ML20236D265

Forwards Info Re Time & Manpower Evaluations to Satisfy 10CFR50,App R Fire Protection Requirements.Remaining Evaluations Involve Manual Operator Actions Associated W/Low & High Pressure Interfaces

ML20236D265
Person / Time
Site:	Davis Besse
Issue date:	03/15/1989
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1642, TAC-60994, TAC-60995, TAC-61745, NUDOCS 8903230030
Download: ML20236D265 (14)

Text

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TOLEDO EDISON A Centeror Energy Company March 15, 1989 DONALD C. SHELTON Vce P:esident -huciett Docket Number 50-346 i

License Number NPF-3 Serial Number 1642 I

United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 ,

l Subj ect Fire Protection - Manual Operator Actions (TAC Numbers 60994, 60995 and 61745)

Gentlemen:

In a telephone conversation on February 23, 1989, Toledo Edison committed to submit the results of the remaining time and manpower evaluations by March 15, 1989. These remaining evaluations involve six manual operator actions associated with the high-low pressure interfaces discussed in Toledo Edison letter dated May 23, 1988 (Serial Number 1497) and those associated with the service water system and certain ventilation systems as discussed in Toledo Edison letter dated June 6, 1988 (Serial Number 1535).

These evaluations have been completed and the results are summarized in i Attachment 1 to this letter. Four of the six manual operator actions were  !

determined to satisfy Nuclear Regulatory Commission (NRC) acceptance criteria J provided to Toledo Edison in a meeting on February 17-18, 1987. One manual .

operator action was determined not to satisfy the NRC acceptance criteria but J is considered by. Toledo Edison to be in conformance with 10CFR50, Appendix R since that action vould be completed well before an unrecoverable plant condition would occur.

i' l The remaining manual operator action was determined not to be required in l order to satisfy 10CFR50, Appendix R. The manual operator action for a fire in Fire Area T to establish temporary ventilation in the CCW Pump Room is no

$o longer considered necessary since the CCW Pumps would not overheat despite the 1

$Q@ fire and postulated loss of the CCW Pump Room Ventilation. . Toledo Edison had l l Mo also proposed to use temporary ventilation as an alternative capability rather '

$$ than provide fire protection in accordance with 10CFR50, Appendix R, Section

• O III.G.2 for circuits associated with the CCW Pump Room Ventilation located in ox Fire Area U. Therefore, in letter dated January 12,.1987 (Serial Number

$o 1327), Toledo Edison requested an exemption from 10CFR50, Appendix R in' order

@@ to obviate the need to' install fixed fire suppression in Fire Area U.

g Additionally, in letter dated August 9, 1988 (Serial Number 1558), Toledo [g 15 N g THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 Di

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Docket Numbar 50-346 l Lic~ense Number NPF-3' '

Serial Number 1642 Page 2 Edison proposed to install a fire wrap of circuits for the CCV Pump Room Fan and Louvers in order to eliminate a post-fire repair necessary to establish the temporary ventilation. However, the evaluation has determined that the CCV Pumps vould remain operable despite the loss of the CCW Pump Room Fans and Louvers, and temporary ventilation is no longer considered necessary. Toledo Edison, therefore, withdraws the exemption for Fire Are. O and does not intend to install'the fire wrap since temporary ventilation is not required to satisfy 10CFR50, Appendix R.

If there are any questions regarding this matter, please contact.

Mr. R. V. Schrauder, Nuclear Licensing Manager, at (419) 249-2366.

Very truly yours, 1

MAL /dlm

[

Attachment cc P. M. Byron > DB-1 NRC Resident Inspector A. B. Davis, Regional Administrator, NRC Region III D. J. Kubicki, NRC/NRR Staff Reviewer T. V. Vambach, DB-1 NRC Senior Project Manager

Dotkat Nu~2b;r 50-3!:6 Lic nsa Numb 2r NPF-3 Serial Number 1642 Attachment 1 ,

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Attachment 1 1

Time and Hanpower Evaluations l

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.Liesnos Nuxbsr NPF-3 Sefial Number 1642 Attachment 1 Page 2 l

INTRODUCTION ~i i

Toledo Edison discussed the results of its time and manpower evaluation regarding the service water system and certain ventilation systems.in letter ,

dated June 6,'1988 (Serial Number 1535) and the results-of its' spurious l actuation analysis of high-low pressure interfaces in letter dated .

1 May 23, 1988 (Serial Number'1497). Each of the~ letters described the adequacy  !

of.the existing plant configurations or identified corrective actions necessary to establish compliance'vith 10CFR50,. Appendix R. The corrective .;

! actions included additional evaluations.of the time available to complete -j certain post-fire manual operator actions before an unrecoverable plant )

. condition would occur. The manual operator actions that are subject to .the. l l additional evaluations are' identified in Table 1. -l l

EVALUATION METHODOLOGY ~

-l In Serial 1535, Toledo Edison' described the methodology used to determine the l time to reach an unrecoverable plant condition. That methodology is applicable to the additional evaluations described herein. As stated in j Serial 1535, an unrecoverable plant condition is defined as the loss of any q f shutdown function (s) for such a duration as.to ultimately cause the reactor I coolant collapsed liquid. level to fall below the top of the active fuel height-of the core and a subsequent breach of the fuel cladding.- Maintaining the reactor coolant liquid level above the top of the' core' ensures adequate core l cooling and fission product boundary integrity. The time to reach an unrecoverable plant condition is measured from the reactor trip.

Additionally, the calculation of the time to reach an unrecoverable plant condition does not take credit for any manual operator actions, which are defined as actions taken outside the Control Room.

The evaluation assumed that the planned upgrades and additional fire protection features required to satisfy 10CFR50, Appendix R and scheduled for the sixth refueling outage have been completed. As an example, if a component would be required to remain operable in the event of a fire and Toledo Edison is committed to provide a means of fire protection consistent with 10CFR50, Appendix R, then that component was assumed to remain operable and not be l

damaged by a fire even though that fire protection' feature may not be l implemented at the.present time. This approach is also consistent with'the evaluation methodology discussed in Serial Number 1535.'

1 The evaluation discussed in Serial Number 1535 was for a fire outside the Control Room / Cable Spreading Room. That evaluation did not consider the evacuation of the control Room and, therefore, remote actions from within the  !

Control Room were assumed to be performed. The evaluation of the high-low i

pressure interfaces discussed herein assumes a Control Room / Cable Spreading Room fire and evacuation of the Control Room. In order to use the' evaluation results of system responses originally reviewed for Serial Number 1535, Toledo Edison assumes that the operators, prior to evacuation of the Control Room,-

would be able to trip.the reactor.as well as either to trip the Turbine or-close the Main Steam Isolation ~ Valves from within the Control. Room. Also, the operator actions to initiate AFV and to close the high-low interface valves

! are all completed either within the Control Room before evacuation or outside the Control Room after evacuation.

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1 Dotkat Nuabsr 50-346 ,

Licanaa Nusbsr NPF-3 Serial Number 1642 Attachment 1 Page 3 ACCEPTANCE CRITERIA Based on NRC guidance provided in the February 17-18, 1987 meeting between  ;

representatives of Toledo Edison and the NRC, the time to implement a manual 1 operator action is considered acceptable if the associated unrecoverable plant 1 condition would not occur: )!

1) for at least I hour if the manual operator action is to be completed I inside the area containing the fire; or  ;

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2) for at least 30 minutes if the manual operator action is to be completed outside the area containing a fire.

i l The 1-hour criterion would also apply to manual operator actions where access and egress routes are through the area containing the fire. Toledo Edison i committed to justify the acceptability of those manual operator actions that I do not satisfy this NRC guidance. I The results of these additional evaluations and necessary justifications are g l

presented below.

