussed in the Davis-Besse Appendix R Compliance Assessment Report (CAR), note 12, pages 4.A-18 and 4.A-19. The narrative of Fire Area A, note 12, discusses the routing of circuit ICCEACIC within Fire Area A. CAR, Appendix B-1 indicates that circuit ICCEACIC is embedded and is also routed in seven fire areas including Fire Area A. Toledo Edison believes that the CAR is consistent for this circuit routing. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 37-1

D:ck:t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 38 - Use of HPI for Fire Area A Regarding [ CAR) Page 4.A-26, confirm that the shutdown procedures stipu-late that the HPI system shall be used to shutdown the plant for a fire in Area A.

Response

The Davis-Besse Appendix R Compliance Assessment Report (CAR), pages

4. A-25, 4. A-26 and 4. A-27 discuss the Appendix R conformance of the circuits for the HPI Flow Indicators, FYI-HP03C and D, and the HPI Lube Oil Pumps, P197-1 and P197-2. As discussed in the CAR, protection for these HPI circuits was not necessary for a fire in Fire Area A since the Makeup System would be used for RCS inventory and boration control in lieu of the HPI System. Consequently, the shutdown procedures appropriate-ly do not address the use of the HPI System for a fire in Fire Area A.

The Fire Area A Compliance Summary of the CAR discusses that one train of the Makeup System would be available. The Fire Area A analysis of the CAR does not specify manual operator actions to ensure the avail-ability of the Makeup System. Further, shutdown procedure AB 1203.02, " Serious Station Fire," indicates that one train of the Makeup System would not be affected by a fire in Fire Area A, and also does not specify any manual operator actions for the Makeup System. Toledo Edison believes that the CAR analysis and shutdown procedures are consistent for the use of the Makeup System for a fire in Fire Area A. Further Response Toledo Edison believes that no further response is required to resolve this question. 38-1

Dockst No.-50-346 ' License No. NPF-3 Serial No. 1361 Question No. 39 - Sprinklers for Cable Chase in Fire Area A Regarding [FHAR] Page 5.A-8, considering that cables for both shutdown divisions are located in Area A and that reliance is placed on 35 feet of spatial separation, justify why the cable chase is unsprinklered (fire load of 655, 000 BTUs/sq. ft.).

Response

Fire Area A consists of many rooms which contain redundant trains of safe shutdown equipment required in the event of a fire. Each of these safe shutdown components is separated from its redundant counterpart by a 3-hour fire barrier or by a horizontal distance of 20 feet. One train of components having 20-foot separation is also provided with localized sprinklers and detectors. This protection is discussed in the Davis-Besse Appendix R Compliance Assessment Report (CAR) and Toledo Edison's exemption request dated March 6, 1986 (Serial No. 1255), as amended by letter dated January 12, 1987 (Serial No. 1327). One of the fire zones within Fire Area A consists of a cable chase, which contains only Train 2 safe shutdown circuits relied upon in the event of a fire. The Train 1 circuits are located outside the cable chase and are separate from the Train 2 circuits within the cable chase by the three-hour fire walls of the cable chase. While the bottom chase is not protected by a rated fire barrier, it is covered by a steel plate as discussed in the Davis-Besse Fire Hazards Analysis Report (FHAR). Additionally, a fire detector is installed in the cable chase to alert the Control Room and ultimately the Fire Brigade to manually extinguish any fire. Consequently, an automatic fire suppression system in the cable chase is not required to satisfy 10CFR50, Appendix R. The high fire loading of this cable chase is due to its physical configu-ration. As discussed in the FHAR, the combustibles for the cable chase consist of several cable trays that run vertically through the chase. These cables represent approximately 34.7 million BTUs. These cable trays havesolidbottomsandarecoveredwithalayerofKaowoo}. The cable chase is tall and slender with a floor area gf only 53 ft and has a fire loading of approximately 654,717 BTU /ft The amount of combusti-ble material itself does not justify the installation of sprinklers in the cable chase since the safe shutdown cables within the cable chase are separated from their redundant counterparts by the three-hour rated fire walls of the cable chase as discussed in the FRAR. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 39-1

Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 40 - Dedicated Alternative Shutdown Fans Regarding [ CAR] Page 4.AB-14, state whether the portable fans used for alternate shutdown are the same fans relied upon by the fire brigade for post-fire salvage / overhaul activities or are dedicated for shutdown operations.

