ML20245D892

Responds to NRC Re Violations Noted in Insp Rept 50-346/83-16.Corrective Actions:Implementation of long-term Corrective Actions by Fire Protection Compliance Group Will Result in Improved Fire Protection Program

ML20245D892
Person / Time
Site:	Davis Besse
Issue date:	09/30/1988
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
1-835, NUDOCS 8810070288
Download: ML20245D892 (24)

Text

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TOLEDO

%m EDISON A Cectere Eregy Crwv i

DONALO C. SHELTON September 30, 1988 Z'77;7*"

Docket No. 50-346 License No. NPF-3 Serial No. 1-835 September 30, 1988 United. States NRC Document Control Desk Washington, D. C. 20555 Gentlemen:

Subject:

Reply to a Notice of Violation (NRC Inspection Report No. 50-346/83-16)

Toledo Edison has received the subject Notice of Violation transmitted by NRC letter dated August 31, 1988 (Log No. 1-1907). That notice addresses the results of a 1983 NRC inspection of the Davis-Besse Fire Protection Program and the steps taken at that time by Toledo Edison regarding compliance with 10CFR50.48 and the applicable sections of 10CFR50, Appendix R.

Toledo Edison has reviewed the alleged violations described in the notice and finds that they are addressed by the noncompliance identified by Inspection Report 83-16 transmitted by NRC letter dated August 30, 1984 (Log No. 1-1024). Toledo Edison accepts that its fire protection program was deficient at the time of the 1983 inspection and, as stated in its November 7, 1986 (Serial No. 1-678) response to Inspection Report 83-16, has accepted that each noncompliance did occur. Toledo Edison will continue to expend significant resources to establish compliance with 10CFR50, Appendix R and, just as importantly, to implement an adequate fire protection program. Therefore, rather than discuss whether each noncompliance identified in 1983 is an actual violation of legally binding requirements, Toledo Edison has concluded to accept the alleged violations and direct its efforts towards implementation of the necessary corrective actions.

In its aforementioned response to Inspection Report 83-16, Toledo Edison identified the corrective action taken or to be taken and the scheduleThe NRC to complete the ongoing corrective actions for each noncompliance.

8810070288 880930 ,O/

PDR ADOCK 05000346 PNV 3gd G.

EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 THE TOLEDO EDl50N' COMPANY

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. ' Docket No. 50-346

. Licensa No. NPF-3 Serial No. 1-835-

. September 30, 1988 ir ~ quested to refer to those discussions in that response. That response notes that eleven of the nineteen 1983 noncompliance have been closed by subsequent NRC inspections. Four additional noncompliance are expected to be closed based on discussions with NRC inspectorr who performed an unannounced Region III inspection at Davis-Besse during the week of September 12, 1988. Attachment I hereto provides an update to the responses in the November 7,1986 letter for certain noncompliance and a correlation of the 1983 noncompliance with the alleged violations.

Toledo Edison's response to the 1983 inspection, however, does not contain a discussion of the 1) reason for the occurrence of these alleged violations and 2) corrective steps that will be taken to avoid further violations.

This discussion is provided below for the violations collectively as well as a reaffirmation of the schedule to establish full compliance:

REASON FOR THE OCCURRENCE OF THE ALLEGED VIOLATIONS In letter dated December 16, 1983 (Serial No. 1-396), Toledo Edison described its good faith effort to satisfy the requirements of 10CFR50.48 and the applicable sections of Appendix R. That letter describes in detail the history of Toledo Edison's commitment in establishing an adequate fire protection program at Davis-Besse, the reviews by contractors to verify compliance with 100iR50, Appendix R, and the engineering evaluations conducted regarding 10CFR50, Appendix R.

While Toledo Edison believes that its efforts to satisfy the fire protection regulatory requirements were taken in good faith, Toledo Edison acknowledges that these efforts were not adequate.

These violations involve noncompliance with the requirements of 10CFR50, Appendix R and the Technical Specifications as well as inadequate implementation and maintenance of the fire protection program required by its license regarding Appendix A to BTP APCSB 9.5-1.

Toledo Edison acknowledges, as stated in the Notice of Violation, the complete cause for the occurrence of these violations includes Toledo Edison's lack of proper supervision of its employees and contractors to ensure adequate technical review of the requirements of 10CFR50, Appendix R and to implement and maintain an adequate fire protection program consistent with its license. However, a number of the

ti. an be enntribu! M ' n % Nk s' H wity in the fi n protection requirements at the time , as noted in the NRC transmittal letter for the Notice of Violation, and to the letter clarifying the guidelines of Generic Letter 81-12 not being received by Toledo Edison.