HIGH-LOV PRESSURE INTERFACES SCOPE Toledo Edison submitted its spurious actuation analysis for the high-lov pressure interface components in letter dated May 23, 1988 (Serial Number l 1497). That analysis determined that a fire inside or outside_the Control Room / Cable Spreading Room could cause a spurious opening of the high-low l pressure interface. A fire inside the Control Room / Cable Spreading Room could cause a spurious actuation of the letdown valves, the PORV and the RCS sample valves, which would be isolated by manual operator action performed outside the Control Room. Table 1 identifies the manual operator action.

A fire outside the Control Room / Cable Spreading Room, in Fire Areas DF, DJ or U, could cause a spurious actuation of the PORV, and the high-low pressure interface would be isolated by closing the block valve rernotely from the Control Room. The scope of the evaluations discussed herein is manual operator actions, which are actions performed outside the control Room.

Contrary to manual operator actions, the evaluation of actions performed remotely from the Control Room does not require an assumption of a time delay, 30 minutes or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, before the remote actions are performed. Therefore, the actions performed remotely from the Control Room would be completed well before an unrecoverable plant condition vould occur and are not included in the sen;e of the evaluations discussed herein.

TIME TO REACH AN UNRECOVERABLE PLANT CONDITION l The evaluation of the time to reach an unrecoverable plant condition t

conservatively assumes that a Control Room / Cable Spreading Room fire results in a loss of RCS inventory, due to a breach of the high-low pressure interface at the letdown valves, the PORV and the RCS sample valves. Using the evaluation methodology discussed in Serial Number 1535, the results of the

Dobkst Nuxb2r 50-346 l

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Lic2nce Nu b2r NPF-3 Serial Number 1642 4 Attachment 1 l Page 4  !

evaluation show that auxiliary feedvater (AFW) and makeup (MU) must be established within 25 minutes to preclude an unrecoverable plant condition.

Isolation of the high-low pressure interface valves would not need to be initiated for greater than 30 minutes. If AFV and MU are not established  ;

within 25 minutes, then the reactor coolant collapsed liquid level vould ultimately fall below the top of the active fuel height of the core.

TIME TO COMPLETE MANUAL OPERATOR ACTIONS The post-fire shutdown procedure for a fire in the Control Room / Cable Spreading Room is DB-0P-02519 (previously numbered as AB 1203.26), " Serious Control Room Fire." This procedure identifies the necessary manual operator 1 actions to achieve and maintain safe shutdown including the establishment of )

AFV and MU and the closing of the high-lov pressure interface valves.- During j Plant Operational Modes 1 through 4, which are defined as Power Operation  !

through Hot Shutdown, cix operators, one electrician and one I&C technician j are maintained around the clock to implement the procedure. In Plant l Operational Mode 5, Cold Shutdown, fever personnel are required to implement  ;

procedure DB-0P-02519 since there are fever required operator actions in this Mode. f l I In the event of a serious Control Room / Cable Spreading Room fire, plant operators are directed by procedure DB-0P-02519 to initiate AFV and MU and to close the high-low pressure interface valves. The operators would then proceed outside the Control Room and verify that the equipment in the plant I has properly responded to the actions taken in the Control Room, and if not, l take the necessary manual operator actions. Since these actions take longer l to complete outside the Control Room than inside the Control Room, the )

evaluation conservatively assumes that the AFV and MU are not established, and l the high-low pressure interface valves are not closed, from within the Control l Room.

To establish AFV and MU from outside the Control Room, the operators available to perform post-fire safe shutdown actions are tasked with the lineup and starting of one emergency diesel generator, the isolation of the high-low pressure interface and the establishment of AFV and HU. The EDG can be placed into operation and the high-low pressure interfaces can be isolated within 20 l minutes based on a valkdown of the actual steps specified in procedure '

DB-FP-02519. The establishment of MU and AFV can be completed within 15 minutes based on a trial walkdown of similar manual operator actions.

These operator actions would not be perfcrmed in the fire area containing the fire, the Control Room / Cable Spreading Room, and the associated access and eFress paths are not through the fire area containing the fire. Consequently, the NRC acceptance criterion for this manual operator action is 30 minutes.

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Dockst Nu2bar 50-346 Licensa Nuxbar NPF-3

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Serial humber 1642 Attachment 1 Page 5 EVALUATION RESULTS AND JUSTIFICATION The results of the evaluation show that the necessary manual operator actions must be completed within 25 minutes to preclude an unrecoverable plant condition, which is less than the aforementioned 30-minute acceptance criterion. Toledo Edison believes that these' manual operator actions are nonetheless acceptable since plant'valkdowns have demonstrated the ability of plant operators to complete these actions well within the time. required to close the high-low pressure interface valves and to. establish the operation of AFV and MU.

It should be noted that procedure DB-0P-02519, " 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 19-25, 1983. A valkdown of this procedure by the NRR and Region III staffs confirmed that the minimum manpower required by the procedure was capable of performing'the identified tasks in the necessary timeframe. The NRC's review and acceptance is documented in Inspection Report 83-16 dated August 30, 1984 (Log Number 1-1024) and the Safety Evaluation Report for the Davis-Besse Fire Protection Program Corrective Action Plan dated September 23, 1983 (Log Number 1375).

This precedure has been subsequently revised to improve its effectiveness and to address other fire protection enhancements at Davis-Besse.

As stated above, Toledo Edison's evaluation shows that there is adequate time to - 9:blish AFV and MU and to close-the high-low pressure interface valves before an unrecoverable plant condition vould occur. Therefore, Toledo Edison has concluded that no additional corrective action regarding this matter is necessary in order to establish compliance with 10CFR50, Appendix R.

SERVICE WATER SYSTEM SCOPE Toledo Edison submitted its evaluation of the post-fire manual operator actions required for a fire outside the Control Room in letter dated June 6, 1988 (Serial Number 1535). That evaluation determined that four manual operator actions identified in Table 1 may be necessary to establish the operation of the Service Water System (SVS) and required additional evaluation. The additional evaluation was necessary to establish better data on the limiting times for the Emergency Diesel Generator (EDGs) to be put into operation in the event of a fire.

TIME TO REACH AN UNRECOVERABLE PLANT CONDITION A fire in Fire Areas BF, II or R could cause the loss of service vater. The SVS provides cooling water to the Component Cooling Vater (CCV) heat exchangers. The CCV system, in turn, provides cooling water to the Emergency Diesel Generator (EDG) heat exchangers. The EDGs provide essential power for certain components that are necessary to achieve end maintain safe shutdown in the event of a fire. These systems include HPI or MU systems, either of which ,

provide a source of water to the reactor vessel.

Dock 3t Nu2bar 50-346 Lictnca Nutbar NPF-3' Sefial Number 1642 Attachment 1 Page 6 Toledo Edison has determined that CCV vould not overheat within 30 minutes despite the loss of service water based on the extrapolation of actual CCV operating data. Consequently, the EDGs would continue to provide a source of onsite power without manual operator action for.at least 30 minutes.

The time to restore either HPI or MU before an unrecoverable plant condition would occur is no less than 44 minutes assuming no fire-induced spurious actuation of a high-low interface valve. Such spurious actuations are not postulated in Fire Areas BF, II or R.

TIME TO COMPLETE MANUAL OPERATOR ACTIONS l I

The post-fire safe shutdown procedure for a fire outside the Control Room is ]

DB-0P-02501 (previously numbered as AB 1203.02), " Serious Station Fire." That q procedure identifies the manual operator actions necessary to achieve and 4 maintain safe shutdown in the event of a fire, including the establishment of

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SVS and the operation of the EDGs. j In the most conservative scenario, a fire in Fire Areas BF, II or R is assumed to cause the loss of service water. A loss of offaite power is also ,

postulated since the post-fire procedures direct the operators to trip the  !

offsite power source breakers in order to pieclude unanalyzed spurious actuations. This condition would result in the automatic start of the EDGs, which would provide a source of onsite power.

For at least 30 minutes without manual operator action, CCW would not overheat despite the loss of service water, and the EDGs vould be provided with a source of cooling water. However, it is assumed that manual operator action vould ultimately be required to restore service water flow to a fire in Fire Areas BF, II or R. The scope of the manual operator actions and the applicable NRC acceptance criteria are discussed below.

Fire Area BF contains the Service Water Pumps and their associated-control and i power circuits, and the circuits for Service Water Valve SV-1399. A fire in Fire Area BF could cause the loss of the Service Water Pumps and the loss of control of SV-1399 from the Control Room. The inability to close SV-1399 from the Control Room would allow the diversion of service water flow to non-essential components such that the available Service Water Pump would trip, if not already inoperable due to the fire. The operator actions are to depower and manually close Service Water Valve, SV-1399, and to start the backup Service Vater Pump. Based on trial walkdowns of similar manual operator actions specified by procedure DB-0P-02501, one operator can depower and close SV-1399 in approximately 8 minutes and another operator would start the backup Service Vater Pump in approximately 12 minutes. Therefore, for a fire in Fire Area BF, the necessary operator actions vould be completed in approximately 12 minutes. For a fire in Fire Area BF, the operator actions are not performed in the fire area containing the fire and the access and egress paths are not through the fire area containing the fire. Consequently, NRC acceptance criterion for the manual operator actions in Fire Area BF is 30 minutes.

' Docket Nunbar 50-346 1 Licsnss Numbar NPF-3 Serial Numbar 1642 i Attachment 1  !

Page 7 Fire Area II contains the circuits for Service Water Valve SV-1399, which if damaged by a fire, could prevent the control of SV-1399 from the Control Room. 1 The inability to close SV-1399 from the control Room would allow the diversion of service water to non-essential components such that.the available Service ,

Water Pump trips. The operator actions are to manually close Service Water j

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Valves SV-630, SV-631.and SV-632 in Room 334. The SVS pump vould be restarted remotely from.the Control Room. Based on trial walkdowns of similar manual-operator actions specified by procedure DB-0P-02501, one operator can close the Service Water Valves in approximately 14 minutes, c

The operator would need to enter Fire Area II in the event of a fire in Fire Area II in order to close the SVS valves and to prevent the diversion of service water ~ flow to non-essential equipment. Fire Area II is the. largest fire area at the Davis-Besse and consists of 20 different fire zones and 25  ;

individual rooms. The need to close the SVS valves would only occur for a fire in Room 53. The SVS valves SV-630, SV-631 and SV-632 are located in Room 334. Room 53 is at the 565 foot elevation at the end of a tunnel connecting the Turbine Building to the Service Water Intake Structure. Room 334 is at j the 585 foot elevation in the Turbine Building. These two rooms are more than )

200 feet from one another and are separated by a concrete vall. Rooms 53 and 334 are provided with automatic sprinklers and Room 53 is also provided with fire detection. Although the manual actions would be performed in the same fire area containing the fire, the operator vould not be exposed to the fire and would not have to traverse within 200 feet of the fire. Consequently, due to the location of the manual operator actions relative to the postulated fire, Toledo Edison does not consider this manual operator action in Fire Area II to be performed in the vicinity of the fire and considers the 30-minute NRC ,

acceptance criterion to be appropriate.

Fire Area R contains the control and power circuits for the Service Water Pumps, which if damaged by a fire, could cause the loss of the Service Water Pumps. The manual operator action is to start the Backup Service Water Pump.

Based on trial walkdowns of the manual operator acticas specified by procedure DB-0P-02501, one operator can line up and startup the Backup Service Water.  ;

Pump in approximately 12 minutes. For a fire in Fire Area R, the manual operator action is not performed in the fire area containing the fire and the access and egress paths are not through the fire area containing the fire.

Consequently, the NRC acceptance criterion for this manual operator action is 30 minutes.

EVALUATION RESULTS AND JUSTIFICATION The results of the evaluation show that the time to reach an unrecoverable plant condition is greater than 30 minutes, which satisfies the NRC acceptance criterion of 30 minutes. Also, the operator actions specified by the existing plant procedures can be completed in less than 30 minutes. Therefore, the manual operator actions required for Fire Area BF, II and R satisfy the NRC guidelines and are in accordance with 10CFR50, Appendix R.

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. Dockst Nuxbsr 50-346

.Lictnca Numbar NPF-3 Serial Number 1642

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'Page 8 The NRC has previously reviewed the manual operator actions for the Service Water System due'to a fire in Fire Area BF and II. In order to' satisfy Appendix A to BTP:APCSB 9.5-1,. Toledo Edison committed in response to NRC

-Question 11 in Revision 4 of the Fire Hazards Analysis Report.to install certain fire protection features for Fire-Areas BF (previously denoted as Fire Area RR) and II (previously denoted as Fire Area TT) rather than install a~ i one-half hour floor-to-ceiling fire barrier between each Service Water Pump. l l

These fire protection features, as documented'in Davis-Besse License Amendment

1. 18, are as follows:

1) Vet pipe sprinkler system equipped with quick response type sprinklers (Grinnell Model F931-type sprinklers) in the Service Water Pump Room )

l and Valve Room (Intake Structure). j i

2) Additional hand-held portable extinguishers in the Service Water Pump Room.

3) Concrete floor curbs around the Service Water Pumps. 1

4) Concrete curb under the Door 218, which is at the entrance of the Service Water Pumps area at the Diesel Fire Pump side.

5) Additional hose station in the Intake Structure.

6) One-half hour fire-rated barrier in the Service Water Pump Room y enclosing the Service Water Valve motors and around conduits f associated with the. power and control for the Service Water Pump and i l

Valves on the return line to the forebay and the cooling tower makeup.

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l. 7) One-half hour fire-rated barrier around conduits in the Service Water I Valve Room associated with power and control for the service water  !

I discharge valves.

8) Backup Service Water System independent of offsite power.

These fire protection features were accepted by the NRC and remain in place at this time. The NRC has previously considered these features to be' adequate fire protection in the Service Water Pump Room in order to complete the manual operator actions to re-establish cooling water to shutdown equipment including the EDGs.

It should be noted that the evaluation discussed herein has determined that safe shutdown in the event of a fire-in Fire Area BF or-II can be achieved and maintained by manual operator action rather than the above fire barriers.

These fire barriers are currently constructed of Kaovool, which is fragile and degrades with age. Toledo Edison has committed to replace the Kaovool with a more durable fire barrier material, but does not anticipate replacing those fire barriers that protect equipment no longer required to achieve and maintain safe shutdown in the event of a fire. The above fire barriers vill =

be removed following a revision of the Davis-Besse License consistent with Generic Letter 86-10.

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.~. q l . Docket N ebar 50-346.-

-- Licsnsa Numbar NPF-3 Serial Number 1642  ;

Attachment:

1 l Page 9 _1 CERTAIN VENTILATION SYSTEMS SCOPE Toledo Edison submitted its evaluation of the post-fire manual' operator .

-l actions required for'a fire outside the Control Room in letter. dated June 6, ~

1988~(Serial Number 1535). It was determined that an additional evaluation of (

the time available to_ implement the one manual operator! action' identified by Table 1 to establish temporary ventilation in the Component Cooling Water.

(CCW)_ Pump Room was necessary.

TIME TO REACH AN UNRECOVERABLE PLANT CONDITION.

A fire in the CCV Pump Room, Fire Area'T, is postulated to cause the loss of the CCW Pump. Room Ventilation Fans and the CCV Pump Room Louvers., As a result, Toledo Edison originally proposed to use temporary, ventilation, I consisting of elephant trunk ducting and portable fans powered by gasoline- I engine driven electric generators, as alternative shutdown capability in order to comply with 10CFR50, Appendix R. l To determine the time before an unrecoverable plant condition would occur, Toledo Edison compared the maximum air temperature the CCW Pump Room would reach in the event of a fire with the loss of the associated' ventilation system to the maximum operating temperature of the CCW' Pump.. For the purposes of this evaluation', a fire is assumed to result in the immediate loss of both ,

CCW Pump Room Fans and Louvers. Such a. fire vould actuate the CCW Pump Room I sprinkler system, which provides protection to the complete floor area and has.

a sprinkler actuation temperature setting of 165'F. Toledo Edison has' concluded that the water from the sprinkler system wouldl cool the air in'the room below the setpoint of the sprinklers and the average air temperature of

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the CCW Pump Room would not exceed 165'F despite the loss of the CCV Pump Room Fans and Louvers. Once the fire is extinguished, the temperature of-the CCV Pump Room is calculated to stabilize at 123'F vith the loss.of the CCV Pump Room ventilation.

-The maximum ambient room operating temperature of the;CCV Pump motors was determined from the rated temperature capacity of the motor insulation minus the measured motor temperature rise above. ambient room temperature based on factory testing. The CCW Pump motors are manufactured with a Class F l insulation, which is intended for use in high voltage and high temperature motors. The insulation is made of a synthetic epoxy resin material with  !

mica-tape strips in order to limit the hottest spot temperatures.. Class F '

insulation has an absolute motor temperature capacity of 311'F. -A. service factor of 1.15 for a NEMA load inertia of.4199 lb-sq.ft. results in a measured motor temperature _ rise of_126*F based on extrapolation of factory testing data. Subtracting the measured motor temperature rise.(126*F) from the absolute. motor temperature operating capacity (311'F) results in a maximum ambient room operating temperature of 185'F for the CCV Pump motors.

Consequently, the maximum ambient room operatingitemperature for the CCV Pump motors is 20'F greater than the postulated maximum-average room temperature (165'F) would be due to a fire and loss of the CCW Pump Room Fans and Louvers.

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Docket Number 50-346 License Number NPF-3 Serial Number 1642 Attachment 1 Page 10 EVALUATION RESULTS Toledo Edison has concluded that the CCV Pump would remain operable in the event of a fire in Fire Area T and the loss of the associated ventilation system since the maximum ambient room operating temperature of the pumps motors (185'F) would be greater than the postulated average air temperature of the CCV Pump Room (165'F). Therefore, manual operator action to establish temporary ventilation for a fire in Fire Area T is not required to satisfy 10CFR50, Appendix R.

Circuits for the CCW Pump Room Fans and Louvers are also located in Fire Area U. Toledo Edison had proposed to use temporary ventilation as an alternative shutdown capability rather than provide fire protection in accordance with 10CFR50, Appendix R, Section III.G.2 for these circuits. As a result, in letter dated January 12, 1987 (Serial Number 1327), Toledo Edison requested an exemption from 10CFR50, Appendix R in order to obviate the need s to install fixed fire suppression in Fire Area U. Additionally, in letter dated August 9, 1988 (Serial Number 1558), Toledo Edison proposed to install a fire wrap of circuits for the CCV Pump Room Fans and Louvers in order to eliminate a post-fire repair necessary to establish the temporary ventilation.

However, the above evaluation has determined that the CCV Pumps would remain operable despite the loss of the CCW Pump Room Fans and Louvers, and temporary ventilation is no longer considered necessary. Toledo Edison, therefore, withdraws the exemption for Fire Area U and does not intend to install the fire wrap since temporary ventilation is not required to satisfy 10CFR50, Appendix R.

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