ML20234F224

Forwards Minutes of 871029-30 Meetings Re Status of Fire Protection Program,Responses to NRC Request for Addl Info, Rev 3 to App R Compliance Assessment Rept & Rev 9 to Final Hazard Analysis Rept

ML20234F224
Person / Time
Site:	Davis Besse
Issue date:	01/06/1988
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20234F227	List: ML20234F224 ML20234F250
References
1456, TAC-60994, TAC-60995, TAC-61745, NUDOCS 8801110386
Download: ML20234F224 (13)

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TOLEDO i EDISON Docket No. 50-346 DONAU) C. SHELTON voor *s-mm, License No. NPF-3 Serial No. 1456 January 6, 1988 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 a letter dated May 27, 1987 (Serial No. 1361), the Toledo Edison Company provided additional information, as requested in the subject transmittals. A meeting was held on October 29 and 30 with members of NRR and Region III to discuss the status of the Davis-Besse Fire Protection Program, previously aubmitted exemption requests and Technical Specification revision. The minutes to the October 29 and 30 meeting are provided in-Attachment 1.

As noted in the meeting minutes the submittal date for this transmittal was changed from December 15, 1987 to January 6,.1988. Additional discussions were held with the NRC on December ;28, 1987 and January 5 .

,1988 which established that the responses to Questions 4, 5, 35, 41, 42, 47 and A will be by January 6, 1988; Questions 24 and F by January 31, 1988; and Questions 1, 19, 20 and 29 by March 15, 1988.

Additional discussions were held with the NRC regarding 'the propose'd" Fire Protection Technical Specifications revision. It was agreed that the proposed revision would be resubmitted and that the portion regarding the Fire Barriers would be approved by the NRC no later than January 31, 1988. This schedule change is also reflected in the attached meeting minutes.

It should be noted that the NRC letter dated November 7, 1987 (Log No.

2429) stated that Toledo Edison comnitted to include in this submittal a discussion of the post-fire safety shutdown repairs and a schedule to complete the NFPA Code Conformance Review. Although Toledo Edison has made these commitments, it did not agree to provide that discussion or schedule in this submittal. These commitments are related-to other g_

commitments scheduled to be completed by March 15, 1988. At that time, gg V Toledo Edison will provide a schedule to complete the discussion of the U post-fire safety shutdown repairs and the NFPA Code Conformance Review. ' I\

This matter has been discussed with the'NRC Project Manager.

THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43052 8801110386 880106 ,

PDR ADOCK 05000346 l

F PDR .

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l Docket No. 50-346 License No. NPF-3 Serial No.1456 Page 2 l

Attachment 2 contains Toledo Edison's response to questions requiring 1 additional information. Should you have any further questions please l contact Mr. R. W. Schrauder at (419) 249-2366. j Very tr ours, s'

FS:bam Attachments l cc: A. B. Davis, Regional Administrator DB-1 Resident Inspector i D. Kubicki - NRR i

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Docket No. 50-346 Licence No. NPF-3 Serial No. 1456 '

Page 1 1

October 29 - 30 Meeting Minutes  :

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Docket No. 50-346 License No. NPF-3 Serial No. 1456 Attachment 1 Page 2 Meeting Minutes Date: .0ctober 29-30, 1987 Location: NRR Office, Phillips Euilding, Bethesda, MD

Subject:

1. Status of Davis-Besse Fire Protection Program <

2. Outstanding Fire Protection Exemption Requests

3. Outstanding Technical Specification Amendment Request

4. NRR Request for Additional Information Attendees: NRC J. Ulie - Region III D. Kubicki - NRR A. DeAgazio - NRR TED j D. Haiman F. Sondgeroth i

L. Young M. Murtha i M. Lalor J. Michaelis l R. Schrauder J. Strausser The subject meeting was requested by Toledo Edison (TED) to discuss the status of the Davis-Besse fire protection program and resolve outstanding NRC fire protection concerns.

TED stated that all requirements necessary to comply with 10CFR50, Appendix R, will be met prior to commencement of power operations following the sixth refueling outage.

Mr. Kubicki asked what kind of operational occurrences would be reportable under 10CFR 50.72 and 10CFR 50.73. Toledo Edison responded stating any deviation would be documented as a Potential Condition Adverse to Quality (PCAQ). The PCAQ system is currently in place and ensures the necessary deportability reviews. The PCAQ reviews are performed on a case-by-case basis.

Mr. Kubicki stated that tne questions related to the Fire Hazards Analysis l Report (FRAR) and Appendix R- Compliance Assessment Report (CAR) that are  !

not remaining open and did not require clarification per this meeting are j acceptable.

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Docket No. 50-346 )

License No. NPF-3 J Serial No. 1456 Attachmtnt 1  !

Page 3 Mr. Kubicki noted that the current fire protection safe shutdown procedures specify manual operator actions to achieve hot standby. These operator actions are considered repairs and are not acceptable to the NRC. Toledo Edison stated that the specific repairs are interim measures specified in the procedures until Davis-Besse is brought into compliance with Appendix R.

These repairs will be eliminated from the procedure following the implementation of certain plant modifications or exemptions will be requested.

The following actions and schedules were committed to by Toledo Edison:

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1. Queetion 14 regards the ventilation of smoke to minimize damage to sensitive electrical equipment. The NRC accepted the Toledo Edison response and closed this question. However, to complete the fire

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protection program, Toledo Edison should document procedural j guidance to appropriately vent smoke and minimize the impact of i damage on sensitive electrical equipment.

2. Question 15 regards the testing of fire dampers under air flow conditions. The NRC accepted the Toledo Edison response and closed this question. However. Toledo Edison should summarize the certification performed by Ruskin. .

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3. Question 45 regards the design and installation of isolation switches .and redundant fuses and their conformance with Generic Letter 81-12. The NRC accepted the Toledo Edison response that certain deviations from NRC guidance may be acceptable and closed i this question. However, Toledo Edison should document any deviations from Generic Letter 81-12.

4. The date for the December 15, 1987 submittal was changed. Additional discussions were held with the NRC on December 28, 1987 and January 5,  ;

1988 which established that the responses to Questions 4, 5, 35, 41, 42, 47 and A will be by January 6, 1988; Questions 24 and F by January 31, 1988; and Questions 1, 19, 20 and 29 by March 15, 1988.

These schedule dates were selected to support the NRC Staff Reviewer availability and the Toledo Edison workload.

5. In the Technical Specifications action statements, refer to back-up hose lines when a fire station is inoperable.

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6. Additional discussions were held with the'NRC regarding the proposed i fire protection Technical Specification revisions. It was agreed that the proposed revision would be resubmitted and that portion regarding the Fire barriers would be approved or rejected by the NRC no later than January 31, 1988.

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Docket No. 50-346 License No. NPF-3 Serial No. 1456 Page 4

7. The proposed Technical Specification Amendment should be revised to allow observation of local fire panels in the event of a loss of Control Room indication.

8. Revise Fire Protection Water Supply Technical Specification to {

clarify the applicability of Technical Specifications 3.0.3 and 3.0.4.

9. Perform a NFPA code conformance review. The schedule for any modifications necessary, as a result of the review, will be determined after completion of the review. This review will include those NFPA codes addressed by Appendix A to APCSB BTP-9.5.1 as well as other codes specified by NRC fire protection guidelines applicable to Davis-Besse.

The following actions and schedules were committed to by the NRC. l

1. The NRC will issue or reject the proposed Technical Specification )

Amendment regarding the Fire Barriers by January 31, 1988. 1

2. The NRC will process all pending fire protection exemption requests by January 31, 1988.

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Docket No. 50-346 License No. NPF-3 Serial No. 1456 Attachment 2 Page 1.

Additional Information to NRC Questions i

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Docket No. 50-346 .)

License No. NPF-3 j Serial No. 1456 Attachment 2 Page 2

-Ouestion No. 4 - Hand Held Lights Justify the use of hand-held lights for accomplishing safe shutdown.

Such use is not consistent with staff guidance or past precedent except j for access and egress routes in outdoor areas. ]

Response

The use of hand held lights is an interim measure to provide emergency light until such time as permanent eight-hour emergency lighting assemblies _

are installed. . The permanent emergency lighting assemblies are scheduled to be installed prior to power ascension following the sixth refueling l outage. {

l Ae described in Section 6.2.3 of the Appendix R Compliance Assessment Report, until implementation of the permanent eight hour battery powered emergency lights Toledo Edison will utilize hand held lights for access j and egress routes in outside plant areas. The discussion regarding the j area of hand held lights was incorporated in Revision 2 to the Appendix R l Compliance Assessment Report issued in Toledo Edison letter dated May 14, l 1987 (Serial No. 1386).

Further Response Toledo Edison oelieves that no further response is necessary to resolve this question.

Docket No. 50-346 License No. NPF-3 Serial No. 1456 Page 3 Ouestion No. 5 - Deviation from BTP Appendir A Regarding (FHAR), 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 clearly specify where deviations from our guidelines exist. Appropriate justification for such deviations should be provided in the FHAR.

Response

Table 4-1 of the Davis-Besse Fire Hazards Analysis Report (FHAR) has been revised to eliminate disparities concerning compliance with BTP APCSB 9.5-1. The categorization " Position (Comply)" has been oldminated, leaving " Comply" and " Deviate" as the only compliance categories. The revised FHAR Table 4-1 is provided in Attachment 4.

Further Response Toledo Edison believes that no further response is necessary to resolve this question.

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Docket No. 50-346 License No. NPF-3 Serial No. 1456 )

Attachment 2 Page 4 Ouestion 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 174? (Reference Notes:

2, 3, 4, 8, 9, 11, 18, 19, 20, 21, 22, 23, 26, 40 and 41).

Response

Safe shutdown circuits are located in Room 124 and other rooms within Fire Area A. Within Fire Area A, three fire dampers are being installed. The installation of these dampers will make all Fire Area A boundaries fire rated for three hours. The Davis-Besse Appendix R Fire Hazards Analysis Report has been revised to more clearly state the fire rating of the Fire Area A boundaries. This revision is provided in Attachment 4.

Further Response Toledo Edison believes that no further response is necessary to resolve this question.

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R Docket No. 50-346 License'No. NPF-3 Serial No. 1456 Page 5 Question No. 41 - Multiple High Impedance Faults Regarding (CAR) Page 4. AB-15, provide details describing the installation of ground-fault protection to preclude multiple high impedance faults.

Response

In letter dated May 27,1987 (Serial 1361), Toledo Edison stated that Lanual tripping of selected buses rather than ground-fault protection would be appropriate to preclude multiple high impedance faults.

However, Toledo Edison intends to minimize the number of manual operator actions, where practical, in order to simplify the associated procedure and to speed the operator's response to a serious fire.

Toledo Edison has begun an evaluation of the time available to implement manual operator actions required to achieve safe shutdown in the event of a fire (Reference Question 1 in Toledo Edison letter dated May 27, 1987).

The results of this evaluation will be used to determine the need for ground-fault protection. At that time, and as part of the response to Question 1, the CAR will be revised to indicate the means used to preclude multiple high impedance faults and, if utilized, to describe the instal-lation of ground-fault protection.

Further Response Toledo Edison believes that no additional response is necessary to resolve this question.

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Docket No. 50-346 License No. NPF-3 Serial No. 1456 Attachment 2 Page 6 Ouestion No. 42 - Off-site Supply of Diesel Generator Fuel Oil Regarding (CAR) Page 4.BN-4, si'fficient justification has not been provided to accept the use of 'a n offsite fuel oil' supplier to compensate for the loss of the redundant fuel oil transfer pumps. The licensee should propose protection to aesure that one fuel oil transfer pump train remains free of fire damage.

Response

The CAR has been revised to include a commitment to provide the capability of an onsite source of fuel oil to compensate for the loss of the redundant fuel oil transfer pumps (Reference Attachment 3). The onsite capability will be provided by adding a portable fuel oil transfer pump and temporary connection to transfer fuel oil from the main fuel oil tank to the day tank. The necessary equipment will be connected utilizing a repair procedure.

Further Response Toledo Edison believes that no further response is necessary to resolve this question.

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Docket No. 50-346 License No. NPF-3 Serial No. 1456 Attachment 2 Page 7 Ouestion No. 47 - RCS Cold Leg Temperature Indication Regarding (CAR) Page 4.DD-56, the lack of RCS Loop I cold leg temperature indications part of post-fire alternate shutdown instrumentation represents 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, j Response l The CAR has been revised on pages 4.DD-55 and 56 (Refetence Attachment 3) to reflect the use of direct readings of RCS cold leg temperature indications as described in TED letter dated May 27, 1987 (Serial No.

1361).

Further Response Toledo Edison believes no further response is necessary to resolve this question.

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Docket No. 50-346 License No. NPF-3 Serial No. 1456 i l Page 8 Additional Question A - Amended Exemption Request Document the evaluation regarding the ventilation ducts in the ceilir.g of the Auxiliary Feedwater Pump Rooms.

Response

Compliance Matrix to Appendix A presented in Table 4-1 of the Davis-Besse Fire llazards Analysis Report and the fire hazards analysis for Fire Areas E and F have been revised to document Davis-Besse's evaluation regarding the ventilation openings in the ceiling of the Auxiliary Feedwater Pump Rooms (Reference Attachment 4).

Further Response Toledo Edison feels that no further response is necessary to resolve this question.  ;

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