Response

The Davis-Besse Appendix R Compliance Assessment Report (CAR), Fire Area AB, Note 11, Page 4.AB-14 discusses the use of temporary ventilation in Room 113 as an alternative shutdown capability. This temporary ventila-tion would be established by portable fans and elephant trunk ducting. These portable fans and elephant trunk ducting are dedicated for alterna-tive shutdown. Separate portable ventilation equipment is available for use in post-fire salvage / overhaul activities. In order to speed the recovery from a fire, the dedicated portable fans and elephant trunk ducting may be used to rcmove smoke from the area of the fire if this fire area is not one for which the alternative shutdown portable fans and elephant trunk ducting are dedicated. Further Response Toledo Edison believes that no further response is necessary to resolve this matter. 40-1

D:ckat No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 41 - Multiple High-Impedence Faults Regarding (CAR] Page 4.AB-15, provide details describing the installation of ground-fault protection to preclude multiple high impedance faults.

Response

Page 4.AB-15 of the Davis-Besse Appendix R Compliance Assessment Report (CAR) proposes to install ground-fault protection at certain breakers in order to preclude the loss of power to Motor Control Centers (MCC) due to multiple high impedance faults. The installation of ground-fault protection is also proposed for breakers to resolve fire protection concerns in other fire areas. Toledo Edison has subsequently evaluated this proposed additional ground-i fault protection in light of the existing ground-fault protection in-stalled at Davis-Besse. This existing protection includes ground over-current relays on the unit substation and solid-state overcurrent devices on downstream HCC feeder breakers fed from essential 480 VAC switchgear. Toledo Edison has determined that an appropriate means to minimize the potential loss of essential power due to a fire would be to manually isolate the associated circuits of concern at the MCC through selected tripping of the buses. This manual action is specified by the two Davis-Besse shutdown procedures, AB 1203.02 and AB 1203.26, and directs that only the associated circuit of concern be isolated. The CAR will be revised by December 15, 1987 to reflect the above operator action rather than the implementation of additional ground-fault protection. Further Response Toledo Edison will issue a revision to the CAR by December 15, 1987 to reflect selected tripping of the buses to manually isolate the associated circuits of concern at the MCC, i 41-1 l

Dacket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 42 - Offsite Supply of Diesel Generator Fuel Oil Regarding [ CAR] Page 4.BN-4, suf ficient justification has not been provid-ed to accept the use of an offsite fuel oil supplier to compensate for the loss of the redundant fuel oil transfer pumps. The licensee should propose protection to assure that one fuel oil transfer pump train remains free of fire damage.

Response

Page 4.BN-4 of the Davis-Besse Appendix R Compliance Assessment Report discusses that guidelines would be provided in a safe shutdown procedure to ensure a backup source of fuel oil to the emergency diesel generator (EDG) day tanks by means of an emergency fill connection. This backup source of fuel was intended to be provided from a local, offsite source. Toledo Edison has evaluated an alternate means to provide a source of fuel oil from an onsite source. The Main Fuel Oil Tank has an adequate supply of fuel oil exceeding 193 hours, which is the allowable time to achieve cold shutdown as documented in an exemption granted by the NRC in letter dated August 20, 1984 (Log No. 1586). A pipe from this tank enters Room 319 containing EDG 1-2. Toledo Edison will install an isolation valve with a hose connection on this pipe and provide a portable pump to transfer fuel oil from the Hain Fuel Oil Tank to the EDG Day Tank 1-2 located in Room 320A, adjacent to Room 319. This portable pump would be powered from an essential power supply or a portable generator. This alternative source of fuel would be protected by the 3-hour rated fire walls of Rooms 319 and 320A and would not be required for a fire in Rooms 319 and 320A. This capability for an onsite source of fuel oil will be implemented prior to the return to power from the sixth refueling outage. A revision to the CAR to reflect this proposed capability will be issued by December 15, 1087. Further Response Toledo Edison will issue a revision to the CAR by December 15, 1987 to reflect the capability to provide an onsite source of fuel oil. 42-1

Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 43 - Description of Radiant Energy Shicids Regarding Fire Areas D/DA, provide details describing the radiant energy shield used to protect vulnerable circuits.

Response

Fire Area D is the Containment and Fire Area DA is the Containment Annulus. Within the containment, four circuits and two penetration terminal boxes associated with the two Containment Air Cooler (CAC) fans ar.d two transmitters and circuits associated with the pressurizer level indica-tions do not have adequate separation in accordance with 10CFR50, Appendix R. Within the Containment Annulus, certain circuits associated with the CAC fans also do not have adequate separation in accordance with 10CFR50, Appendix R. As discussed in the Davis-Besse Appendix R Compli-ance Assessment Report (CAR), radiant energy shields will be installed in the Containment and the Containment Annulus to protect the redundant compo-nents. At this time, the design for these radiant energy shields have not been completed, liowever, conceptual criteria for the designs were developed. For the CAC circuits within the Containment Annulus, the radiant energy shield will consist of a noncombustible material with a 1-hour fire rating. This shield will be installed to completely enclose the whole length of one train of CAC circuits within the Containment Annulus. The radiant energy shield within Containment will also consist of a non-combustile material with a 1-hour fire rating. This shield will be installed to completed enclose one penetration terminal box for the CAC Fans and one transmitter for the Pressurizer Level indications. This shield will also be installed to completely enclose the whole length of one train of CAC Fan circuit within the Containment due to the close proximity of the redundant CAC Fan circuits to one another. Ilowever, the pressurizer level indication circuits begin a separate routing at their transmitters. The radiant energy shield will be installed to completely enclose one train of these circuits that are within 20 feet of their redundant counterpart, and the remainder of the circuits are not in line of sight of one another due to separation by the concrete D-ring shielding structure. As discussed in Toledo Edison letter dated November 7, 1986 (Serial No. 1-678), these radiant energy shields will be installed prior to the return to power from the sixth refueling outage. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 43-1

Dockst No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 44 - Copy of Shutdown Procedures Regarding [ CAR] Fire Areas DD/FF, provide a copy of revised procedure AB 1203.26 (post September 1983 procedure).

Response

During the meeting on February 17-18, 1987 between representatives of the NRC and Toledo Edison, uncontrolled copies of Abnormal Procedures AB 1203.26, " Serious Control Room Fire," and AB 1203.02, " Serious Station Fire," were provided to the NRC. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 44-1 l

Docket No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 45 - Isolation Switches and Redundant Fuses Regarding [ CAR] Page 4.DD-40 (and others), confirm that the design and installation of isolation switches and redundant fuses will conform with the criteria established in Generic Letter 81-12.

Response

Page 4.DD-40 of the Davis-Besse Appendix R Compliance Assessment Report (CAR) states that isolation switches and redundant fuses will be installed at certain cabinets. Generic Letter 81-12 addresses the design of isola-tion switches. The new isolation switches installed to satisfy 10CFR50, Appendix R meet the intent of Generic Letter 81-12 in that the switches conform to the design criteria of the systems on which they were installed. This criteria is specified in the Davis-Besse Updated Safety Analysis Report. Additionally, IE Information Notice (IEN) 85-09 dated January 31, 1985 (Log No. 1-1111) addresses a concern that circuit transfer may not occur due to fire damage of transfer schemes with only one set of fuses. An engineering evaluation of the Davis-Besse conformance with IEN 85-09 was conducted. The results of that evaluation was utilized to the design of existing isolation switches and redundant fuses and will be considered in the design and installation of the additional isolation switches determined to be necessary in the CAR. Further Response Toledo Edison believes that no further response is necessary to resolve this question. I I 45-1 i

Docket No. 50-346 ~ License No. NPF-3 Serial No. 1361 Question No. 46 - Isolation Switch for Certain Circuit Regarding (CAR] Page'4.DD-41, justify the lack of a commitment to install isolation devices for circuit ICAC103A, as was done for other previously unisolated hot shutdown circuits.

Response

Revision 1 of the Davis-Besse Appendix R Compliance Assessment Report (CAR), Note 33, Page 4.DD-41 addresses certain circuits for the 4.16 KV AC Switchgear Bus C1. Note 33 indicates that six circuits, including circuit ICAC103A, for this essential bus are not isolable but provides resolution only for five circuits and not circuit ICAC103A. Toledo Edison has reviewed the proposed resolution and has determined that circuit ICAC103A was inadvertently not included in the proposed resolu-tion. Revision 2 of the CAR has been transmitted to the NRC in letter dated May, 14, 1987 (Serial No. 1386) and includes a commitment to install an isolation device for circuit ICAC103A. The installation of this isolation device is currently addressed by a modification scheduled to be installed prior to the return to power from the sixth refueling outage. Further Response Toledo Edison believes that no further response is necessary to resolve this question. i a i 46-1 l l L

Dockat No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 47 - RCS Cold Leg Temperature Indication Regarding [ CAR] Page 4.DD-56, the lack of RCS Loop 1 cold leg temperature indication as part of post-fire alternate shutdown instrumentation repre-sents an unjustified nonconformity with Section III.L of Appendix R. This condition also fails to respond to concerns / findings of the Appendix R audit team as described in the previously referenced report.

