ML20235Q633

Forwards Rev to Bases of Tech Spec 3/4.7.10 Re Fire Barriers,Per Discussion W/Kubicki & De Agazio.Rev Clarifies That Surveillance Requirement to Verify Each Door Is Closed at Least Once Per 24 Hr Not Applicable to Elevator Doors

ML20235Q633
Person / Time
Site:	Davis Besse
Issue date:	02/16/1989
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1596, NUDOCS 8903020708
Download: ML20235Q633 (10)

Text

-

\

l

' 1 1

TOLEDO

%e EDISON l Acenwyeac %  !

j DONALD C. SHELTON I v e maaw ^

(*

• 2"3

• Docket Number 50-346 License Number NPF-3 1

Serial fiumber 1596 l l

February 16, 1989 l l

United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Subj ec t : Revision tt Bases of Technical Specification 3/4.7.10, Fire Barriers l 1

Gentlemen:

Enclosed is a revision to the Bases of the Davis-Besse Nuclear Power Station, Unit Number 1 Technical Specification 3/4.7.10, Fire Barriers. This revision i clarifies that the surveillance r2quirement to verify each fire door is closed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not applicable to fire-rated elevator doors.

The justification for this Bases revision was discussed with Mr. D. J.

Kubicki, NRC Staf f Iteviewer, and Mr. A. V. DeAgazio, Davis-Besse NRC Senior Project Manager.

The enclosure includes 1) the associated Safety Evaluation (Attachment 1),

2) a copy of the existing affected pages of the Technical Specifications annotated to reflect the revision (Attachment 2), and 3) the typed affected pages of the Technical Specifications reflecting the revision (Attachment 3).

The Bases revision requested herein does not require the submittal of a license amendment application since the Bases are not part of the Technical Specifications in accordance with 10CFR50.36(a). Toledo Edison requests that the NRC issue this Bases revision by March 31, 1989.

Very tru yours, s

lh., - ^A VNQ MAL /dlm 8903020708 390236 PDR p

siDOCF 00000336 PDL Enclosure cc: P. M. Byron, DB-1 NRC Resident Inspector b A. B. Davis, Regional Administrator, NRC Region III 1 T. V. Vambach, DB-1 NRC Senior Project Manager i THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO OHIO 43652

I Attachment 1 l Safety Evaluation I

l

. Docket Numbar 50-346 Licensa Number NPF-3 Serial Number 1596 Attachment 1 Page 1 SAFETY EVALUATION FOR REVISION TO BASES OF TECHNICAL SPECIFICATION-3/4.7.10 DESCRIPTION Surveillance requirement 4.7.10.b requires that each fire door and associated hardware be visually inspected at least once per 18 months. Surveillance requirement 4.7.10.d requires " Verifying at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> each fire door (i) that is unlocked is closed or (ii) that is equipped with an automatic i

hold open and release mechanism is free from obstructions." Surveillance

requirement 4.7.10.e requires " Verifying bt least once per 7 days each locked fire door is closed and locked."

l This Technical Specification was issued by License Amendment 106.and was requested by Toledo Edison letter dated December 7, 1987 (Serial Number 1446).

The Safety Evaluation for this Technical Specification contained in Serial 1446 states:

...Those systems required to achieve and maintain safe shutdown conditions in post-fire conditions, rather than nuclear safety-related equipment, have been ider<tified and evaluated for its availability in the event of a fire as documented in the Davis-Besse Appendix R Compliance Assessment Report (CAR). That equipment necessary to achieve and maintain safe shutdown i conditions in post-fire conditions is termed in the proposed l Technical Specification revision as safe shutdown equipment required in the event of a fire. The fire barriers for each fire area identified in the CAR are addressed by the proposed Technical Specification revision since these barriers separate redur. dant safe shutdown equipment."

Those fire barriers that separate portions of redundant safe shutdown systems required in the event of a fire are addressed by the FHAR and CAR and, in certain cases, contain fire-rated elevator doors. Since these . fire-rated elevator doors separate portions of redundant safe shutdown systems required in the event of a fire, they are addressed by the surveillance requirements of Technical Specification 4.7.10.b and 4.7.10.d.

The proposed revision to the Bases of Technical Specification 3/4.7.10 would clarify that the 24-hour surveillance requirement for doors (TS 4.7.10.d) would not apply to elevator doors. Surveillance requirement 4.7.10.e does not apply to elevator doors since the elevator doors at Davis-Besse are not locked and do not restrict personnel access to the elevators. The 18 month surveillance requirement for doors (TS 4.7.10.b) would continue to apply to elevator doors. The proposed Bases revision is an administrative change which involves no physical modifications.

l l

l

'. Docket Numbar 50-346 License Number NPF-3 Serial Number 1596 Aitachment 1 Page 2 SYSTEMS AND COMPONENTS AFFECTED:

System Number 013-14, Fire Doors - The proposed Bases revision affects fire-rated elevator doors that are addressed by Technical Specification 4.7.10.b and 4.7.10.d and are part of the fire-rated valls identified in the Davis-Berse Appendix R Compliance Assessn.ent Report.