Additionally, a number of the violations can also be attributed, in part, to audits performed by outside contractors that did not reveal significant deficiencies in the 1983 fire protection program prior to the 1983 NRC inspection.

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. Docket No. 50-346

. Liccaso No. NPF-3 Serial No. 1-835

. September 30, 1988 CORRECTIVE ACTION TAKEN OR TO BE TAKEN TO PREVENT RECURRENCE Since 1983, Toledo Edison has been in close communication with Staff members at the NRC regarding the development of the Davis-Besse fire protection program. In letters dated August 26, 31 and September 13, 1983, Toledo Edison submitted its fire protection corrective action plan identifying the short and long-term corrective actions necessary to resolve the 1983 inspection findings. Based on the completion of the short-term corrective actions, the NRC allowed the restart of Davis-Bessa by NRC letter dated September 23, 1983 (Log No. 1375).

Toledo Edison has been implementing the long-term corrective actions since issuance of the fire protection corrective action plan. The focal point for the long-term corrective actions is the Fire Protection Compliance Group (FPCG) which was established in 1985 with a purpose to establish compliance with 10CFR50, Appendix R by restart from the sixth refueling outage and to implement a fire protection program consistent with the Davis-Besse license. Currently, the FPCG consists of twenty-nine technical personnel including four registered fire protection engineers.

The implementation of the long-term corrective actions by the FPCG will result in an improved Davis-Besse fire protection program.

This improved fire protection program is under development and will be consistent with the requirements of 10CFR50.48. The improved program is to include the fire hazards analysis for Davis-Besse and the necessary implementing procedures. The overall Davis-Besse procedure program controls the existing fire protection procedures.

Additionally, the existing program and implementing procedures are currently addressed by the Administrative Controls Section of the Davis-Besse Technical Specifications. The fire hazards analysis, including the Davis-Besse Fire Hazards Analysis Report and Appendix R Compliance Assessment Report (CAR), is being revised to be based on a thorough comparison of the plant configuration via drawing reviews and limited plant walkdowns, against the fire protection regulatory requirement of 10CFR50, Appendix R, the Davis-Besse Technical Specifications, License Condition 2.C(4) regarding Appendix A to BTP APCSB 9.5-1 and the applicable NFPA Codes. All clarifying regulatory documentation are being utilized, such as Generic I-tra- 91-7? md 96-?" . These revisions are being documented and incorporated into the program as design basis documentation.

The appropriate procedures to be included in the program are to ensure that the design basis documentation is maintained current and any plant changes are properly reviewed against the design basis documentation in order to preclude a reduction in the ability of Davis-Besse to achieve safe shutdown in the event of a fire. The program is also to include the necessary procedures that ensure fire protection equipment is maintained and surveilled and the appropriate compensatory measures are implemented when equipment is found, or is intentionally taken, out of service.

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, .Dockat'No. 50-346

,' Liczase No. NPF-3 Serial No. 1-835'

. September 30, 1988

.The Administrative Controls section of the Davis-Besse Technical Specifications require annual and triennial audits of the fire l protection and loss prevention program. A triennial quality assurance audit was recently completed in August 1988 with a' qualified outside fire consultant and included a special review of those portions of the fire protection program implementing the requirements of 10CFR50, Appendix R. The audit report notes that much work remains to be completed and that the program is in transition, but concludes: "All objective evidence indicates that, once the identified modifications are implemented and analyses are completed, the program will be in full compliance with the applicable requirements."

In summary, this improved fire protection program will preclude the recurrence of these violations in the future.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The required corrective actions necessary to establish full compliance include physical modifications and NRC approval of Toledo Edison's exemptions requested in letter dated January 12, 1987 (Serial No. 1327). Toledo Edison is preceeding to implement the physical modifications with a schedule to achieve full compliance by t- restart from the sixth refueling outage assuming NRC approval of the requested exemptions.

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

Schrauder, Nuclear Licensing Manager, at (419) 249-5000, ext. 7360.

Very truly yours, b

D. C. Shelton Attachment cc. D;,-I sh Remidcut luopcotut A. B. Davis, NRC Region III Region Administrator

9 Dock:t No. 50-346 Licenso No. NPF-3 Serial No. 1-835

- September 30, 1988 Attachment 1 ATTACHMENT 1 UPDATE TO THE RESPONSES TO THE 1983 NONCOMPLIANCE In letter dated November 7, 1986 (Serial No. 1-678), Toledo Edison responded to each noncompliance identified in Inspection Report 83-16. These noncompliance address each of the alleged violations identified in the Notice of Violation transmitted in letter dated August 31, 1988 (Log No. 1-1907). Toledo Edison requests that the NRC refer to the response to the 1983 inspection for the corrective actions taken or to be taken for each of the violations. The following is a correlation of the alleged violations with the 1983 noncompliance:

CORRELATION OF ALLEGED VIOLATIONS AND 1983 NONCOMPLIANCE VIOLATION DESCRIPTION 1983 NONCOMPLIANCE A One train of AFWS not protected 83-16-02

& missing Kaowool 83-16-11 l B1 Lack of capability to achieve 83-16-01A cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B2 Lack of alternative shutdown 83-16-01A instrumentation and an inadequate instrument range B3 Alternative shutdown procedures 83-16-01A did not consider loss of offsite power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B4 Lack of a complete associated 83-16-01A circuits evaluation 83-16-01B C Lack of fixed fire suppression 83-16-03 in areas requiring alternative shutdown D Lack of certain emergency lights 83-16-05 and failure to satisfy 8-hour battery discharge test for 2 lights E Inadequately sized reactor coolant 83-16-07 pump oil collection system F1 Inadequate staffing qualifications 83-16-22I 1

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D:ckat No. 50-366 Liernsa No. NPF-3 Serial No. 1-835

. September 30, 1988 Attachment 1 F2 Inadequate controls of fire door 83-16-15 modifications F3 Inadequate fire damper test 83-16-22J procedure F4a Inadequate performance of 83-16-22C sprinkler teet procedure F4b Inadequate diesel fire pump test 83-16-22A procedure F4c Inadequate valve operability 83-16-22B test procedure F4d Lack of minimum physical 83-16-22F requirements for fire brigade members F4e Inadequate fire watch training 83-16-22G F4f Inadequate fire detector test 83-16-22D procedure F5 Inadequate procedures for the 83-16-22H offsite fire department F6 Inadequate emergency light test 83-16-22E procedure G Failure to establish fire watch 83-16-13 for inoperable fire damper Since the Toledo Edison response to the Inspection Report 83-16 was issued, modifications, procedure revisions and further evaluations have been performed. As a result, the corrective actions for three of the noncompliance (83-16-01A, 83-16-01B, and 83-16-11) have been revised.

Four other noncompliance (83-16-02, 83-16-03, 83-16-15, and 83-16-22B) are expected to be closed based on discussions with NRC inspectors who participated in an unannounced Region III inspection at Davis-Besse during the week of September 12, 1988. The following provides a summary of the status of each of the 1983 noncompliance and an update to the seven concompliances whose corrective actions have been revised or will be closed. Revision bars have been used to highlight the text changes of the previous response to Inspection Report 83-16.

. Docket No. 50-346

LicenseNo. NPF-3

. Serial No. 1-835-

. September.30, 1988

Attachment:

1' Status of the 1983 Noncompliance

.-IR 83-16 Actions to be.Taken Noncompliance Status Procedure'Rev. Modification

• Exemption **

01A. Open - X. X l 01B Open -

X -

l 02- Open- - - X .l 03 Open - - X 05 Open -

X X-07 Closed - - -

11- Open - X -

l 13 Closed - - -

15l Closed - - -

l 22A Closed - - -

22B . Closed - - - '

l 22C Closed - - -

22D . Closed - - -

22E Closed- - - -

'22F Closed - - -

22G Closed - - -

22H Closed -- - -

22I Closed - - -

22J Closed - - -

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• The required modifications are in various stages of implementation, but are scheduled for completion no later than restart from the sixth refueline mitare.

• • The exemptions required to resolve the noncompliance have been submitted by Toledo Edison in letter dated January 12, 1987 (Serial No. 1327). These exemptions are pending NRC approval and no additional Toledo Edison action is anticipated.

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' Docket No. 50-346

4- License No. NPF-3 o Serial No. 1-835 L

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. ' September 30, 1988 Attachment 1-Noncompliance The alternate shutdown capability did not meet'the 83-016-01A acceptance criteria for achieving and maintaining hot standby, achieving cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, being independent of the fire area, accommodating loss of offsite power, providing direct readings of the process variables necessary to perform and control the reactor shutdown functions, and having procedures in effect to implement the safe shutdown capability (83-16-01A).

Updated Response: Acceptance or Denial of the Alleged Noncompliance Toledo Edison accepts the alleged noncompliance.

Corrective Action Taken and Results Achieved Toledo Edison developed and submitted the Davis-Besse Appendix R Compliance Assessment Report (CAR), Revi-sion 1, to the NRC in letter dated June 3, 1986 (Serial No. 1253). The CAR provides a compliance assessment of Davis-Besse's safe shutdown systems,.

components, circuits and associated circuits (Appen-dix R, Sections III.G), emergency lighting (Appendix R,Section III.J) and reactor coolant pump oil collection system (Appendix R,Section III.0). The CAR also presents the evaluation for alternative shutdown capability as required by Appendix R, Sections III.G and III.L.

Proposed resolutions of identified deficiencies in Davis-Besse's. compliance with Appendix R are presented in the CAR and include physical modifications and l specific exemptions from Appendix R requirements.

The following specific concerns cited in IR 83-16, Paragraph 4.a (1) and the proposed resolution documented in the CAR are as follows:

IR 83-16-01A

a. It did not consider the effect of a fire.

Assumptions of initial conditions such as the capability of automatic control features were not consistent with the existence of a postulated fire in the control room or cable spreading room.

Thus, various designated procedural actions could not be implemented without procedural modifica-tions. For example, auxiliary feedwater flow to

Dock 2t No. 50-346

.. Lie:nsa No..NPF-3 Serial No. 1-835

. September 30, 1988

. Attachment I the steam generators will provide decay heat removal for hot shutdown and the decay heat removal system for cold shutdown. The use of the steam generators requires either MS101 and FW612 or MS100 and FW601 valves to close plus either MS106 and AF3870 or MS107, AF599, and AF3872 valves to open. A fire could affect the automatic operation of these valves.

CAR Resolution The CAR documents the analysis for the auxiliary feedwater system for a fire in the Control Room or Cable Spreading Room. The CAR indicates that the aforementioned valves are either 1) not required for a fire in the Control Room or Cable Spreading Room or 2) that the necessary corrective actions for these valves have been implemented.

IR 83-16-01A

b. It did not consider the possible effects of interaction between associated circuits of concern. Protection from spurious or maloperations of associated circuits caused by a fire may require the addition of isolation, transfer switches or other equipment.

CAR Resolution Section 5 of the CAR documents the associated circuits analysis for common power sources, spurious actuations and common enclosures. This analysis includes an evaluation of the nonconfor-mances with Appendix R,Section III.G and planned resolutions which include the installation of isolation (transfer) switches.

IR 83-16-01A

c. It failed to delineate specific actions or shutdown methods unique to the availability or unavailability of offsite power for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Instead emergency operating procedure EP 1202.02,

" Station Blackout" had to be utilized in conjunc-tion with AB 1203.12, but the station blackout procedure did not address the effects of a fire on implementation of the procedure.

H . Dockat No. 50-346 Licensa No. NPF-3 Serial Nc. 1-835 September 30, 1988 Attachment 1 CAR Resolution The analysis performed in the CAR considered the possibility of a loss of offsite AC power in conjunction with a fire. The systems necessary to satisfy the protective functions to safely shutdown the plant in the event of a fire were identified through a review of Emergency Procedure EP 1202.02, " Station Blackout." A list of components for each of these safe shutdown systems included those components required to assure essential power to safe shutdown components in the event of a loss of offsite power. Required operator actions, including those necessary to cope with a-loss of offsite power based on the i CAR analysis, are addressed in procedures I AB 1203.02, " Serious Station Fire Procedure," and AB 1203.26, " Serious Control Room Fire."

Currently, procedure AB 1203.02 specifically addresses automatic and operator actions with and without a loss of offsite power. Operator actions without a loss of offsite power include tripping all source breakers to Buses "A" and "B", thereby resulting, in effect, in the same condition as a loss of offsite power. This operator action would be taken if safety systems are adversely affected by fire and the fire is extremely serious.

Procedure AB 1203.26.also currently addresses the availability of offsite power. As with procedure AB 1203.02, the operator is directed by procedure AB 1203.26 to trip all source breakers to Buses "A" and "B" as determined necessary by the Shif t Supervisor.

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IR 83-16-01A

d. The station staff did not agree with some proce-dure requirements. Procedure AB 1203.12, Section 4.2 states, "The objective of this procedure is to place the plant in a shutdown condition with the reactor decay heat dependent on the minimum amount of equipment...". At a meeting with plant personnel on July 27, 1983 the licensee's staff verbally indicated that the pressurizer heaters were not included in the minimum amount of equipment. However, the

Dock 2t No. 50-346 Lic;nsa No. NPF-3 Serial No. 1-835

. September 30, 1988-Attachment I control room evacuation-procedure required use of the pressurizer heaters and the control for the heaters were electrically independent of the control room or cable spreading room. The procedures did not delineate methods of maintain-ing hot standby without pressurizer heaters nor did the procedures identify the provision to l

q immediately proceed to cold shutdown, given a control room or cable spreading room fire.

CAR Resolution The CAR analysis does not consider the essential pressurizer heaters as necessary to achieve and maintain hot standby since reactor coolant system I depressurization and subsequent cooldown are controlled by the rate of pressurizer heat loss to the Containment atmosphere. Procedure AB 1203.02,

" Serious Station Fire Procedure," specifies that if there is a loss of all pressurizer heaters because of a fire, the operator is to proceed to cold shutdown. This operator action is required with either offsite power available or unavailable.

Procedure AB 1203.26, " Serious Control Room Fire," does not require the use of the pressurizer heaters in the operators guidelines to achieve and maintain hot standby. Additionally, Section 4.0 of procedure AB 1203.26 provides operator guidelines for cooldown to cold shutdown.

IR 83-16-01A

e. The licensee did not provided the capability of achieving cold shutdown conditions independent of the control room or cable spreading room.

Additionally, during the July 27 meeting, the licensee indicated that cold shutdown conditions I could not be achieved in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> assuming a loss of_;ffpite cover.

CAR Resolution In letter dated August 20, 1984 (Log No. 1586),

the NRC granted an exemption from Appendix R to obviate the need for the capability to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This portion of noncompliance 83-16-01A was closed by an NRC Region III follow-up inspection documented in IR 85-028, dated November 22, 1985, (Log No. 1-1280).

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D:ckst No. 50-346 Licensa No. NPF-3 Serial No. 1-835 September 30, 1988 Attachment 1 IR 83-016-01A

f. The instrumentation at the auxiliary shutdown panel did not provide complete process monitoring function. The panel lacked source range flux monitoring capability. Monitoring of core flux is needed to provide a direct indication of the reactor shutdown condition. The reactor coolant

. temperatures, in conjunction with the reactor coolant system pressure, are necessary parame-ters for plant cooldown and control. The plant control elements which rely on accurate reactor coolant temperature indication are natural circulation, subcooling and pressurized thermal shock concerns. The panels lacked instruments-tion for reactor coolant cold leg temperature and the range for reactor coolant hot leg temperature was inadequate.

CAR Resolution In response to the NRC Region III inspection leading to noncompliance 83-16-01A, Toledo Edison committed in letter dated September 13, 1983 (Serial No. 986) to take interim action to compensate for the absence of source range flux, cold leg and wide range hot leg temperature, and the potential isolation of the reactor coolant system (RCS) pressure instrument. These interim measures, including procedure revisions and physical modifications, were verified as complete by an NRC Region III follow-up inspection as documented in IR 83-16. As discussed in the CAR, a source range monitor will be installed at the alternative shutdown panel and a redundant source of RCS pressure indication will be installed at a local panel. Additionally, RCS cold and hot leg temperature indication will be provided via a digits 1 resdent device that esy be placed in operation via a multi-pin twist disconnect plug as discussed in Toledo Edison letter dated May 27, 1987 (Serial No. 1361).

As stated in TED letter dated June 3,1986 (Serial No. 1253), the physical modifications identified by the CAR are scheduled to be com-pleted by the end of the sixth refueling outage.

The procedure revisions identified by the CAR are completed. The necessary exemptions from certain requirements of Appendix R have been requested by Toledo Edison letter dated January 12, 1987 (Serial No. 1327).

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.y Dockat No.'50'-346-Licsase No. NPF-3 Serial No. 1-835' September 30, 1988 Attachment 1 Date When Full Compliance Will be Achieved l Full compliance will be achieved upon implementa-tion of the physical modifications committed in l the CAR and NRC approval of the exemptions requested in Toledo Edison's letter dated January 12, 1987. The physical modifications are scheduled to be-completed by the end of the sixth refueling outage. The procedure revisions inde-pendent of the physical. modifications.have been completed.

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r Docket No. 50-346 Licznse No. NPF-3 Serial No. 1-835 September 30, 1988 Attachment 1 Noncompliance Failure to perform a spurious signal analysis for 83-16-01B motor-operated valves M02929, 2930, 2931 and 2932 in the service water discharge line, and failure to analyze for spurious signal actuation of the pressur-izer POPV and block valves, and the letdown cooler isolation valves (83-16-01B).

l l Updated Response: Acceptance or Denial of the Alleged Noncompliance I, Toledo Edison accepts the alleged noncompliance.

Corrective Action Taken and Results Achieved The CAR documents the spurious actuation analysis of safe shutdown circuits and associated circuits, including the service water valves, PORV and its block valve, and the letdown cooler isolation valves.

Additional information was provided in response to NRC Questions 29, 30 and 31 by letters dated May 27, 1987 (Serial No. 1361) and May 23, 1988 (Serial No. 1497).

No modifications, procedure revisions or exemption requests are outstanding for the spurious actuation concerns of the service water discharge line valves:

SW2929, 2930, 2931 and 2932. One of the service water discharge line valves is administratively controlled open and depowered in order to ensure service water discharge. Consequently, a fire would not result in a loss of service water due to spurious actuation of the valves.

However, the CAR previously identified two procedure l revisions (Fire Areas DD/FF and U) and one physical modification (Fire Area CC) to resolve the outstanding spurious actuation concerns regarding the PORV and its block valve (RC-2A and RC-11). The CAR also previously l identified two procedure revisions (Fire Areas D and DD/FF) to resolve the outstanding spurious actuation enneerns regarding the letdown cooler isolation valves (MU 01A,B; MU 02A,B and MU 01). The CAR reflects that these procedure revisions and modifications have been completed.

Toledo Edison's evaluation regarding high-low pressure interfaces, documented in Serial No. 1497, describes the need for fire protection features in accordance with Appendix R,Section III.G.2 for the circuits of the PORV and its block valve in Fire Area D. This evalua-tion also concluded that manual operator action would be required to mitigate a short-term breach of the high-low pressure interface before an unrecoverable

Dock t No. 50-346  !

License No. NPF-3 Serial No. 1-835 September 30, 1988 Attachment 1 plant condition would occur. These short-term breaches j could occur at the letdown valves, the PORV and its block valve, and the RCS sample valves. As stated in Serial No. 1497, Toledo Edison will complete an evalua-tion of the time before an unrecoverable plant condition would occur as a result of the postulated breach and confirm that the associated manual operator actions to .

isolate these breaches are consistent with NRC guidance. I Subbequent to IR 83-16, NRC Region III follow-up inspections documented in IR 85-028, dated November 22, 1985 (Log No. 1-1280), and IR 86-06, dated February 28, 1986 (Log No. 1-1342), have reviewed certain actions taken regarding this matter and have closed the noncompliance. However, as noted above, Toledo Edison is completing additional evaluations and corrective actions.

Date When Full Compliance Will be Achieved The aforementioned evaluation and any fire protection corrective actions are scheduled to be completed by restart from the sixth refueling outage, at which time full compliance will be achieved.

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l- Dsck2t No. 50-346 License No. NPF-3 Serial No. 1-835 September 30, 1988 Attachment 1 Noncompliance The auxiliary shutdown panel fails to provide one 83-16-02 train of systems needed for hot standby free from l fire damage. (83-16-02)

Updated Response: Acceptance or Denial of the Alleged Noncompliance Toledo Edison accepts the alleged noncompliance.

Corrective Actions Taken and Results Achieved Specifically, IR 83-16, Paragraph 4.b addresses the potential loss of control and indication for the auxiliary feedwater pumps 1 and 2 at both the auxiliary shutdown panel and the control room due to a fire in Room 324, Fire Area R. The CAR documents the analysis performed for Fire Area R. The results of the analysis indicate that both Auxiliary Feedwater System (AFWS) l governor control valves required to regulate and control the speed of the associated turbine may be subject to fire-induced failure.

The recommended corrective action proposed in the CAR is to provide alternative shutdown capability by manually aligning and starting the Motor Driven Feedwater Pump (HDFP) and locally operating the governor control valve. The MDFP has been installed and is physically and electrically independent of Fire Area R. The MDFP would be utilized after the normal and auxiliary feedwater capabilities are confirmed to be unavailable. MDFP instrumentation, such as discharge pressure and flow, are not necessary to achieve a safe shutdown in the event of a fire.

Procedure AB 1203.02, " Serious Station Fire Procedure,"

has been revised to manually align and start the MDFP and, as necessary, to manually operate the applicable governor valve locally in fire areas other than Fire Area R. However, Toledo Edison has evaluated the time beforc on unicto.cio'ule plant condition would occur if this manual operator action was not performed, as discussed in Toledo Edison letter dated June 6, 1988 (Serial No. 1535). As a result of this evaluation, Toledo Edison has determined that the need for this manual operator action would not be necessary subsequent to the installation of solenoid-operated flow control valves to the auxiliary feedwater system. The flow control valves would be operable from the Control Room despite a fire in Fire Area R and will be installed

i Dockat No. 50-346

. License No. NPF-3

. Serial No. 1-835 September 30, 1988 Attachment 1 prior to restart from the current fifth refueling.

outage. NRC Staff Reviewer, Mr.-D. J. Kubicki, while participant in an unannounced Region III inspection at Davis-Besse during the week of September. 12, 1988, stated that this noncompliance will be closed and the installation of the flow control valves will be treated as a separate issue.

Additionally, an exemption was requested from Appendix R,Section III.G.3 to obviate the need for fixed fire

.. suppression in Fire Area R. The exemption was requested' in Toledo Edison's letter dated January 12, 1987, Serial No. 1327.

Date When Full Compliance Will be Achieved Full compliance will be achieved upon NRC approval of the aforementioned exemption request.

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'Dodket No.'50-346

,Licensa No. NPF-3 Serial No. 1-835 September 30, 1988 Attachment.1 Noncompliance The auxiliary shutdown panel and transfer switch room 83-16-03 lacks a fixed fire suppression system. (83-16-03)

Updated Response: Acceptance or Denial of the Alleged Noncompliance Toledo Edison accepts the alleged noncompliance.

Corrective Action Taken and Results Achieved The CAR documents the analysis performed for the auxiliary shutdown panel and transfer switch room, Fire Area R. The results of the analysis indicate that. alternative shutdown capability is necessary for-the Auxiliary Feedwater System and Service Water System. The provisions for this alternative shutdown capability atr presented in Section 7 of the CAR. l However, Fire Area.R is not provided with a fixed fire suppression system. An exemption was requested from the requirements of Appendix R,Section III.G.3 to obviate the need for the fixed fire suppression system in Toledo Edison' letter dated January 12, 1987 (Serial No. 1327). NRC Staff Reviewer, Mr. D. J. Kubicki, while participating in an unannounced Region III inspection at Davis-Besse during the week of September 12, 1988, stated that this noncompliance will-be closed.

Date When Full Compliance Will be Achieved Full compliance will be achieved upon tbe NRC approval of the aforementioned exemption request.

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i Docket No. 50-346

. Licznse No. NPF-3 Serial No. 1-835

. September 30, 1988 Attachment 1 Noncompliance Lack of a J-hour fire barrier in various conduits and 83-16-11 junction boxes in Rooms 314 and 328 (missing wrapping and partial wrapping) (83-16-11).

Updated Response: Acceptance or Denial of the Alleged Noncompliance Toledo Edison accepts the alleged noncompliance.

Corrective Action Taken and Results Achieved Room 314 is in Fire Area DJ, and Room 328 is in Fire Area T. As documented in the CAR, these fire areas were analyzed and proposed modifications and procedure revisions were determined necessary to bring Fire Areas DJ and T into compliance with 10CRF50, Appendix R.

However, no outstanding fire barrier modifications for l Fire Area T are identified by the CAR and one circuit (IPBE1234A) located in Fire Area DJ was identified to require a fire barrier (CAR Section 4.DJ, Note 12).

As stated in Toledo Edison letter dated June 3, 1986 (Serial No. 1253), the physical modifications will be completed prior to the end of the sixth refueling outage. The procedure revisions have been completed.

The following specific concerns were cited in Para-graphs 4h and 8b of IR 83-16:

a. In Fire Area T, Conduits 36010C, 37452A, 37450B, 47342B, 37474A and 37035A were without fire barriers that totally enclosed the equipment.

b. In various locations, temperature and flow monitoring instrumentation was not protected by a fire barrier.

c. Junction boxes JB 3715, JB 3716 and JB 3718 were not protected by a fire barrier.

d, in Fire _ Area T, conduits 36011A, 36203A and 36111A containing the power cables for the CCW pumps were not protected by a fire barrier.

I e. Conduits located in Room 53 and needed for the operation of Service Water System valves SW-2929, SW-2930, SW-2031 and SW-2032 were found to have worn Kaowool wrapping and, in one case, the Kaowool wrapping for Conduit 30526 was incomplete.

Dockst No. 50-366 1 ' - Lic:nsa No. h?F-3 Serial No. 1-835 September 30, 1988 Attachment 1 As a result of the CAR analysis, the following resolu-tions have been developed for these specific concerns cited in IR 83-16, Paragraphs 4h and 8b:

a. Conduit Resolutions 47342B Does not contain circuits required to satisfy Appendix R.

37035A No physical modifications or 37452A procedure revisions are necessary since their fire-induced failure would be inconsequential.

37450B No physical modifications or procedure revisions are necessary since its redundant train is-accredited for safe shutdown.

36010C Has been verified to be wrapped with a fire barrier during NRC Region III follow-up inspection as documented in IR 84-10, dated July 5, 1984 (Log 1-988).

37474A Will not be wrapped with a fire barrier but a revision to procedure AB 1203.02, " Serious Station Fire Procedure," has been made to I establish temporary component cooling water pump room ventilation  !

as an alternative shutdown capa-bility. In letter dated June 6, 1988 (Serial No.1535), Toledo Edison has committed to verify that the time available to implement this alternative shutiown capability will satisfy NRC guidance for manual nperator actions.

b. The numerous monitoring instruments considered as safe shutdown components are listed in Appendix A of the CAR. Section 4.DJ of the CAR describes that an HPI flow indication will be installed at the alternate shutdown panel and a backup means of steam generator outlet pressure indication will be established in the Control Room to resolve deficiencies in Fire Area DJ.

Section 4.T of the CAR indicates that no modifications are required for monitoring instrumentation in Fire Area T.

f Dsekat No. 50-346 L c. Licensa No. NPF-3 P Serial No. 1-835 September 30, 1988 Attachment 1 1

'c. Junction boxes JB3715, JB3716 and JB3718 have been wrapped and so verified by an NRC Region III follow-up inspection documented in IR 84-10, dated July 5,1984 (Serial 1-988).

d. The component cooling water pumps (CCWP) as well as their power circuits contained in conduits 36111A, 36203A and 36011A are located in Fire Area T. In letter dated November 23, 1982 (Log No. 1138), the NRC granted an exemption from Appendix R to obviate the need for one-hour fire barriers for components in Fire Area T. These conduits are. considered to be part of the CCWP and are addressed by this approved exemption.

e. Room 53 is located in Fire Area II. For a fire in this area, one of the Service Water System valves, SW'2929, 2930, 2931 or 2932, must be open to ensure service water discharge. One of these valves is administratively controlled open and depowered.

Consequently, a fire in this area would not affect the safe shutdown function of the valves, and their related conduits and raceways do not require a fire.

barrier.

Date When Full Compliance will be Achieved As stated on Toledo Edison letter dated ' June 3,1986 (Serial No. 1253), the physical modifications will be completed by the end of the sixth refueling outage.

D:ck;t No. 50-346

• Lic nsa No. NPF-3 Serial No. 1-835 September 30, 1988 Attachment 1 Noncompliance Failure to control modifications to fire doors (83-16-15) 83-16-15 Updated Response: Acceptance or Denial of the Alleged Noncompliance Toledo Edison accepts the alleged noncompliance.

Corrective Action Taken and Results Achieved In letter dated May 27, 1987 (Serial No. 1361),

Toledo Edison has evaluated the effect that previous security modifications have had on the fire rating of .

fire doors.

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,r Revision 1, dated October 29, 1986.

To control future modifications and maintenance on fire doors, administrative procedures now direct Maintenance Work Orders af_^ecting fire doors to be reviewed by the fire protection coordinator and require an operability inspection. Periodic Test,

""! 16.15, =hi.h un ap p..ml x _'anacry 21, 126;,

previously provided the door inspection criteria. That PT has been replaced by Procedurer DB-FP-03026, DB-FP-03027, and DB-FP-03028, which are the implementing procedures for the Technica" Specification surveillance requirements.

^~

Docket N'o.--50-346

. , . = License No. NPF-3:

Serial No. 1-835' Sep tembe r.. 30, 1988'.

Attachment:

1 NRC ' Staff Reviewer, Mr. D, J. Kubicki', while parti-cipating.in an unannounced Region III inspection

'at Davis-Besse during the week of September 12,~1988, stated that this noncompliance will be closed.

-D.ite When Full Compliance will be Achieved Full compliance has been ach'ieved. l 2

19

____x_:__---_ . _ - _ - - _ _ - - _ _ _ _ _ - _ .__:_-.

Docket No. 50-346

.. License No. NPF-3 l- - Serial No. 1-835 l

September 30, 1988 l . Attachment 1 Noncompliance Failure to develop and implement adequate ' surveillance 86-13-22B test procedures for fire protection system valves operability (86-13-22B)

Updated Response: Accept ance or Denial of the Alleged Noncompliance -

Toledo Edison accepts the alleged noncompliance.

Corrective Actions Taken and Results' Achieved Toledo Edison has evaluated its program for providing supervision of fire protection system valves. This program was revised to inspect locked valves on a l monthly basis and unlocked valves on weekly basis.

NRC Staff Reviewer, Mr. D. J. Kubicki, while parti-

.cipating in an unannounced Region. III inspection at Davis-Besse during the week of September 12, 1988, ~

stated that this noncompliance will be closed.

Date When Full Compliance will be Achieved Full compliance has been achieved.

d

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