Response

In response to the special NRC safety inspections conducted at Davis-Besse on July 11-13 and July 25-29, 1983, Toledo Edison committed in letter dated September 13, 1983 (Serial No. 986) to interim actions to compensate for the absence of reactor coolant cold leg temperature indication at the Auxiliary Shutdown Panel. This interim. compensation consists of a port-able battery powered Digital Volt-Ohm Meter (DV0M) that has been made available to obtain resistance readings for conversation to temperature indications. The implementation of this interim action was confirmed and accepted in NRC Inspection Report No. 83-16 dated August 30, 1984 (Log No. 1-1024) and NRC Safety Evaluation Report transmitted in letter dated September 23, 1983 (Log No. 1375). Revision 1 of the Davis-Besse Appendix R Compliance Assessment Report (CAR), Page 4.D-56, reflected this approved interim action for the cold leg temperature indication. However, Toledo Edison responded to Inspec-tion Report No. 83-16 in letter dated November 7, 1986 (Serial No. 1-678) and committed to provide digital readouts of reactor coolant cold leg temperature at a local panel outside the Control Room. This commitment will be included in a revision of the CAR to be issued to the NRC by December 15, 1987. The use of the digital readout device would be as a result of a fire in the Control Room / Cable Spreading Room. The operators would place the digital readout device in use at the penetration room. The circuits for the cold leg temperature indication would be disconnected via a multi pin twist disconnect plug and then connected to the digital readout device. The digital readout device will be battery powered and no external power source will be required. The digital readout device will be dedicated for use in obtaining reactor coolant temperature indication. The digital readout device will be implemented prior to the return to power from the sixth refueling outage. Further Response Toledo Edison will issue a revision of the CAR by December 15, 1987 to reflect the digital readout of reactor coolant cold leg temperature to be provide at a local panel outside the Control Room. 47-1

Dockst No. 50-346 License No. NPF-3 Serial No. 1361 Question No. 48 - Operator Actions for a Control Room Fire Regarding [ CAR] Page 4.FF-7, for a fire in the control room, describe the actions within the control room that are being relied upon to achieve and maintain safe shutdown prior to control room evacuation.

Response

Page 4.FF-7 of the Davis-Besse Appendix R Compliance Assessment Report (CAR) is the Compliance Summary for a fire in Fire Area FF, the Control Room Complex. This Compliance Summary states that many procedure actions are necessary to recover from a fire in the Control Room and that these actions are specified in Abnormal Procedure AB 1203.26, " Serious Control Room Fire." This procedure specified nine manual operator actions, in addition to obtaining plant keys, to be performed prior to Control Room evacuation and requires the Reactor and Equipment Operators and the Shift Supervisor or Assistant Shift Supervisor to then report to the Fire Emergency Cabinet outside the Control Room. Two of these actions, reactor trip and turbine trip, are to be completed prior to Control Room Evacuation. The remaining actions may be completed prior to evacuating the Control Room or may be completed and verified outside the Control Room in accordance with addi-tional steps provided in the procedure. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 48-1

e-Dock 2t Na. 50-346 License No. NPF-3 Serial No. 1361 Additional Question A - Amended Exemption Request Document the evaluation regarding the ventilation exhaust ducts in the ceiling of the Auxiliary Feedwater Pump Rooms.

Response

In letter dated January 12, 1987 (Serial No. 1327), Toledo Edison withdrew a previous exemption request for pressure relief openings in the ceilings of Fire Areas E and F, the Auxiliary Feedwater Pump Rooms. These large openings must remain open for pressure relief in the event of a steamline rupture. These openings were part of the original plant construction and the associated fire area boundarier were described as a 3-hour rated fire barriers in the Davis-Besse Fire Hazard Analysis Report (FHAR). The NRC han reviewed and accepted these fire barriers as documented in the Davis-Besse Fire Protection Safety Evaluation Report dated April 26, 1979 (Log No. 409). However, since the submittal of the previous exemption request, the NRC has issued Generic Letter 86-10, Implementation of Fire Protection Requirements, dated April 24, 1986 (Log No. 1983) which presents the NRC's response to various questions regarding fire protection. Specifically the response to Question 3.1.2 states that, "If a fire area boundary was described as a rated barrier in the 1977 Fire Hazard Analy-sis, and was evaluated and accepted in a published SER, the fire area boundary need not be reviewed as part of the re-analysis for compliance with Section III.G of Appendix R." Consequently, the ceilings of Fire Areas E and F need not be reviewed for compliance with III.0 of Appendix R with respect to these large pressure relief openings and, the previously requested exemption was withdrawn. In addition to the large pressure relief openings, there is a ventilation exhaust duct opening containing a fire damper in each ceiling of Fire Areas E and F. Subsequent to submitting the previously requested exemption, Toledo Edison found the dampers to be inoperable during a visual inspection and determined that significant modifications or replacement is required in order to return the dampers to an operable status. Toledo Edison has concluded that the replacement or modification of these dampers would not be cost-effective since the ceilings of these fire areas currently have large pressure relief openings. Engineering evaluations for the dampers in Fire Area E and F regarding the acceptability of this additional unrated opening from a fire protection standpoint has been completed. Additionally, Toledo Edison has verified that no auxiliary feedwater circuitry is located above the ventilation openings. These evaluations and a revision to the FHAR reflecting their results will be issued to the NRC by December 15, 1987. Further Response By December 15, 1987, Toledo Edison will issue the engineering evaluations justifying the ventilation exhaust ducts in ceilings of Fire Areas E and F as unrated openings and issue a corresponding revision to the FHAR. A-1 1

7 Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 Additional Question B - FHAR Change Notice 90 Regarding FitAR Change Notice 90, document any deviations from Regulatory Guide 1.52.

Response

The Davis-Besse Fire llazard Analysis Report (FIIAR), Table 4-1 addresses certain aspects of the Davis-Besse Fire Protection Program relative to the guidelines of Appendix A to BTP APCSB 9.5-1. Change Notice 90 affects Table 4-1 and states that the Containment Purge Exhaust System isolation features and cooling via convection heat transfer is sufficient to meet the intent of Regulatory Guide (RG) 1.52. This Change Notice has been incorporated into Revision 8 of the FIIAR issued in latter dated May 22, 1987 (Serial No. 1391). The compliance of the Containment Purge System with RG 1.52 is limited to the design of the air filtration charcoal absorbers in order to prevent the occurrence of a fire or mitigate the effects of a fire in the charcoal filter unit. RG 1.52, Section 3, paragraph K reads as follows: K. The design of the absorber section should consider possible iodine desorption and absorbent auto-ignition that may result from radioactivity-induced heat in the absorbent and an concomitant temperature rise. Acceptable designs include a low-flow air bleed system, cooling coils, water sprays for the absorber section, or other cooling mechanisms. Any cooling mechanism should satisfy the single-failure criterion. A low-flow or bleed system should satisfy the single-failure criterion for providing low-humidity (less than 70 percent relative humidity) cooling air flow. Paragraph K recognizes mechanical or other means for cooling as acceptable methods for reducing temperatures in order to maintain the charcoal below its auto-ignition point. In addition, paragraph K requires the selected system to satisfy the single failure criterion. The method relied upon for cooling the Containment Purge Exhaust System charcoal filter is passive. This method incorporates natural convection heat transfer and is not dependent on any mechanical system or component. Therefore, the system is not subject to any single failure that would impair its functions. B-1

Docket No. 50-346 License No. NPF-3 Serial No. 1361 The Containment Purge Exhaust System is normally not in operation and is manually operated as needed. The purge system is normally isolated form any air flow that would serve to induce possible iodine desorption and absorbant auto-ignition. Additional means are provided as indicated in the FRAR Change Notice to isolate the system automatically if it should be running and abnormal conditions such as smoke or elevated temperatures at the unit's discharge or radiation at the unit's inlet, are sensed. Further, the unit can he manually isolated if necessary. The Containment Purge Exhaust system features and operating modes preclude the development of elevated charcoal temperatures. Therefore, RG 1.52 Section 3. Paragraph K is satisfied without the need for additional fire suppression or forced cooling systems. Further Response Toledo Edison believes that no further response is necessary to resolve this question. B-2

C Dockrt No. 50-346 License No. NPF-3 Serial No. 1361 Additional Question C - FRAR Change Notice 93 Regarding FHAR Change Notice 93, confirm that the Control Room carpet is rated Class A in accordance with ASTM E84.

Response

Revision 7 of the Davis-Besse Fire Hazard Analysis Report (FIIAR) discusses the control room carpet rating was tested in accordance with ASTM E-84-68 Steiner Tunnel Test for flame spread. The control room carpet, however, has been replaced and its testing is discussed in FHAR Change Notice 93. This Change Notice has been incorporated in Revision 8 of the FHAR issued in letter dated May 22, 1987 (Serial No. 1391). The new control room carpet has been tested in accordance with ASTM E-648 and NFPA-258 (1976). The ASTM E-648 testing is the current industry standard for floor covering and is recognized by the National Fire Protec-tion Association. The ASTM E-648 testing of the new control room carpet yielded a Critical Radiant Flux (CRF) of greater than 1.00 watts /sq. cm. The NFPA-258 (1976) test yielded a specific optical density of 177 for the flaming test mode and 245 for the non-flaming test mode. Toledo Edison has reviewed the qualifications of the new control room carpeting. Paragraph 6-5.3.1 of the NFPA 101-1985, " Life Safety Code," specifies two classes of carpet with minimum CRF ratings of 0.22 and 0.45 watts /sq. cm. Additionally, the CRF range measured under ASTM E-648 begins at approximately 0.1 and ends near 1.1 watts /sq. cm. The testing of the new control carpet yielded a CRF of greater than 1.00 watts /sq.cm. Consequently, this carpet exceeds NFPA 101-1985, tested near the top of the CRF range and, in the opinion of Toledo Edison, satisfies the intent of Appendix A to BTP APCSB 9.5-1. Further Response Toledo Edison believes that no further response is necessary to resolve this question. C-1

Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 Additional Question D - FHAR Change Notice 100 Regarding FHAR Change Notice 100, please address how Technical Specifica-tion compliance would be maintained if the subject barriers were not inspected.

Response

Change Notice 100 of the Davis-Besse Fire Hazards Analysis Report (FHAR) justified that either side of the fire barrier between Room 102 and Room 210 (Barrie,- 102W/210E) would not be periodically inspected due to ALARA concerns. Additionally, one side of fire barriers between Rooms 206 and 210 (Barrier 206E/210W) and Rooms 205 and 206 (Barrier 205N/206E) is also inaccessible due to ALARA concerns. Portions of the other side of Barriers 206E/201W and 205N/206E are obstructed by a filter bank that is not readily movable. These obstructed portions of Barriers 206E/210W and 205N/206E would also not be inspected due to ALARA concerns. This Change Notice has been in :orporated in Revision 8 of the FHAR issued to the NRC in letter dated May 12. 1987 (Serial No. 1391). The current Davis-Desse Technical Specification requires fire barrier penetrations protecting safety-related areas to be visually inspected and verified as functional at least once per 18 months. Based on a review of plant drawings, there are no penetrations in Barriers 102W/210E or in the obstructed portion of Barriers 206E/210W and 205N/206E. Penetrations are located in portions of Barriers 206E/210W and 205N/206E that are not obstructed and these penetrations have been visually inspected and verified as fun (tional in late 1986. Consequently, Toledo Edison is in compliance with its Technical Specifications. .a Further Response Toledo Edison believes that no further response is necessary to resolve this question. D-1 I

D:ck2t No. 50-346 License No. NPF-3 Serial No. 1361 Additional Question E - CAR and FHAR Change Notices Document all outstanding Change Notices to the Davis-Besse Fire Hazard Analysis Report (FHAR) and Appendix R Compliance Assessment Report (CAR) as formal revisions.

Response

Revision 7 of the FHAR and Revision 1 of the CAR were issued on March 6, 1986. Since that time, numerous changes were identified to each report and documented as Change Notices in accordance with Toledo Edison procedures. Change notices to the FHAR and CAR are periodically issued in accordance with plant procedures to reflect plant modifications and fire protection program enhancements as part of normal plant operation. In order to support the NRC review, these Change Notices have been incorporated into the FHAR and CAR as formal revisions. Revision 8 of FHAR incorporates those Change Notices issued as of February 12, 1987 and was transmitted to the NRC in a letter dated May 22, 1987 (Serial No. 1391). Revision 2 of the CAR incorporates those Change Notices issued as of April 10, 1987, and was transmitted to the NRC in letter dated May 14, 1987 (Serial No. 1386). Further Response Toledo Edison believes that no further response is necessary to resolve this question. l I 4 E-1

(- ' Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 Additional Question F - Cable Ignitibility Address the ignitibility'of cables installed at Davis-Besse relative to the fire seal protected side temperature limits.

Response

Toledo Edison will ensure that the ignitibility of cables installed at Davis-Besse is such that a single fire would not ignite cables in a separate fire area due to heat transfer through a cable penetration fire seal. It is anticipated that Toledo Edison would obtain this assurance by comparing cable manufacturer data on ignibility to the protected-side temperature test results for cable penetration fire seals installed at Davis-Besse. This evaluation is scheduled to be completed prior to December 15, 1987. Further Response The evaluation regarding cable ignitibility relative to fire seal protected-side temperature limits will be completed by December 15, 1987. F-1

( Dockst No. 50-346 License No. NPF-3 Serial No. 1361 Additional Question G - Administrative Controls for Transient Combustibles Verify that transient combustibles are not against cable penetrations and that plant procedures would assure this is continued.

Response

In late 1986, Toledo Edison has completed a visual inspection of each penetration seal in fire barriers that separate redundant safe shutdown equipment required in the event of a fire. This inspection requires that the inspection teams, consisting of Quality Control, Fire Protection Engineering and craft personnel, be within approximately 3 feet of each side of the penetrations. Obstructions to these visual inspections such as cabinet or panel doors, or recessed ceiling panels were not sufficient to preclude the inspection of that side of the penetration. Any obst-ruction determined by the inspection team to prevent the inspection of one side of a penetration seal was documented and reviewed for acceptability by supervisory personnel. Any transient combustibles covering or against any inspected penetration would have been documented and removed. Toledo Edison has reviewed this documentation and determined that no penetration inaccessibility was due to transient combustibles. Moreover, based on interviews with certain inspecting personnel, no transient combustibles were identified against inspected penetrations. Additionally, Davis-Besse has administrative procedures to control com-bustibles and to conduct plant cleanliness inspections. Procedure AD 1810.01, " Control of Combustibles and Ignition Sources," addresses the storage and use of combustible material in order to control their placement and provides special guidelines for certain specific plant areas such as the Containment. Procedure AD 1835.00, " Plant Cleanliness Inspection Program," establishes responsibility and criteria for clean-liness inspections. The Fire Protection Coordinator is responsible for ensuring that frequent plant inspections are being conducted to identify and correct problems associated with fire loading of transient combustibles within the station. This procedure provides a checklist to guide the cleanliness inspections and assigns responsibilities and schedules for the inspections. More frequent inspections would be condacted during periods of high activity such as refueling outages, and special inspections would also be conducted when hazards are reported. In summary, the visual inspection has ensured no transient combustibles are against Technical Specification-related fire penetrations and that the plant administrative procedure would ensure that such transient combus-tibles are properly controlled. Conclusion Toledo Edison believes that no further response is necessary to resolve this question. G-1

a. Docket No. 50-346 License No.;NPF-3 Serial No. 1361 Additional question H - Conduit Seals Document the method Toledo Edison will use for internal conduit seals.

Response

Toledo Edison has visually inspected the internal seal of conduits penet-rating fire barriers that separate redundant safe shutdown components required in the event of a fire. Based on this inspection, Toledo Edison will: 1. Assess the adequacy of the installed internal conduit seals configurations and any identified degradation against qualified seal details establishing proper fire protection. 2. Repair those internal conduit seals that are not in accordance with the seal details or are unacceptably degraded; otherwise, justify their current installation. 3. Install internal conduit seals where required based on the physical configuration of the conduit, and the fire and negative pressure functions of the fire barrier. The Davis-Besse criteria for providing internal conduit seals is limited to conduits penetrating fire barriers that protect redundant safe shutdown equipment required in the event of a fire. In summary, conduits greater than 4 inches in diameter will be provided with a fire seal at the fire barrier equivalent to the fire rating of its associated fire barrier. Davis-Besse currently has no such conduits installed but this criteria would be applied to future installations involving such conduit. Conduits less than or equal to 3/4 inches in diameter will not be provided with a fire seal or smoke and hot gas seal unless the conduit is a spare (Refer-ence Question 9). Conduit less than or equal to 4 inches but greater than 3/4 inches in diameter will be: 1. Provided with a fire seal equivalent to the fire rating of the associated fire barrier on at least one side of the fire barrier, if l the ccnduit extends less than 5 feet from the barrier, or 2. Provided with a smoke and hot gas seal in order to protect sensitive electrical equipment based on the routing and termination point of the conduit and the negative pressure function of the fire barrier, if the conduit five feet or more from the fire barrier. This criteria considers junction boxes and regular conduit fittings to be an extension of the conduit. The criteria is discussed in detail in. H-1 t

6 Dockst No. 50-346 License No. NPF-3 Serial No. 1361 Toledo Edison will complete the aforementioned evaluations and any necessary physical modifications prior to the return to power operation from the sixth refueling outage. Further Response Toledo Edison believes that no further response is necessary to resolve this question. 4 l-H-2 l l. I I

O 'D2cket No. 50-346 License No. NPF-3 ~ Serial No. 1361 - ENCLOSURE 1 FIRE. PROTECTION EQUIPMENT INDICATIONS Annunciator Windows Window Description L431' Fire Water Storage Tank Level P431 Fire Water Turbine Building Pressure Low Q440 Fire Water Diesel Pump On Q441 Fire Water Diesel Pump System Trouble Q442 Fire Water Electric Pump On Q978 Unit Fire or Radiation Trouble T411 Fire Water Storage Tank Temperature Low Main Control Board Device Description LI-1051 Fire Water Storage Tank Level Indication PI-1044 Fire Water Turbine Building Pressure Low II-1052 Indication Light For Electric Fire Pump HIS-1054 Hand Indicating Switch For Fire Jockey Pump HIS-1042A Hand Indicating Switch For Diesel Fire Pump

/ Dock:t No. 50-346 License No. NPF-3 Serial No. 1361 ENCLOSURE 2 SIMPLIFIED DRAWINGS l l [ i

O Dock 2t No. 50-346 License No. NPF-3 Serial No. 1361 ENCLOSURE 4 I. Conduits larger than 4" in diameter No conduits larger than 4" in diameter penetrate Technical Specification Fire Barriers at Davis-Besse Unit 1. II. Conduits equal to or less than 3/4" in diameter These conduits need no seal, unless they are spare conduits analogous to pipe sleeves. No 3/4" conduit sleeves are expected to be found, but if they are, they will be sealed with a fire rated seal. All other 3/4" conduits are not credible paths for significant amounts of smoke. Reports prepared by other utilities show that in tests run per ASTM-E 119 criteria, smoke in small conduits condenses out over short distances. Calculations show that even if a differential pressure across the barrier of.25 in. wg. is postulated, the smoke flow through a three foot long 3/4" conduit would be less than 2 CFM. Smoke flow through conduits 10 feet long is less that 1 CFM. When compared to the allowable leak rates through closed smoke dampers per UL Standard 555 S, any smoke flow through 3/4" conduits is considered negligible. III. Conduits less than or equal to 4" and greater than 3/4" in diameter which extend less than 5" on at least one side of the barrier. Where possible, a fire seal shall be installed at the barrier. If it is not possible to install the seal at the barrier, the side (s) extending less than 5" from the barrier shall be sealed with a fire seal remote to the barrier. If the other side extends beyond 5' from the barrier, the sealing requirements for that side shall be in accordance with Items IV, V, VI or VII. IV. Conduits less than or equal to 4" and greater than 3/4" in diameter which terminate at sensitive electrical equipment on the side under review. A. Barrier is also a negative pressure barrier and conduit being evaluated is on negative pressure side of barrier. These conduits shall be sealed with a noncombustible material to prevent the flow of smoke and hot gases. The seal shall be installed at the barrier if possible, if not, it shall be installed at the first access point away form the barrier. B. Barrier is not a negative pressure barrier, or conduit is on positive pressure side of negative pressure boundary. I

F. Docket No. 50-346 License No. NPF-3 Serial No. 1361 1. Conduit is equal to or greater than 3" in diameter. These conduits shall be sealed per IV A. 2. Conduit is less than 3" in diameter. If the conduit is continuous for at least 10 feet before terminating, no seal is required; otherwise, the conduit shall be sealed per IV A. V. Conduits less than or equal to 4" and greater than 3/4" in diameter which branch to several runs on the side under review i A. Barrier is also a negative pressure barrier and conduit being evaluated is on negative pressure side of barrier. Unless all the branch conduits can be determined to be configuration VI routings, the penetrating " Header" conduit shall be sealed with a noncombustible material to prevent the flow of smoke and hot gases. The seal shall be installed at the barrier if possible, if not, it shall be sealed at the first access point away form the barrier. B. Barrier is not a negative pressure barrier, or conduit is on positive pressure side of negative pressure boundary. 1. Conduit is equal to or greater than 3" in diameter. Theses conduits shall be sealed per V A. 2. Conduit is less than 3" in diameter If all the header and branch conduit combinations are continuous for at least 10 feet, no seal is required; otherwise, the conduit shall be sealed per V A. VI. Conduits less than or equal to 4" and greater than 3/4 in diameter which are continuous on the side under review (e.g.: conduit penetrates barrier, is routed through room, and exits room through another or the same barrier without branching into different conduits.) A. Barrier is also a negative pressure barrier and conduit is on negative pressure side of barrier. 1. Conduit exits room and penetrates through the same or another fire barrier. These conduits do not require seals. 2

r o o Docket No.-50-346 License No. NPF-3 Serial No. 1361 2. Conduit exits room and penetrates through a barrier which is not a fire barrier. The routing of these conduits shall be determined past the non-fire barrier exit and they shall be sealed per configurations IIV, IV, V, VI or VII as applicable. 'B. Barrier is not a negative pressure barrier or conduit is on positive pressures side of negative pressure barrier. 1. Conduit is equal to or greater than 3" in diameter. These conduits shall be sealed per VI A. 2. Conduit is less than 3 in diameter. If the conduit is continuous for at least 10 feet before it exits the room, it requires no seal regardless of whether it exits through a fire or non-fire barrier; otherwise, the conduit must be sealed per VI A. VII. Conduits less than or equal to 4" and greater than 3/4" in diameter which do not penetrate the barrier but are embedded in the barrier The sealing requirements for the non-embedded run shall be per configurations III, IV, V or VI. The sealing requirements for the embedded run shall be as follows: A. Conduit also crosses a negative pressure boundary and conduit under review is on negative pressure side. The routing of these conduits shall be determined and they shall be sealed per configurations III, IV, V or VI. i B. Conduit does not cross a negative pressure boundary or is I on the positive pressure side of the negative pressure boundary crossed. 1. Conduit is greater than or equal to 3" in diameter. l l The conduit shall be sealed per VII B 1. t l 1 ? 3

o Dockst No. 50-346-l License No. NPF-3 Serial No. 1361 2. Conduit is less than 3" in diameter If the embedded length of conduit and any non-embedded run can be determined to be at least 10 feet, no seal is required; otherwise, the conduit must be sealed per VII Bl. C. Embedded conduit routing :annot be determined. No seal is required. Conduits that cannot be tracked are assumed to be non-essential routed conduits. As such they do not provide a path for smoke to potentially affect sensitive electrical equipment. Such conduits are addressed by an exemption request in Toledo Edison letter dated March 6, 1986 (Serial No. 1255), as amended in letter dated January 12, 1987 (Serial No. 1327). 4 1

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• Controlled per AD 1834.02 4

END ATTACHMENT 7 ) -n. a._ n

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