DOCUMENTS AFFECTED:

USAR Section 9.5.1 Technical Specification Bases 3/4.7.10 DB-FP-03026 SAFETY FUNCTION OF SYSTEMS AND COMPONENTS AFFECTED:

l Operability of the fire-rated elevator doors as part of fire rated boundary ensures that fires vill be confined or adequately retarded from spreading to ,

cdjacent fire areas or to portions of redundant safe shutdown syste.as required l in the event of a fire within the fire area. This design feature minimizes the possibility of a single fire rapidly involving several fire areas of the facility prior to detection and extinguishment. Fire-rated elevator doors are not nuclear safety-related but they are important to safe shutdown.

EFFECTS ON SAFETY:

The proposed revision to the Bases vould clarify that the 24-hour surveillance i requirement for doors (TS 4.7.10.d) would not apply to elevator doors. 1 I

The purpose of the fire barrier is to minimize the possibility of a single  !

fire rapidly involving several fire areas of the facility prior to detection and extinguishment. The purpose of the 24-hour surveillance requirement is to ensure that the fire door is closed in order to confine or adequately retard the spread of fire to adjacent fire areas.

The purpose of the 18-month surveillance requirement is to ensure that the visually observed condition of the fire door is the same as the as-designed condition. The as-designed condition of each fire barrier is based on a tested configuration analyzed to withstand the fire hazards associated with the fire area. The 18-month inspection is a visual inspection of each fire door to ensure that it closes completely and review of the elevator certification to ensure it is current. The annual elevator door certification required by the State of Ohio includes a visual inspection of the mechanical safety device that prevents the opening of the elevator door without the j presence of the elevator car, unless intentionally overridden by a key.

1 With one fire-rated elevator door open, a single fire vould not spread from i one area to another fire area containing redundant safe shutdown systems required in the event of a fire. This is because 1) the elevator shafts do j not contain any safe shutdown circuits required in the event of a fire, and 2) with one fire-rated elevator door open, a fire vould not spread through the elevator shaft and through another fire-rated elevator door to reach another fire area. The Davis-Besse elevator doors are fire-rated for 1-1/2 hours.

The higher level of elevator doors are separated from direct fire exposure

. Docket Numbar 50-346 License Numbar NPF-3

, S9 rial Number 1596 Attachment 1 Page 3 caused by any fire hazards on the lover level. Even assuming one fire-rated elevator door open, the other fire-rated elevator doors within the elevator shaft in combination with the distance between elevator doors is sufficient to preclude the spread of a fire from one fire area to another fire area containing redundant safe shutdown systems required in the event of a fire.

The assumption that no more than one fire-rated elevator door would be open concurrently with a single fire is reasonable. The elevator doors are held closed mechanically. The elevator doors open due to the presence of the elevator car or by the use of a key to override the mechanical safety device.

The mechanical safety features of these fire rated elevator doors are addressed by an annual elevator door certification required by the State of Ohio. Therefore, it is unlikely that the mechanical safety features of two fire-rated elevator doors would simultaneously fail or be overridden ,

concurrent with a single fire. The elevator safety features are such that if I any shaft door was open the elevator could not move and any door impairment would quickly be repaired. In addition, if an elevator door is open, a fire watch would be established in accordance with Technical Specification 3.7.10.a.

Thus, the 24-hour surveillance requirement for fire doors should not apply to

, fire-rated elevator doors since a fire vould not spread from one fire area to another fire area containing redundant safe shutdown systems required in the event of a fire even with one elevator door open. The 18-month surveillance requirement alone is adequate to verify the operability of fire-rated elevator doors.

The proposed Bases revision is en administrative change which does not change the safe shutdown evaluation as described in the USAR, FHAR and CARP.

UNREVIEVED SAFETY OUESTION CONCLUSIONS

1. The proposed action would not increase the probability of an accident previously evaluated in the MAR because the proposed Basis revision is an administrative change which does not change any accident previously evaluated in the USAR, FHAR and CARP.

2. The proposed action vould not increase the consequences of an accident previously evaluated in the USAR because the proposed Basis revision is an administrative change which does not change any accident previously evaluated in the USAR, FHAR and CARP.

3. The proposed action vould not increase the probability of a malfunction of equipment important to safety because the proposed Basis revision is an administrative change which does not introduce any malfunction different from that evaluated in the USAR, PHAR and CARP.

4. The proposed action vould not increase the consequences of a malfunction of equipment important to safety because the proposed Basis is an administrative change which does not introduce any malfunction different from that evaluated in the USAR, FHAR and CARP.

'. Docket Number 50-346 License Number NPF-3

. Serial Number 1596 Attachment 1 Page 4

5. The proposed action vould not create the possibility for an accident of a different type than any evaluated previously in the USAR because the proposed Basis revision is an administrative change which does not introduce any accident that has not been evaluated in the USAR, FHAR and CARP.

6. The proposed action would not create the possibility for a malfunction of equipment of a different type than any evaluated previously in the USAR because the proposed Basis revision is an administrative change which does not introduce any malfunction that hos not been evaluated previously in the USAR, FHAR and CARP.

7. The proposed action would not reduce the margin of safety as defined in the basis for any Technical Specification because the proposed Basis revision is an administrative change which does not reduce the operability requirements for fire rated barriers.

CONCLUSION Based on the above evaluation, it is determined that the proposed Basis revision does not involve an unreviewed safety evaluation.

l

Docket Number 50-346 License Number NIF-3

. Serial Number 1596 Attachment 2 Page 1 Attachment 2 Annotated Proposed Bases Revision

Docket Number 50-346 License Number NPF-3 Serial Number 1596 PLANT SYSTEMS Attachment 2 Page 2 BASES 3/4.7.8 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium. This limitation will ensure that leakage from by product, source, and special nuclear material souces will not exceed allowable intake values.

_3/4.7.9 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the fire suppreseien systems ensures that adequate fire suppression capability is available to confine and extinguish fires occuring in any portion ef the facility where safety related equipment is located. The fire suppression system consists of the water system, spray and/or sprinklers, and fire hose stations. The collective capability of the fire suppression systems is adequate to minimize potential damage to safety related equipment and is a maior element in the facility fire protection program.

In the event that portions of the fire suppression systems are inoper-able, alternate backup fire fighting equipment is required to be made available in the affected areas until the inoperable equipment is restored to service.

In the event the fire suppression water system becomes inoperable, immedi-are correctiv6 measures eust be taken since this system provides the major fire suppression capability of the plant. The requirement for a twenty-four bour report to the Commission provides for prompt evaluation of the acceptability os the corrective measures to provide adequate fire suppres-sien espability for the continued protection of the nuclear plant.

3/4.7.10 FIRE BARRIERS The OPERABILITY of the fire barrier ensures that fires will be confined or adequately retarded from spreading to adjacent fire aress or to portions of redundant safe shutdown systems required in the event of a fire within the fire area. This design feature minimizes the possibility of a single fire rapidly involving several fire areas of the facility prior to detection and extinguishment. The fire barriers are passive elements in the facility fire protection program.

Fire barriers, including cable penetration barriers, fire doors and dampers, are considered OPERABLE when the visually observed ~ condition is the same as the as-designed condition. The as-designed condition of each fire barrier is based on a tested configuration or a configuration analyzed to withstand the fire hazards associated with the fire area.

I L. St-hco: su r va llune t r e yu n in c o r a v e C nf hc due a r c c k W ci c' "

twt tr W ] 1C 4

• r , r a 4 w ,{ cl,g a gc g pq g %ince ,Wnih c> n e c I v v aile J LC id C f n ) 't k ' ' C' wcuid on op re c t/

n ,r3 c c o t 4 i,1 a r e g i c a ,ic ( he et f mc oret Cent m m (j ufL GN F dta n squemt r q a m q m ., % i t e ,j p 4 o ,.E DAVIS-BESSE. UNIT 1 3 3/4 7-6 Amendment No./,106

, Docket Number 50-346

~

Licensa Numbar NPF-3 "

, Serial Number 1596 Attachment 3

! Page 1 1

l l

Attachment 3 Typed Proposed Bases Revision l

l l

l

, Docket Number 50-346

' License Number NPF-3 Serial Number 1596 Attachment 3 Page 2 PLANT SYSTEMS BASES 3/4.7.8 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium.

This limitation vill ensure that leakage from by product, source, and special nuclear material sources vill not exceed allowable intake values.

3/4.i.9 FIRE SUPPRESSION SYSTEMS

\ The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related equipment is located. The fire suppression system consists of the water system, spray and/or sprinklers, and fire hose stations. The collective capability of the fire suppression systems is adequate to minimize potential damage to safety related equipment and is a major eler.ent in the facility fire protection program.

In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is required to be made available in the affected areas until the inoperable equipment is restored to service.

In the event the fire suppression water system becomes inoperable, immediate corrective measures must be taken since this system provides the major fire suppression capability of the plant. The requirement for a twenty- four hour report to the Commission provides for prompt evaluation of the acceptability of the corrective measures to provide adequate fire suppression capability for the continued protection of the nuclear plant.

3/4.7.10 FIRE BARRIERS The OPERABILITY of the fire barrier ensures that fires vill be confined or adequately retarded from spreading to adjacent fire areas or to portions of redundant safe shutdown systems required in the event of a fire within the fire area. This design feature minimizes the possibility of a single fire rapidly involving several fire areas of the facility prior to detection and extinguishment. The fire barriers are passive elements in the facility fire protection program.

Fire barriers, including cable penetration barriers, fire doors and dampers, are considered OPERABLE when the visually observed condition is the same as the as-designed condition. The as-designed condition of each fire barrier is based on a. tested configuration or a configuration analyzed to withstand the ,

fire hazards associated with the fire area. l The 24-hour surveillance requirement to verify fire doors are closed does not apply to fire-rated elevator doors since, with one elevator door open, a fire vould not spread from one fire area to another fire area containing safe shutdown systems required in the event of a fire.

DAVIS-BESSE, UNIT 1 B 3/4 7-6 Amendment No. 9, 106

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _