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{{Adams
#REDIRECT [[L-17-253, Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805]]
| number = ML17284A190
| issue date = 10/09/2017
| title = Davis-Besse Nuclear Power Station, Unit No. 1, Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 (CAC No. MF7190)
| author name = Bezilla M B
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000346
| license number = NPF-003
| contact person =
| case reference number = CAC MF7190, L-17-253
| document type = Letter, Response to Request for Additional Information (RAI)
| page count = 170
| project = CAC:MF7190
| stage =
}}
 
=Text=
{{#Wiki_filter:FE NOC Mark B. Bezilla Vice President -Nuclear October 9, 2017 L-17-253 A TIN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUBJECT: Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 5501 Norlh State Route 2 Oak Harbor, Ohio 43449 419-321-7676 Fax:419-321-7582 Supplemental Information Regarding License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 (CAC No. MF7190) By letter dated December 16, 2015 (ADAMS Accession No. ML 15350A314), as supplemented by letters dated March 7, 2016, July 28, 2016, 16, 2016, January 17, 2017, and June 16, 2017 (Accession Nos. ML 16067A195, ML 16210A422, ML 16351A330, ML 17017A504, and ML 17170AOOO respectively), FirstEnergy Nuclear Operating Company (FENOC) submitted a license amendment request (LAR) to change the Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1 fire protection program to one based on the National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition. , In previous responses to the Nuclear Regulatory Commission (NRC) staff's questions during the review process, FENOC indicated that revisions to attachments G, K, L, S, and W in the license amendment request would be provided in future submittals. Updates to LAR attachments G and Ware currently being finalized, and FENOC plans to submit these updated attachments with the response to probabilistic risk assessment question 03 (Accession No. ML 16256A066). The enclosures to this letter replace, in their entirety, the following December 16, 2015 LAR attachments:
* LAR Attachment K -Existing Licensing Action Transition
* LAR Attachment L -NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii))
* LAR Attachment S -Modifications and Implementation Items LAR Attachment K has been annotated to identify changes made consistent with previous FENOC responses to NRC requests for additional information (denoted by /r D O Lf "RAI" in the right-hand margin). The following changes have been made to LAR Attachment K: -
Davis-Besse Nuclear Power Station, Unit No. 1 L-17-253 Page 2
* Licensing Action No. 2, CCW [component cooling water] Pump Separation, has been updated in accordance with the response to safe shutdown analysis (SSA) question No. 12.
* Licensing Action No. 15, Fireproof Coating for Structural Steel, has been added in accordance with the response to fire protection engineering (FPE) question No. 07.
* New licensing action Nos. 16.01 through 16.10 have been added in accordance with the response to FPE question No. 05. LAR Attachment L has been annotated to identify changes made consistent with previous FENOC responses to NRG requests for additional information (denoted by "RAI" in the right-hand margin), or other licensee-identified updates by FENOG (denoted by "UC" in the right-hand margin). The following changes have been made to LAR Attachment Lin response to the RAI questions:
* Approval Request No. 2 has been updated in accordance with the response to FPE question No. 04.01.
* Approval Request No. 4 has been updated in accordance with the response to FPE question No. 06.
* Approval Request No. 8 has been withdrawn in accordance with the response to SSA question No. 12.
* Approval Request No. 11 has been added in accordance with the response to FPE question No. 03. The following licensee-identified updates have been made to LAR Attachment L:
* LIC(1) -Added accession number for the safety evaluation report.
* LIC(2) -Approval Request No. 9 was added due to a change in fire detection type in the containment building.
* LIC(3) -Approval Request No. 10 was added for adequate-for-the-hazard compliance associated with NFPA 30, 1990 edition, "Flammable and Combustible Liquids Code," code compliance review for the diesel fuel tank T210 inside the station blackout building.
* LIC(4) -Approval Request No. 12 was added for adequate-for-the-hazard compliance associated with NFPA 30 code compliance review for the lube oil , storage tank.
* LIC(5) -Approval Request No. 13 was added for adequate-for-the-hazard compliance associated with NFPA 30 code compliance review for the emergency diesel generator fuel oil day tanks in the auxiliary building.
* LIC(6) -Approval Request No. 14 was added for adequate-for-the-hazard compliance associated with NFPA 30 code compliance review for the emergency feedwater facility.
Davis-Besse Nuclear Power Station, Unit No. 1 L-17-253 Page 3 An updated LAR Attachment S is submitted without the changes annotated. The following changes have been made to LAR Attachment S:
* Updated Table S-1, Plant Modifications Committed, with DB-2061 in accordance with the response to SSA question No. 12.
* In accordance with the responses to FPE question No. 01 and SSA question No. 01, the following items have been updated or added to Table S-2, Implementation Items: DB-0779; DB-0540; DB-1825; DB-1838; DB-1900; DB-1912; DB-1964; DB-2041; DB-2049; and DB-2050.
* Updated the Table S-2 item DB-1825 description in accordance with the response to FPE question No. 06'.
* In accordance with the response to .FPE question No. 05, the following items have been added to Table S-2: DB-2053; DB-2054; DB-2055; DB-2056; and DB-2057.
* Added the Table S-2 item DB-2062 in accordance with the response to FPE1 question No. 02.
* Added the Table S-2 item DB-2063 in accordance with the response to FPE question No. 03.
* Removed the implementation period discussion at the top of Table S-2.
* Added Table S-3, Plant Modifications Completed, and moved items DB-1983 and DB-2010 from Table S-1 to Table S-3. FENOC also requests a change to the specific activities required for implementation of the license amendment. The December 16, 2015 letter requested that the specific activities listed in LAR Attachment S, Table S-2 be completed within 180 days following issuance of the license amendment, unless the 180-day period ended during a scheduled refueling outage. It is hereby requested that the specific activities be completed within one year following issuance of the license amendment request. Additional time is requested to coordinate development of NFPA Standard 805 FENOC fleet procedures with the Beaver Valley Power Station. The NFPA 805 fire protection program modification and specific activity schedules were reflected in Section 5.5 of the LAR, and LAR Attachment S, Table S-2, Implementation Items. The enclosed LAR Attachment S has been updated to remove the implementation item timeframe discussion. Section 5.5 of the LAR is hereby changed to: The following schedule for transitioning DBNPS to the new fire protection licensing basis requires NRC approval of the LAR in accordance with the following schedule:
* Implementation of the new NFPA 805 fire protection program to include procedure changes, process updates, and training to affected I _J Davis-Besse Nuclear Power Station, Unit No. 1 L-17-253 Page4 plant personnel. This will occur within one year following issuance of the license amendment. See LAR Attachment S, Table S-2.
* LAR Attachment S, Table S-1 provides a listing of plant modifications associated with the transition to NFPA 805. Modifications will be 1 completed by the startup of the first refueling outage following issuance of the license amendment. Appropriate compensatory measures will be maintained until modifications are complete. Finally, during a public meeting on September 12, 2017, the NRC requested additional information to complete its review. The FENOC response is attached to this letter. The information provided by this submittal does not invalidate the significant hazards consideration analysis provided in the December 16, 2015 letter. There are no regulatory commitments included in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -Fleet Licensing, at (330) 315-6810. I declare under penalty of perjury that the foregoing is true and correct. Executed on October -1-* 2017. Attachment: Response to Request for Additional Information Enclosures: A. LAR Attachment K -Existing Licensing Action Transition B. LAR Attachment L -NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii)) -C. LAR Attachment S -Modifications and Implementation Items cc: NRC Regional Administrator -Region Ill NRC Resident Inspector NRC Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison) Utility Radiological Safety Board 
 
==Attachment==
L-17-253 Response to Request for Additional Information Page 1of2 The NRC staffs request for additional information is provided in bold text followed by the FENOC response. ! Based on the response to SSA RAI 07.01 (dated June 16, 2017), the licensee concluded that the current reactor coolant pump (RCP) seal model, though "simple," is considered sufficient because human failure events to trip the RCPs dominate the RCP seal failure sequences. However, the response did not provide sufficient information to allow a detailed review of the technical adequacy of the RCP seal model. As such, justify that the RCP seal model has no or minimal impact on the NFPA 805 application (i.e., change-in-risk estimates for transition and to support the self-approval of post-transition changes). In this justification, also discuss the possibility that conservative modeling assumptions made in the compliant plant model could artificially reduce the calculated change-in-risk associated with RCP seal related VFDRs. Response: In the current RCP seal model, seal failures account for approximately 14 percent of core damage frequency (CDF), and only occur if the operators fail to trip the RCPs after a loss of seal cooling and seal injection, or seal return. If, as a sensitivity study, an event is added to the model representing a 2.0E-4 probability of seal failure even after tripping the RCPs, CDF increases by 1.4 percent. The assumed seal failure probability is based on engineering judgement and considered bounding. Subsequent evaluations indicate that change in risk estimates for items related to seal injection and seal cooling, or seal return could increase by approximately 10 percent due to the increased probability of a seal loss-of-coolant accident (LOCA). However, change in risk evaluations for items related to tripping the RCPs would be reduced, due to the reduced effectiveness of that action. Change in risk evaluations for items unrelated to RCP seal LOCAs would not be impacted by a change to the seal modeling. Thus, the human failure events (HFEs) dominate the seal leakage model, and the addition of a seal failure probability after tripping the RCPs does not greatly impact the model results. 9 In variances from deterministic requirements (VFDRs) relating to a loss of seal cooling and seal injection, or seal return, the compliant cases were performed by setting the HFE for tripping the RCPs to false, thereby ensuring no seal failures occur. With no seal failures allowed to occur in the compliant case, it most likely underestimates compliant plant risk, since random, non-fire related failures that could cause RCP seal failures are also prevented in the compliant plant evaluation. Thus, the calculated change in risk is likely overestimated in those cases. For cases where the control cabling for the RCPs are impacted, which prevents tripping the pumps from the control 
 
==Attachment==
L-17-253 Page 2of2 room, the compliant plant case removed those failures from the model and allowed the pumps to be tripped from the control room. If the compartment also had VFDRs related to loss of seal cooling and injection, or seal return, the delta risk would likely be overestimated as stated above. If there were no VFDRs for the compartment related to seal cooling and seal injection, or seal return, then tripping the RCPs would only be done in response to random, non-fire related failures of the seal support systems. Since fires in those cases do not induce conditions to require tripping the RCPs, the modeling provides a direct comparison of the risk, and does not underestimate compliant plant risk.
r L --------Enclosure A L-17-253 LAR Attachment K -Existing Licensing Action Transition (94 pages follow)
FE NOC K. Davis-Besse Attachment K -Existing Licensing Action Transition Existing Licensing Action Transition 93 Pages Attached Page K-1 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 1: Fire Compartments FF-01, FF-02, and FF-03 '-An exemption has been approved from Section 111.G.3 to the extent it requires full, fixed fire suppression in an area for which alternate shutdown capability is provided. The alternate shutdown capability is physically and electrically independent of Fire Compartments FF-01, FF-02, and FF-03. Basis Date: 11 /23/1982 To Be Transitioned? No Basis: 111.G.3 requires that alternate or dedicated shutdown capability be protected by smoke detection and a fixed fire suppression system. In addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration. The Control Room (Appendix R Fire Area FF) does not comply with Section 111.G.3 because it is not provided with an automatic suppression system. DBNPS submitted an exemption request on April 29, 1982, (Serial No. 815) requesting an exemption from Section 111.G for the lack of fixed fire suppression system in the Control Room. The NRC issued an SER dated November 23, 1982, (Log No. 1138) that stated, in part, " ... the installation of a fixed fire suppression system will not increase significantly the level of fire protection safety in the control room, .... " The exemption was granted due to the Control Room/cabinet room containing the following features: 1. Continuous manning 2. Area fire detectors 3. Internal cabinet fire detectors for safety-related control panels 4. Hose station 5. Fire extinguishers 6. Low fire load 7. Alternate shutdown system is available, which provides remote control capabilities for those systems necessary to maintain SSD capability from outside the Control Room 8. Control Room operators are qualified firefighters Davis-Besse Page K-2 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 1: Fire Compartments FF-01, FF-02, and FF-03 Fire Compartment Description FF-01, FF-02, and FF-03 Control Room/Cabinet Room Reference Document
* Log No. 1138, SER dated November 23, 1982, "Appendix R to 10 CFR 50, Exemption From Certain Technical Requirements"
* Serial No. 815, "Topic: Appendix R Request for Exemptions in Control Room and Component Cooling Water Room, April 29, 1982" Evaluation: The November 23, 1982, (Log No. 1138) SER stated that the fire protection features currently installed in the Control Room/cabinet room and the continuous manning of the Control Room provide adequate DID firefighting capability for these areas. The licensee has stated that the Control Room/cabinet room is equipped with area fire detectors and internal cabinet fire detectors for safety related control panels. The Control Room/cabinet room is provided with both a hose station and fire extinguishers for manual firefighting, and the fire load in the area is low. In addition, an alternate shutdown system is available, which provides remote control capabilities for those systems necessary to maintain SSD capability from outside the Main Control Room. Plant Technical Specifications require continuous occupancy of the Control Room by the operators. Because the operators constitute a continuous fire watch, manual fire suppression in event of a fire would be prompt and effective, and thus, a fixed suppression system is not necessary to achieve adequate fire protection in this area. Validation/Conclusions: This exemption is no longer necessary, as Fire Compartments FF-01, FF-02, and FF-03 (Appendix R Fire Area FF) will be evaluated using the performance-based approach as identified in NFPA 805 Section 4.2.4. As such, the existing exemption will not be transitioned into the NFPA 805 license basis. Associations: None Davis-Besse Page K-3 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 2: CCW Pump Separation An exemption has been approved from Section 111.G.2 to the extent that it requires separation of redundant SSD components with a 1-hour rated fire barrier where less than 20 feet of separation exists. The CCW pumps are not separated by a 1-hour rated fire barrier. Basis Date: 12/26/2002 To Be Transitioned? Basis: This e:xemption requires NRC apprcv.'81 and is being submitted in lAR Att. b as Appro,.'81 Item B. OnGe appFOJJed, this liGensing aGtion will be Gompliant under 1 O CFR 50.48(G). Fire Compartment T-01 (Appendix R Fire Area T) does not comply with Section 111.G.2 because 1-hour fire barriers have not been installed between the CCW water pumps, and the separation is less than 20 feet between them. DBNPS submitted an exemption request on April 29, 1982, (Serial No. 815) requesting an exemption from Section 111.G for the lack of 20-foot separation between the CCW pumps. The NRG issued an SER dated November 23, 1982, (Log No. 1138) that stated, in part, " ... the installation of rated fire barriers between the component cooling water pumps will not increase significantly the level of fire protection in the component cooling water heat exchanger and pump room." On December 21, 2000, DBNPS submitted a letter (Serial No. 2680) that requested an amendment of an exemption approved by the NRG in Log No. 1138. The letter referenced DBNPS letter dated March 15, 1989 (Serial No. 1642) when it stated, "The letter noted that the manual operator action to establish temporary ventilation in the CCW pump room in the event of a fire is no longer considered necessary since the CCW pumps would not overheat despite the fire and postulated loss of the CCW pump room ventilation." The amended exemption request was approved by the NRG in a letter dated December 26, 2002 (Log No. 6041 ). The exemption stated, "The licensee concluded that since the sprinkler system operated at 165 °F, the sprinkler system would keep the pumps from reaching 185 °F, allowing the pumps to remain operational." In another letter dated December 14, 2004, (Serial No. 3105) DBNPS indicated that the temperature cited in Log No. 6041 was incorrect. DBNPS had installed a new sprinkler system in the CCW pump room, and the fusible links in the new system actuate at 212 degrees F. DBNPS performed an engineering evaluation and confirmed that the technical basis for the December 26, 2002, exemption remained valid. Davis-Besse Page K-4 lssA RAI 12 FE NOC Attachment K-Existing Licensing Action Transition
* Licensing Action 2: CCW Pump Separation The exemption was granted. A review performed for NFPA 805 found the features in the CCW pump room support approval of a revised basis for this exemption, as explained in Attachment L, Approval Item 8. Once approved, this licensing action will be compliant under 10 CFR 50.48(e). Fire Comparbnent Description T-01 CCW Pump Room Reference Document
* Log No. 1138, "Appendix R to 1 OCFR50 -Exemption From Certain Technical Requirements"
* Log No. 6041, "Exemption from the Requirements of 10 CFR 50, Section 111.G of Appendix R"
* Serial No. 815, "Topic: Appendix R Request for Exemptions in Control Room and Component Cooling Water Room, April 29, 1982"
* Serial No. 1642, "Fire Protection -Manual Operator Actions"
* Serial No. 2680, "Request to Amend the Existing Exemption for Component Cooling Water Heat Exchanger and Pump Room"
* Serial No. 3105, "Updated Information Regarding the Existing Exemption from 10 CFR 50 Appendix R, for the Component Cooling Water Heat Exchanger and Pump Room" Evaluation: The exemption (Log No. 6041) states: The SSD requirements at DBNPS require at least one CCW pump to remain operational during and after a fire. The November 23, 1982, exemption allowed less than 20 foot separab"on and no fire barriers between the CCW pumps. This was based on the existence of adequate active and passive fire protection features that provided reasonable assurance that one CCW pump would remain operational The active protection features were smoke detectors, a wet pipe sprinkler system, a manual hose station, and portable fire extinguishers. The passive fire protection features provided were: low in-situ combusbble loading, minimal intervening combustibles, and curbing around the pumps to contain an oil spill fire, in addition to the fire wrap that is the subject of the current exemption request Davis-Besse Page K-5 issA RAI 12 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 2: CCW Pump Separation Active fire protection features have not changed since the granting of the existing exemption and combustible loading remains low. Under the re-evaluations discussed earlier, protection of CCW header valves and ventilation circuits is not necessaty in order for at least one CCW pump to remain operational during and after a fire. Modifications have changed the SW valves to fail safe and removed circuits that would cause a spurious pump trip. In summaty, DBNPS has demonstrated reasonable assurance of the availability of CCW during and after a postulated fire in the CCW pump room, notwithstanding less than 20 foot separation between the CCW pumps, the absence of fire barriers and no fire wrap on the SSD cables and valves in the CCW pump room. Therefore, under these circumstances, the underlying purpose of the regulation is still achieved The exemption concludes: On the basis of the staff review and evaluation of the information provided in the licensees request to amend the existing exemption, the staff concludes that the request for exemption from the technical requirements of Section Ill. G.2 of Appendix R to 10 CFR Part 50 demonstrates that under the proposed alternative circumstances from original circumstances that existed at the time the existing exemption was granted, the underlying purpose of the regulation is still achieved Thus, the NRC staff has determined that there are special circumstances as specified in 10 CFR 50. 12(a)(2)(ii), in that application of Section Ill. G2 of 10 CFR Part 50, Appendix R is not necessaty in order to achieve the underlying purpose of the regulation. The staff has further determined that the exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. Accordingly, the Commission hereby grants the requested exemption, which supersedes the November 23, 1982, exemption, based on the circumstances set forth herein. Validation/Conclusions: Conformance with the Appendix R exemption agreements reached with the NRG regarding cable separation 111.G.2 jssA RAI 12 criteria, as stated in NRG exemption dated December 26, 2002, was reviev1ed and three exemption bases statements have changed. These bases incl1:1de 1) the amo1:1nt of l1:1bricating oil in Compartment T 01 is increased from six gallons to nine gallons, 2) the type of l1:1bricating oil in the CC'/V p1:1mps is updated; ho'.vever, the oil flash point decreased from 450°F to approximately 400° F and 3) the combustible loading in T 01, while still low, is being increased above 1,375 BTU/ft2-ta approximately 10,000 BTU/ftZ-;-Davis-Besse Page K-6 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 2: CCW Pump Separation. Validation of the exemption bases for this licensing action *.vas performed by revie1Ning station controlled procedures, drm.*Jings, and design control process documentation. Since three of the exemption bases have changed, LA 02 is included in Att. L as Approval Request 8 and requires NRG approval for transition to the NF'PA 805 Licensing Basis. With approval of LAR Attachment L Approval Item 8, this licensing action 1Nill be compliant under 10 CF'R 50.48(c). The separation between the CCW pumps will be evaluated using the performance-based approach as identified in NFPA 805 Section 4.2.4. As such. the existing exemption will not be transitioned into the NFPA 805 license basis. Associations: Ch.4 Compartment: T 01 I Subsection: F'ire Protection F'ire Compartment: A 05 I F'orm: Passive Protection F'ire Protection F'ire Compartment: AB 01 I F'orm: Passive Protection F'ire Protection F'ire Compartment: CC 01 I F'orm: Passive Protection F'ire Protection F'ire Compartment: G 02 I F'orm: Passive Protection F'ire Protection F'ire Compartment: II 01 I Form: Passive Protection F'ire Protection F'ire Compartment: T 01 I F'orm: Detection F'ire Protection F'ire Compartment: T 01 I F'orm: Passive Protection F'ire Protection F'ire Compartment: T 01 I F'orm: 'Nater Based Suppression F'ire Protection F'ire Compartment: U 01 I F'orm: Passive Protection F'ire Protection F'ire Compartment: UU 01 I F'orm: Passive Protection None Davis-Besse Page K-7 issA RAI 12 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 3: Fire Door 215 Equivalent Protection An exemption has been approved from Section 111.G.2 to the extent it requires separation of redundant SSD components by a fire barrier having a 3-hour rating. Door 215 between the two fire areas is not 3-hour rated but provides an equivalent level of proteCtion. Basis Date: 08/20/1984 To Be Transitioned? Yes Basis: Fire Compartments E-01 and F-01 (Appendix R Fire Areas E and F) do not comply with 111.G.2 because Door 215 is not a 3-hour fire-rated barrier as required. DBNPS submitted an exemption request on September 30, 1983, (Serial No. 991) and provided supplemental information on December 30, 1983, (Serial 1015) because Door 215 is not a 3-hour rated fire barrier. An NRC letter dated August 20, 1984, (Log No. 1586) was received that approved the requested exemption. It stated the following: Subsection Ill. G.2 of Appendix R to 10 CFR 50 requires that redundant trains of equipment necessary for safe shutdown be separated by one of three specific methods to ensure that one of the redundant trains of equipment will be free of nre damage. . One of the methods specified is separation by a fire barrier having a 3-hour rating including all piping, electrical, heating, ventilation, and air conditioning penetrations and personnel access doors. The licensees have requested an exemption from the requirement for a 3-hour rated barrier with respect to a door which separates rooms containing equipment necessary for safe shutdown. The Davis-Besse Nuclear Power Station is equipped with two auxiliary feedwater (AF/111 pumps located in adjacent rooms (Room 237 in Fire Area E, Fire Zone No. E-1 and Room 238 in Are Area F, Fire Zone F-1) separated by a 3-hour rated nre wall. Door 215 located in the fire wall separating the two rooms is designed as a pressure rated door (10 psi) to protect against the consequences of a high energy line break in either AFW pump room. The door, however, is not a UL rated fire door and has not been tested by the licensees. Instead, an engineering evaluation has been performed to determine the fire resistance of Door 215, simulating the nre test requirements of NFPA 251. The evaluation demonstrates that the door would permit a temperature rise on the unexposed face of 250°F when subjected to a 1300°F nre exposure for 25 minutes. The licensees have determined that the combustible material in either pump room would have a nre duration of less than 10 minutes. The licensees conclude that the door, if tested, would have a nre resistance signincant/y longer than the maximum postulated fire duration. We Davis-Besse Page K-8 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 3: Fire Door 215 Equivalent Protection have reviewed the analysis and agree with the licensees. Due to the low fuel load in the area and installed smoke detection system, there is reasonable assurance that an incipient nre would be detected promptly, and the response of the fire brigade to the AFW pump room would be expected in less than 25 minutes. It is our opinion that this combination of features provides reasonable assurance that one train of AFW pumps will remain free of fire damage. Based on our evaluation, Fire Door 215 provides a level of safety equivalent to the technical reqwrements of Section Ill. G and, therefore, the exemption requested is granted Fire Compartment E-01 and F-01 Reference Document Description Auxiliary Feedwater Pump Rooms ---* A-222F, Revision 16, "Fire Protection General Floor Plan EL. 565'-0""
* A-87, Revision 61, "Architectural Door Schedule"
* C-FP-013.06-023, "Fire Doors"
* C-FP-013.10-006, Revision 4, "Combustible Loading Analysis"
* CR-2012-05848, Revision 0, "Combustible Loading in AFW Pump Rooms May Exceed NRC Approved Exemption Request"
* DB-FP-00005, Revision 7, "Fire Brigade"
* E-892, Revision 9, Sheet 6, "Raceway-Fire Alarm System Auxiliary Building Plan EL. 565"
* FHAR, Revision 24, "Fire Hazards Analysis Report"
* Log No. 1586, "Exemption From Certain Requirements of Appendix R to 1 OCFR50"
* Serial No. 1015, "Topic: Evaluation in Support of Door Exemption Request, December 30, 1983"
* Serial No. 991, "Topic: Appendix R Exemption Requests, September 30, 1983"
* Spec 7749-A-2, Revision 6, "Delivery and Installation of Pressure Doors" Davis-Besse Page K-9 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 3: Fire Door 215 Equivalent Protection Evaluation: The NRG letter dated August 20, 1984, stated, "Based on our evaluation, Fire Door 215 provides a level of safety equivalent to the technical requirements of Section 111.G and, therefore, the exemption requested is granted." Validation/Conclusions: Conformance with the Appendix R exemption agreements reached with the NRG regarding separation of redundant SSD components by a fire barrier having a 3-hour rating; 111.G.2 criteria, as stated in NRG exemption dated August 20, 1984, has been verified. The as-built plant configuration verification process consisted of walkdowns, review of current plant procedures, plant drawings, and the design change control process documentation. Based on NRG exemption dated August 20, 1984, (Log No. 1586) the following criteria was selected for validation in order to carry this exemption forward. Validation was performed by review of station records as identified below. The validation findings support transition of the exemption. _ 1. Door 215 is a pressure-rated door (10 psi). Drawing A-87, "Architectural Door Schedule," lists Door 215 as a pressure door of Fire Rating "A CONST" (Construction). Technical Specification for the furnishing, delivery, and installation of pressure doors, Spec 7749-A-2 includes the 10 psi peak incident pressure requirement. 2. An engineering evaluation has been performed to determine the fire resistance of Door 215, simulating the fire test requirements of NFPA 251. Verify that the evaluation demonstrates that the door would permit a temperature rise on the unexposed face of 250 degrees F when subjected to a 1300 degrees F fire exposure for 25 minutes. An engineering evaluation, contained within Serial No. 1015, demonstrated the door would permit a temperature rise on the unexposed face of 250 degrees F when subjected to a 1300 degrees F fire exposure for 25 minutes. The evaluation concluded 25 minutes to be "a sufficiently long time to allow for the fire brigade to take counter measures and have the situation under control." 3. The combustible material in either pump room would have fire duration of less than 10 minutes. The fire severity in both rooms is not less than 10 minutes. It is over 10 minutes in both rooms. Per Appendix 12 of C-FP-013.10-006, the loading in Fire Area E is 19,380 Btu/ft2 or 14.53 minutes; the loading in Fire Area F is 13,542 Btu/ft2 or 10.16 minutes. The NRC's approval of the exemption does reflect that the licensee indicates a 10-minute duration, but their conclusion indicates that the condition is acceptable because of "low fuel load" Davis-Besse Page K-10 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 3: Fire Door 215 Equivalent Protection (among other things). Times were calculated using a conversion factor of 80,000 Btu/ft2 = 1 hour as stated in the NFPA Handbook, Table 18.1.1. Per walkdowns completed October 2010 and June 2011, these fire compartments have detection and are separated by Fire Door 215. The NRC's approval of the exemption was based on a number of features taken together (i.e., "combination of factors"). Combustible loading in the room was just one of the factors. It was also that any fire would be detected quickly and that the brigade would respond quickly. They did not state that their approval was based on the fire duration being less than 10 minutes; rather they stated that it was based on "low fuel loading." While there is no standard industry definition for low combustible loading, it can still be argued that both the previous values and the current values both are still a fraction of an hour and thus still "low." Thus the exact fire loading values in the room can vary without exceeding our licensing basis as long as the fire severity can be considered low. While the combustible loading values as currently calculated exceed the 10 minute duration, the hazards in the room have not changed. Door 215 is still expected to provide "reasonable. assurance that one train of AFW pumps will remain free of fire damage." Thus DBNPS remains within the current design and licensing basis. 4. Door 215 has a fire resistance significantly longer than the maximum postulated fire duration. A fire severity of -15 minutes (see Item 3 above) is less than the 25 minutes discussed in Item 2 above and less than the 3-hour fire rating for Door 215 evaluated in the Factory Mutual report attached to C-FP-013.06-023. 5. Fire areas E and F have smoke detection FHAR Section 4.6.E.4 states, "Fire Area E consists of Room 237 which has fire detection." Section 4.6.F.4 states, "Fire Area F consists of Room 238 which has fire detection (Fire Detection Zone 238)." Table 8-3 Fire Detection Systems spells out that four smoke detectors are installed in Fire Area E and F. Drawings A-222Fand E-892, Sheet 6, show four fire detectors in Code compliance of detectors is discussed in LAR Attachment A in accordance with NFPA 805 Section 3.8.2. 6. The fire brigade response would be less than 25 minutes. Procedure DB-FP-00005, "Fire Brigade," includes Attachment 4, "Fire Brigade Drill Assessment." The acceptance criteria for the brigade's timely arrival include assembling at the scene of the simulated fire and commencing discussion of firefighting agent application within twelve minutes. A note states: "Elapsed time in excess of 15 minutes will be considered unsatisfactory drill performance." Davis-Besse Page K-11 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 3: Fire Door 215 Equivalent Protection In conclusion, although the information has been updated over time, the bases for previous acceptance are still valid, and the exemption for separation of redundant SSD components by a fire barrier having a 3-hour rating will be transitioned to the new licensing basis under NFPA 805. Associations: Ch. 4 -Compartment: E-01 Ch. 4 -Compartment: F-01 Fire Protection -Fire Compartment: E-01 I Form: Detection Fire Protection -Fire Compartment: E-01 I Form: Passive Protection Fire Protection -Fire Compartment: F-01 I Form: Detection Fire Protection -Fire Compartment: F-01 I Form: Passive Protection Davis-Besse Page K-12 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 4: Fire Compartments A-04 and A-05 An exemption has been approved from Section 111.G.2 to the extent it requires separation of redundant SSD components by a 3-hour rated fire barrier. Specifically, Train 1 circuits in Rooms 123 and 124 are not separated from Train 2 circuits in Room 115 by a complete 3-hour rated barrier. Basis Date: 04/18/1990 To Be Transitioned? No Basis: The licensee requested an exemption (Serial No. 1327) from Section 111.G.3 of Appendix R because Fire Compartments A-04 and A-05 (Appendix R Fire Area A) do not comply with Section 111.G.2. The separation is less than 20 feet between redundant trains of SSD equipment. After a request for additional information and a meeting with the NRC, DBNPS clarified the site's position in a follow-up letter, Serial No. 1361. The NRC stated in its exemption (Log No. 3219) the following information: For Fire Area A (Item 4 of the table above), the licensee has requested an exemption from the requirement of Section Ill. G 2 a of Appendix R which requires in part that cables and equipment and associated nonsafety circuits of redundant trains be separated by a fire bamer having a 3-hour rating. While there are, in general, 3-hour fire barriers in Fire Area A between redundant circuits used to achieve and maintain hot shutdown conditions, there are a number of non rated fire walls bounding some of the rooms within this subject area. Specifically, the Train 1 safe shutdown circwls in Room Nos. 123 and 124 are not completely separated from the Train 2 circwls in Room No. 115 by a 3-hour fire barner. The licensees basis for its request for an exemption for Fire Area A is that the present level of fire protection is acceptable since smoke and heat from a fire would have to travel between redundant circuits via a complicated path through locations which are partly protected by an automatic sprinkler system in order that a fire in the vicinity of one train could also damage the redundant train. This complicated path derives from the layout of Fire Area A which is a complex of a number of individual rooms encompassing more than one elevation within the plant Fire Comparbnent Description A-04 and A-05 ECCS Pump Room 1-2 and Clean Waste Receiver Tank Room Davis-Besse Page K-13 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 4: Fire Compartments A-04 and A-05 Reference Document
* FHAR, Revision 24, Fire Hazard Analysis Report
* Log No. 3219, Exemption dated April 18, 1990, "Exemption to 10 CFR Part 50, Appendix R, Section 111.G & 111.J"
* Serial No. 1327, January 12, 1987, untitled DBNPS letter to NRC, Attachment 1 titled "Exemption Requests From 1 OCFR50, Appendix R"
* Serial No. 1361, May 27, 1987, "Fire Protection -Request for Additional Information" Evaluation: The exemption (Log No. 3219) stated the following information: On the basis of its review of the licensee's nre hazards analysis (FHA) and its on-site inspection of the subject nre area, the staff agrees with the licensee that there is presently an acceptable level of fire protection within Fire Area A. Additionally, the licensee stated in its letter dated May 27, 1987, that if Train 1 systems were to be damaged by a fire in Room Nos. 123 and 124, the plant procedures would direct the plant operators to use the undamaged Train 2 systems in Room No. 115. Since Train 1 shutdown systems are relied upon in Fire Area A, the staff finds that these procedures transferring reliance to Train 2 provide further assurance that the safe shutdown capability will be -maintained in the event of a nre in the subject area. On the basis that the plant operators are fully trained in the transfer procedures cited above, the staff nnds that these procedures are acceptable and that there will be no confusion experienced by the operators in making the safe shutdown capability transfer. During its review of the licensee's FHA, the staff identified a concern regarding a cable chase in the subject fire area which had a significant in-situ fire load but was not protected by an automatic fire suppression system. The licensee addressed this concern in its letter dated May 27, 1987 by stating that the cable trays in this chase were protected by: the trays' solid bottoms,* a cover of fire resistant material (i.e. Kaowool),* a nre detection system,* and manual fire fighting equipment. Additionally, the licensee stated that the high fire loadtng is attributable to the small floor area of the chase. The staff finds that the licensee's responses in its letter of May 2 7, 1987 satisfy its specific concerns identified 1n its review of the Davis-Besse FHA. The staff further concludes that the licensee has demonstrated, as discussed above, that it can achieve and maintain a safe shutdown even if the subject area were to sustain fire damage. Davis-Besse Page K-14 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 4: Fire Compartments A-04 and A-05 On this basis, the staff llnds that the licensee has demonstrated, as required by 10 CFR 50. 12(a)(2)(ii), that the application of the regulation requiring that cables and equipment of redundant trains in Are Area A be separated by a 3-hour nre barrier is not necessary to achieve the underlying purpose of the rule (i.e., achieve and maintain a safe shutdown of the plant). Validation/Conclusions: Fire Compartments A-04 and A-05 will be evaluated using the performance-based approach as identified in NFPA 805 Section 4.2.4. As such, the existing exemption will not be transitioned into the NFPA 805 license basis. Associations: None Davis-Besse Page K-15 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 5: Fire Compartment AB-01 An exemption is requested from Section 111.G.3 of Appendix R to 10 CFR 50 to the extent that it requires fixed fire suppression in an area where alternate shutdown capability is provided. Specifically, alternate shutdown capability is provided for circuits controlling ECCS Room Cooler Fans C31-1 and C31-2 within Fire Compartment AB-01 (portion of Appendix R Fire Area AB). The alternate shutdown capability is physically and electrically independent of Fire Compartment AB-01. Basis Date: To Be Transitioned? Basis: 04/18/1990 No Fire Compartment AB-01 (portion of Appendix R Fire Area AB) consists of the DH Coolers Room 113, Hatch Area 113A, and ECCS Pump Room 105. According to the request for exemption (Serial No. 1327), the area consists of 2,589 ft2 of floor area, with an in-situ combustible loading consisting primarily of cable insulation, grease, polyethylene, and small quantities of lube oil. The total combustible loading in the area is approximately 5,500 Btu/ft2, which equates to an equivalent fire severity of four minutes. The fire area is bounded by reinforced concrete walls with a minimum thickness of 2 feet, a reinforced concrete ceiling with a thickness of 1.5 feet, and a reinforced concrete floor with a thickness of 3 feet. Existing fire protection capability in the area consists of an area-wide, early warning fire detection system that alarms locally and in the Control Room. Manual fire suppression capability in the form of portable fire extinguishers and standpipe hose stations is readily available in the area. For a fire in Appendix R Fire Area AB, Train 1 of the SSD systems is assumed to be lost, and Train 2 is used to ensure SSD. The Compliance Assessment Report describes in detail the SSD analysis and consequent modifications performed to bring this fire area into compliance with Section 111.G of Appendix R. In addition to these modifications, fire damage to certain circuits requires that alternate action be taken to ensure SSD capability. These circuits are associated with the ECCS Room Cooler Fans C31-1 and C31-2. Fire damage to the circuits would prevent the fans from operating. Alternate shutdown capability is provided by setting up temporary ventilation in Room 115. Adequate time exists to set up the portable fans before equipment in the area exceeds critical temperatures. Fire Compartment Description AB-01 ECCS Room Cooler Fans Davis-Besse Page K-16 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 5: Fire Compartment AB-01 Reference Document:
* FHAR, Revision 24, Fire Hazard Analysis Report
* Log No. 3219, Exemption dated April 18, 1990, "Exemption to 10 CFR Part 50, Appendix R, Section 111.G & 111.J"
* RFA 89-1852, "Room 115 ECCS Room Coolers"
* Serial No. 1327, January 12, 1987, untitled DBNPS letter to NRC, Attachment 1 titled "Exemption Requests From 1 OCFR50, Appendix R" Evaluation: An exemption from the requirements of Section 111.G.3 to provide area-wide fixed fire suppression in Appendix R Fire Area AB was requested based upon the following evaluation in Serial No. 1327: The equivalent fire severity in Fire Area AB is approximately 4 minutes, which consists of cable insulation, grease, polyethylene, and small quantities of lube oil A fire originating in these combustibles and/or an assumed transient combustible is expected to produce a fire of insignificant magnitude. . The installed early warning fire detection system will alert the Control Room operators to summon the fire brigade, which will respond and manually extinguish the fire. If the fire causes damage to the ECCS Room Coolers alternate shutdown capability is provided. This capability consists of manual operator actions. It is, therefore, Toledo Edison s position that a level of protection equivalent to Section Ill G. 3 of Appendix R to 10CFR50 is provided for Are Area AB. The addition of a complete area-wide fixed suppression system to this area would not significantly enhance the level of fire protection provtded for safe shutdown equipment. As indicated in the exemption (Log No. 3219), the staff found that the licensee demonstrated that the application of the regulation requiring a fixed fire suppression in Appendix R Fire Area AB was not necessary to achieve the underlying purpose of the rule (i.e., achieve and maintain a SSD of the plant) in accordance with 10 CFR 50.12(a)(2)(ii). Validation/Conclusions: This exemption is no longer required from the provisions of Appendix R 111.G.3 to have full area suppression where credit is taken for an alternate shutdown capability. Fire compartment AB-01 was evaluated using the performance-based approach as identified in NFPA 805 Section 4.2.4. As such, the existing exemption will not be transitioned into the NFPA 805 license basis. Davis-Besse Page K-17 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 5: Fire Compartment AB-01 Associations: None Davis-Besse Page K-18 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 6: Fire Compartment D-01 An exemption is requested from Section 111.G.2 of Appendix R to 10 CFR 50 to the extent it requires the separation of redundant SSD equipment inside non-inerted containment (Fire Compartment D-01) by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. Specifically, Redundant Containment Air Cooler Fans C1-1, C1-2, and C1-3 are located within approximately 10 feet of each other. Basis Date: . 04/18/1990 To Be Transitioned? No Basis: Fire Compartment D-01 (Appendix R Fire Area D) is the Containment. The containment air coolers are located on the 585' elevation in Fire Zone D-15. Fire Zone D-15 consists of 3,410 ft2 of floor area with an in-situ combustible loading consisting primarily of cable insulation and small quantities of grease and lube oil. The total combustible loading in the area is approximately 5,000 Btu/ft2, which equates to an equivalent fire severity of four minutes. Existing fire protection capability in the area consists of ionization-type early warning fire detectors throughout Fire Zone D-15. Manual fire suppression capability in the form of portable fire extinguishers and standpipe hose stations is available for the area. Access to the Containment is restricted during plant operation due to high neutron dose levels. The Redundant Containment Air Cooler Fans C1-1, C1-2, and C1-3 are located side-by-side on the 585' elevation. The minimum separation distance between the fans is approximately 10 feet. As explained in the fire protection commitment revisions in DBNPS letter Serial No. 1757, one containment air cooler fan is required for SSD. The circuits associated with the fans will be protected with radiant energy heat shields. The NRC approved the exemption (Log No. 3219) which states: The staff agrees with the licensee that it has met the underlying purpose of the rule as discussed below. The licensee originally committed to protect the three circuits associated with these fans by radiant energy shields in its letter dated Januaty 12, 1987. However, in its letter dated Februaty 16, 1990, the licensee revised this commitment to protect only one of these circuits with a radiant energy shield in the containment and annulus and with a 1-hour barrier and n"re suppression and detection systems or with a 3-hour fire barrier in the auxiliaty building. This proposal to protect only one train of a system is in compliance with the requirements of Appendix R to 10 CFR Part 50 and is acceptable. With respect to the fan coolers themselves, the small fire loading in this area would result in a relatively minor equivalent fire severity of about 4 minutes in the n"re zone where the fan coolers are located (i.e., Are Zone D-15). Further, the configuration of this area would tend to dissipate smoke and hot Davis-Besse Page K-19 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 6: Fire Compartment D-01 gases away from the subject fan coolers in the event of a fire. Addib"onal/y, the metal cabinets enclosing the fans would shield the fans themselves from the radiant energy of a nre. On this basis, we find that the licensee has demonstrated, as required by 10 CFR 50. 12(a)(2)(ii), that the application of the regulation requiring that the subject equipment be separated by more than 20 feet is not necessary to achieve the underlying purpose of the rule (i e., achieve and maintain a safe shutdown of the plant). Fire Compartment Description D-01 Containment Air Cooler Fans Reference Document
* Log No. 3219, Exemption dated April 18, 1990, "Exemption to 10 CFR Part 50, Appendix R, Section 111.G & 111.J"
* Serial No. 1327, January 12, 1987, untitled DBNPS letter to NRC, Attachment 1 titled "Exemption Requests From 1 OCFR50, Appendix R"
* Serial No. 1757, February 16, 1990, "Fire Protection -Changes from Previous Submittals in Fire Protection Compliance Approaches" Evaluation: According to the exemption request (Serial No. 1327), the equivalent fire severity in Fire Zone D-15 is approximately four minutes. The RCPs located elsewhere in Containment are provided with an oil collection system. Due to the restricted access to Containment during operations, the accumulation of transient combustibles is not postulated. Any fire occurring in the area is therefore expected to be of insignificant magnitude. In addition, the metal cabinets enclosing the fans will provide a limited amount of heat shielding. If a fire were to occur in this area, the installed early warning fire detection system will alert the Control Room operators to summon the plant fire brigade. Due to the low combustible loading in the area, fire damage to both trains of containment air cooler fans is considered unlikely. With the proposed installation of radiant energy shields between the redundant air cooler circuits, a level of protection equivalent to Section 111.G.2 of Appendix R will be provided in Containment. Additional protection for the containment air cooler fans would not significantly enhance the level of protection provided for SSD equipment. Davis-Besse Page K-20 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 6: Fire Compartment D-01 Validation/Conclusions: This compartment will be evaluated using the performance-based approach as identified in NFPA 805 Section 4.2.4. As such, the existing exemption will not be transitioned into the NFPA 805 license basis. Associations: None Davis-Besse Page K-21 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 7: Fire Compartment EE-01 An exemption has been approved from Section 111.G.3 to the extent it requires area-wide fixed fire suppression in an area for which alternate shutdown capability is provided. Alternate shutdown capability is provided for circuits and electrical components for the Main Steam Inlet Isolation Valve MS106 for the AFPT 1. The alternate shutdown capability Driven Feedwater Pump) is physically and electrically independent of Fire Compartment EE-01 (Appendix R Fire Area EE). Basis Date: To Be Transitioned? Basis: 04/18/1990 No Section 111.G.3 requires that alternate or dedicated shutdown areas be provided with fixed fire suppression Fire Compartment EE-01 (Appendix R Fire Area EE) is not provided with a fixed suppression system. The NRC exemption (Log No. 3219) dated April 18, 1990, states, "Fire Area EE has an alternative shutdown capability in Fire Area II which is physically and electrically independent for potential fire damage to either the circuits or electrical components of the . MS106 main steam inlet isolation valve for auxiliary feedwater pump turbine No. 1." In a letter (Serial No. 1327) dated January 12, 1987; the following attributes were provided: 1. The fire severity in the area will only be eight minutes. 2. There is low in-situ combustible loading in the area. 3. The cable insulation is slow-burning with a gradual rise in room temperature with significant quantities of smoke. 4. The fire brigade will be dispatched and use manual firefighting equipment to suppress a fire. 5. The walls, floors, and ceilings are 3-hour rated. 6. There is a partial sprinkler system covering at least 30% (Room 501) of the area, which would tend to minimize a fire. 7. There is an alternative shutdown capability for each of these three fire areas, which is both physically and electrically independent. Davis-Besse Page K-22 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 7: Fire Compartment EE-01 The NRC also stated in the exemption (Log No. 3219) the following information: The licensee also justifies its exemption request for these three fire areas based on the available fire protection. The staff agrees with the licensee that fires of significant magnitude would not occur in the subject areas nor would they spread beyond the boundaries of these areas. As a result, the cables and/or components which provide the alternative shutdown capability for the equipment in these three fire areas, as discussed above, would not be damaged The staff's basis is that the principal fire hazards in the subject areas are the insulation on the electrical cables. A fire involving cable insulation is characterized initially by slow burning with a gradual rise in room temperature and significant quantities of smoke. Since the combustion products would be detected by either the existing smoke detection systems or by the plant personnel, the fire brigade would be dispatched and suppress the fire using manual nre fighting equipment Furthermore, the walls, floors and ceilings of these three nre areas are 3-hour fire barriers which would be effective in confining the effects of a fire to the area of its origin until the arrival of the nre brigade. Additionally, Fire Area EE has a partial sprinkler system covering at least 30 percent of the area which would tend to minimize a nre in this area. Moreover, as discussed above, there is an alternative shutdown capability for each of these three fire areas which is both physically and electrically independent, thereby permiUing a safe shutdown to be achieved even if the subject areas were to sustain nre damage. Fire Comparbnent Description EE-01 Auxiliary Building HVAC Rooms Reference Document
* Log No. 3219, Exemption dated April 18, 1990, "Exemption to 10 CFR Part 50, Appendix R, Section 111.G & 111.J"
* Serial No. 1327, January 12, 1987, untitled DBNPS letter to NRC, Attachment 1 titled "Exemption Requests From 1 OCFR50, Appendix R" Evaluation: Based on the discussion above, the staff determined that the licensee has demonstrated, as required by 10 CFR 50.12(a)(2)(ii), that the application of the regulation requiring a fixed fire suppression in Fire Compartment EE-01 (Appendix R Fire Area EE) is not necessary to achieve the underlying purpose of the rule (i.e., achieve and maintain a SSD of the plant). Davis-Besse Page K-23 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 7: Fire Compartment EE-01 Validation/Conclusions: This compartment will be evaluated using the performance-based approach as identified in NFPA 805 Section 4.2.4. As such, the existing exemption will not be transitioned into the NFPA 805 license basis. Associations: None Davis-Besse Page K-24 
/ FE NOC Attachment K-Existing Licensing Action Transition Licensing Action 8: Manhole MH3001 Cable Separation An exemption has been approved from the requirements for fire protection features for Fire Compartment MA-01 (Appendix R Fire Area MA), Manhole 3001, required by Section 111.G.2. Basis Date: 04/18/1990 To Be Transitioned? Yes Basis: Fire Compartment MA-01 (Appendix R Fire Area MA) does not comply with 111.G.2 because the separation of redundant train cables is less than 20 feet, the area is not provided with an automatic suppression system, and it does not have fire detection coverage throughout the area. In an exemption dated April 18, 1990, (Log No. 3219) the NRC stated: For manhole MH 3001 (Item 7 of the table above), the licensee has requested an exemption from the requirement of Section Ill. G.2b that requires in part that cables and equipment and associated nonsafety circuits located in the same fire area outside of primary containment and necessary to achieve and maintain hot shutdown conditions be separated by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. Specifically, the licensees request is with respect to redundant circuits in the subject manhole associated with the service water system, including pumps (P3-1, P3-2 and P3-3), the backup pump (P-180), valves (SW 1395 and SW 1399) and motor control centers (MCCs E12C and F12C), which are less than 6 feet from one another. This manhole has neither active nor passive fire protection features. Fire Comparbnent Description MA-01 Manhole 3001 Reference Document
* 3614-2-E-140, Revision 0, "Nuclear Engineering and Construction Specification"
* C-83, Revision 7, "Yard Structures Electrical Manholes Plans, Sections, and Details"
* CR 10-74188, "Review of Thermoplastic and Thermoset Cables Used at Davis-Besse"
* E-0309, Revision 9, Sheet 1, "Raceway & Grounding Manhole-Sections & Details"
* E-0326, Revision 23, "Underground & Embedded Raceway & Grounding Pump House El.562'-6" & 585'-0"" Davis-Besse Page K-25 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 8: Manhole MH3001 Cable Separation
* FHAR, Revision 25, "Davis-Besse Nuclear Power Station Unit 1 Fire Hazard Analysis Report"
* Log No. 3219, "Exemption to 1 OCFR50, Appendix R, Section 111.G & 111.J" Evaluation: In an exemption dated April 18, 1990, (Log No. 3219) the NRC stated the following: The staff agrees with the licensee that there is a negligible potential for a nre which could damage redundant cables in this manhole in that there are no credible external sources of nre since the manhole is constructed with a concrete raised sill whose top opening is covered with a steel cap bolted into place. As a result, the only signin"cant fire threat to the redundant cables is from a cable-induced nre within the manhole itself With respect to this fire potential, the licensee stated in its exemption request that the insulation on the cables in this manhole satisfies the criteria of IEEE Standard 383-1974 or its equivalent Accordingly, this material will not sustain combustion unless an external heat source is present Since the redundant cables are separated in accordance with the guidance in Regulatol)/ Guide 1. 75 and the cables are protected against protracted fault conditions by overcurrent devices, the staff concludes that there is a negligible potential for a nre which could damage the redundant circuits. On this basis, the staff nnds that the licensee has demonstrated, as required by 10 CFR 50. 12(a)(2)(ii), that the
* subject redundant cables in manhole MH 3001 need not be physically separated by more than 20 feet to achieve the underlying purpose of the rule (i.e., achieve-and maintain a safe shutdown) 1i7 that there is negligible potential for a nre in the subject fire area. Validation/Conclusions: Conformance with the Appendix R exemption agreements reached with the NRC regarding cable separation 111.G.2 criteria, as stated in NRC exemption dated April 18, 1990, has been verified. The as-built plant configuration verification process consisted of review of current plant procedures, plant drawings, and the design change control process documentation. As stated above, validation of the exemption criteria for this licensing action was performed by reviewing station-controlled procedures, drawings, and design control process documentation. Therefore, no walkdown of the areas evaluated was considered necessary. Based on NRC exemption dated April 18, 1990, (Log No. 3219) the following criteria was selected for validation in order to carry this exemption forward: Davis-Besse Page K-26 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 8: Manhole MH3001 Cable Separation 1. Manhole MH3001 is constructed with a concrete, raised sill whose top opening is covered with a steel cap bolted into place.
* Review of Drawing C-83 confirms construction to include concrete, raised sill, with top opening covered with steel cap bolted into place. 2. The cables in MH3001 satisfy the criteria of IEEE Standard 383-1974 or equivalent. Review of SETROUTE Report dated 2012-04-03 for cables installed and pending for area MH3001 lists the cable types for the area. A comparison of those cable types to the Thermoset Thermoplastic Review performed for DBNPS indicates the cables are thought to be compliant with IEEE Standard 383. Discussions with the plant staff indicate the site procurement specification for Kerite cable requires it to be qualified to IEEE 383. However, an issue has been raised with regard to the actual qualification of the Kerite cable.
* A review of cable codes was performed against the work previously done and captured in condition report CR 10-74188. Detailed documentation cannot be located for every cable code. Some cable codes can be traced to vendor documentation indicating that they passed the IEEE 383 flame testing. While for other cable codes, the jacket and insulation type (e.g., Hypalon and cross-linked polyethylene (XLPE)) are_ known through other vendor tests that the material has passed the flame testing considered to be "equivalent." If no data could be located or if it was known that this was likely not to pass (e.g., PVC), then it would not be considered "383 or equal." None of the cables reviewed in MH3001 were of this type. Thus the cables routed through MH3001 are considered IEEE 383 or equivalent. 3. The cables in MH3001 are separated in accordance with RG 1.75.
* Nuclear Engineering and Construction specification number 3614-2-E-140 includes the separation requirements and reference to RG 1.75. RG 1.75 endorses the electrical independence requirements of IEEE 384-1992, as shown on page three. MH3001 Drawings E-309 and E-326 were reviewed to verify the cable separation met the IEEE criteria. However, the visual inspection indicated that "unistrut" of> 1" is located between the trays. FENOC verified the evaluation that the physical arrangement observed,actually complies with RG 1.75 separation requirements, which is documented in Action Item DB-1063. Davis-Besse Page K-27 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 8: Manhole MH3001 Cable Separation 4. The cables in MH3001 are protected against protracted fault conditions by overcurrent devices.
* Power cables in MH3001 were identified by a review of station drawings to confirm an installed breaker upstream of MH3001 cables. Instrument and control cables located in MH3001 have been identified by a review of station drawings to confirm the installation of fuses both upstream and downstream of the cables in MH3001. According to the FHAR Section 5.2.4, the interrupting device for each circuit within a common enclosure is adequately sized to perform its design function as part of the original plant design. The common power source analysis is in FHAR Section 5.1. In conclusion, although the information has been updated over time, with acceptable resolution of the open items, the bases for previous acceptance will still be valid. The exemption for less than 20-foot separation of redundant train cables in an area not provided with an automatic suppression system and that does not have fire detection coverage throughout will be transitioned to the new licensing basis under NFPA 805. Associations: Ch. 4 -Compartment: MA-01 Fire Protection -Fire Compartment: MA-01 I Form: 20 ft. Separation Davis-Besse Page K-28 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 9: Fire Compartment R-01 An exemption has been approved from Section 111.G.3 to the extent that it requires fixed fire suppression in an area for which alternate shutdown capability is provided. Specifically, alternate shutdown capability is provided for circuits controlling the Service Water Pumps and AFPT Governor Valves within Fire Compartment R-01 (Appendix R Fire Area R). The alternate shutdown capability (in the form of the Backup Service Water Pump and the Motor-Driven Feedwater Pump) is physically and electrically independent of Fire Compartment R-01. Basis Date: 04/18/1990 To Be Transitioned? No Basis: Fire Compartment R-01 (Appendix R Fire Area R) is the Auxiliary Shutdown Panel and Transfer Switch Room 324. The area consists of 350 ft2 of floor area with an in-situ combustible loading consisting primarily of cable insulation and incidentals. The total combustible loading in the area is approximately 5,000 Btu/ft2, which equates to an equivalent fire severity of four minutes. The fire area is bounded by 3-hour fire rated concrete and concrete-block walls with a minimum thickness of one foot, and 3-hour fire rated ceiling and floor constructed of 1-foot thick reinforced concrete. Existing fire protection capability in the area consists of an area-wide, early warning fire detection system that alarms locally and in the Control Room. Manual fire suppression capability in the form of portable fire extinguishers and standpipe hose stations is readily available in the area. For a fire in Room 324, both Train 1 and Train 2 are used to ensure SSD. Modifications (MOD 84-0177) were required to bring this fire area into compliance with Section 111.G of Appendix R. In addition to these modifications, fire damage to the circuits for the three Service Water Pumps could disable all three pumps. One Service Water Pump is required for SSD. Alternate shutdown capability is provided by manually aligning and starting the Backup Service Water Pump, located in Fire Compartment BD-01. Adequate time exists for the operators to perform these actions following a fire in Fire Compartment R-01. Fire damage to circuits for the Auxiliary Feedwater . Pumps' Governor Control Valves ICS038A and ICS038B could disable their remote operability. Alternate shutdown capability is provided by manually aligning and starting the Motor-driven Feedwater Pump P-241 in Fire Compartment 11-01. Adequate time exists for the operators to perform these actions following a fire in Fire Compartment R-01. DBNPS procedures include instructions for performing these manual actions if the aforementioned circuits are damaged by a fire in Room 324. Davis-Besse Page K-29 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 9: Fire Compartment R-01 NRG letter dated April 18, 1990, (Log No. 3219) states: For Items 1, 2 and 3 of the table above, the licensee has requested exemptions from the requirements of the last paragraph of Section Ill G. 3 of Appendix R which states in part that a fixed fire suppression system shall be installed in the area under consideration (i.e., Fire Areas R, EE and AB) in that an alternative shutdown capability and its associated circuitry is provided for each of these three areas. Specifically, Fire Area BD provides an alternative shutdown capability for the setvice water system in Fire Area R Addtlional/y, an alternative shutdown capability and its associated circuitry is provided in Fire Area II for the control valves of the turbine driven auxiliary pumps in Fire Area R .... The detailed description of the configuration of the three subject areas, including the construction of the perimeter boundanes, the potential fire hazards, and the available fire protection, is contained in the licensees letter dated January 12, 1987, in 1ls Fire Hazards Assessment Report (FHAR) and in the Davis-Besse Appendix R Compliance Assessment Report (CAR). Part of the licensees basis for its request for exemptions for these three fire areas is the limited fire hazard in which the equivalent fire severity would range from 4 minutes in Fire Areas Rand AB to 8 minutes in Fire Area EE These relatively low equivalent fire severity times are due to the low in-situ combustible loadings in the subject areas. The licensee also justifies its exemption request for these three fire areas based on the available fire protection. The staff agrees w1lh the licensee that fires of significant magnitude would not occur in the subject areas nor would they spread beyond the boundanes of these areas. As a result, the cables and/or components which provide the alternative shutdown capability for the equipment in these three nre areas, as discussed above, would not be damaged. The staffs basis is that the principal nre hazards in the sub;ect areas are the insulation on the electrical cables. A fire involving cable insulation is characterized initially by slow burning with a gradual rise in room temperature and significant quantities of smoke. Since the combustion products would be detected by either the existing smoke detection systems or by the plant personnel, the fire brigade would be dispatched and suppress the fire using manual fire fighting equipment Furthermore, the walls, floors and ceilings of these three nre areas are 3-hour fire barriers which would be effective in confining the effects of a fire to the area of its origin unltl the arrival of the nre brigade.... Moreover, as discussed above, there is an alternative shutdown capability for each of these three fire areas which is both physically and electrically independent, thereby permiUti7g a safe shutdown to be achieved even ifthe sub;ect areas were to sustain nre damage. Davis-Besse Page K-30 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 9: Fire Compartment R-01 On this basis, the staff finds that the licensee has demonstrated, as required by 10 CFR 50.12(a)(2)(ii), that the application of the regulation requiring a fixed fire suppression in Fire Areas R, EE and AB is not necessary to achieve the underlying purpose of the rule (i.e., achieve and maintain a safe shutdown of the plant). Fire Compartment Description R-01 Alternate Shutdown Reference Document
* Log No. 3219, "Exemption to 10CFR50, Appendix R, Section 111.G & 111.J"
* Serial No. 1327, "Topic: Appendix R Exemption Requests, January 12, 1987" Evaluation: DBNPS letter (Serial No. 1327) states: An exemption from the requirements of Section Ill. G.3 to provide fixed bre suppression in Fire Area R is requested, based upon the following evaluation: The equivalent fire severity in Fire Area R is approximately 4 minutes, which consists of widely dispersed cable insulation and incidentals. A fire originating in these materials or a postulated transient combustible is not expected to produce a fire of signibcant extent or duration. The installed early warning detection system will alert the Control Room operators to summon the plant bre brigade, which will respond and manually extinguish the bre. If the bre causes damage to the Service Water System and/or the Turbine Driven Auxiliary Feedwater Pumps Governor Control Valves pnor to intervention by the fire brigade, alternate shutdown capability is provided This capability consists of manual operator actions to manually start the Backup Service Water Pump and/or Motor Driven Feedwater Pump. It is, therefore, Toledo Edison s position that a level of protecfton equivalent to Section Ill. G. 3 of Appendix R to 10CFR50 is provided for Fire Area R, the Auxiliary Shutdown Panel and Transfer Switch Room #324. The addition of a fixed fire suppression system to this area would not signibcantly enhance the level of fire protection provided for safe shutdown equipment Davis-Besse Page K-31 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 9: Fire Compartment R-01 Validation/Conclusions: This exemption is no longer necessary as this compartment will be evaluated using the performance-based approach as identified in NFPA 805 Section 4.2.4. As such, the existing exemption will not be transitioned into the future license basis. Associations: None Davis-Besse Page K-32 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 1 O: Emergency Lighting An exemption has been approved from Section 111.J to the extent it requires self-contained emergency lighting units with at least an 8-hour battery power supply in the areas needed for the operation of SSD equipment, and in access and egress routes thereto. The exemption is specifically to utilize existing "hard-wired" AC/DC essential lighting in portions of the Auxiliary and Turbine Buildings, and to utilize hand-held portable units in outside plant areas. '---Basis Date: 04/18/1990 To Be Transitioned? No Basis: According to the NRC exemption (Log No. 3219): The staff initially identified four specific concerns regarding this particular exemption request In response to the first of these concerns, the licensee stated that the results of its own evaluation confirmed that the AC/DC lighting system in the pertinent portions of the auxilial)/ and turbine blJlldings which would be used in establishing an alternative method for achieving a safe shutdown in the event of a lire in either the control room or the cable spreading room, would not be disabled by a lire in either of these latter two locations. On the basis that there is an alternative means for achieving a safe shutdown with the existing AC/DC lighting systems in the event of a fire in either the control room or the cable spreading room, the staff finds that this concern has been resolved With respect to the staffs concern regarding the use of hand-held lighting units while conducting manual operations in outside plant areas, the licensee confirmed in Attachment 3 to its letter dated May 27, 1987 that no operator manual actions are required to achieve safe shutdown which would involve the use of both hands. On this basis, the staff finds this concern resolved With respect to the third of the staff's concerns, the licensee also confirmed in its letter dated May 27, 1987 that the travel route of the operators is free from potentially hazardous conditions for those outside plant areas where operator action is required to achieve safe shutdown. On this basis, the staff finds this particular concern resolved The staff also expressed its concern that the illumination level in certain areas might not be sufficient to permit the plant operators to perform actions required to achieve a safe shutdown. In response, the licensee stated in its letter dated Janual)/ 12, 1987, that a plant wa!kdown was performed to verify that there was adequate illumination within these areas for all activities which must be performed in the first 8 hours following the onset of a fire. This is also true for the access routes to these areas of concern. Following this plant walkdown, the licensee installed add!lional emergency lighting umts and repositioned others. These mod!"fications were performed consistent with Davis-Besse Page K-33 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 10: Emergency Lighting the guidance provided in Genedc LeUer86-10, ''Implementation of Fire Protection Requirements." On this basis, the staff finds that this last concern regarding emergency lighting is resolved The staff agrees with the licensee that there is an acceptable method for providing emergency lighting in those portions of the auxiliary and turbine buildings that the plant operators must enter to achieve a safe shutdown in the event of a fire in either the control room or the cable spreading room. The staff also agrees with the licensee that there is an acceptable method for providing emergency lighting in outside plant areas. Finally, the staff also agrees -that the modifications to the emergency lighting units cited above made in accordance with Genedc LeUer 86-10 are acceptable. On the basis that the licensee has provided acceptable emergency lighting units for all areas, including the access routes, that plant operators must enter in the event of a fire, the staff finds that the licensee has demonstrated, as required by 10 CFR 50. 12(a)(2)(ii), that it meets the underlying purpose of the rule regarding emergency lighting. Fire Compartment Various Fire Areas Reference Document Description Emergency Lighting
* Log No. 3219, "Exemption to 1 OCFRSO, Appendix R, Section 111.G & 111.J"
* Serial No. 1327, "Topic: Appendix R Exemption Requests, January 12, 1987" Evaluation: The licensee stated in a letter dated January 12, 1987, (Serial No. 1327): An exemption from the requirements of Section Ill. J to provide self-contained baUery-powered lighting units in all areas needed for the operation of safe shutdown equipment is requested based upon the following evaluation: For a fire occurdng in either the Control Room or Cable Spreading Room that is of sufficient magnitude to require evacuation of the Control Room, Toledo Edison has developed an alternative shutdown procedure to ensure safe shutdown of the plant This procedure may require the Control Room operators to man the alternate shutdown panel as well as several other stations through the plant A circuit analysis has been petformed to show that the essential AC/DC hard-wired lighting system would not be disabled by a fire in either the Control Room or Cable Davis-Besse Page K-34 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 1 O: Emergency Lighting Spreading Room. Several modifications were identified and are being implemented to ensure the availability of the ''/Jard-wired" lighting circuits. In addtlion, the essential AC/DC hard-wired lighting system will provide illumination for at least 8 hours. Plant walkdowns have.been petformed to verify that the level of illumination produced by the combination of essential AC/DC hard-wired lighting systems and the battery-powered lighting unit system is adequate for the operators to petform the activtlies required by the alternate shutdown procedure. For several outside plant areas, lighting will be supplied by hand-held units. These outside areas are discussed in Davis-Besse Appendix R Compliance Assessment Report The portable lighting in outside areas can provide an equivalent level of lighbi7g as a nxed lighting system. In addition, in outside areas, portable lighting provides greater flexibility than a nxed lighbi7g system. Additionally, security lighbi7g may be available to supply background lighting although this lighting system has-not been evaluated for availability in the event of a nre. Testing and maintenance of the essential AC/DC hard-wired lighting system will be petformed under controlled procedures to provide a measure of reliability. For a fire occurring in any plant area other than the Control Room and Cable Spreading Room, emergency lighting is provided by the battery-powered lighting system and handheld portable units for outside plant areas. Plant walkdowns have been petformed to verify adequate illumination for all activtlies that must be petformed in 8 hours. Additionally, security lighting may be available to supply background lighting although this lighting system has not been evaluated for availability in the event of a fire. It is, therefore, Toledo Edison's position that a level of protection equivalent to Section 111.J of Appendix R to 10CFR50 is provided by the essential AC/DC lighting system, as supplemented by self-contained 8-hour battery-powered lighting untls and portable lighting units for outside areas. The addition of 8-hour battery-powered lighting units for complete coverage of all areas needed for the operation of safe shutdown equipment would not significantly enhance the level of safety provided for safe shutdown equipment. Validation/Conclusions: 8-hour battery backed emergency lights are not a specific requirement of NFPA 805. This exemption (Section 111.J of Appendix R) will not be transitioned to the new licensing basis under NFPA 805. Associations: None Davis-Besse Page K-35 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 11: Embedded Conduits An exemption has been approved from the requirement to have a rated 3-hour barrier separating embedded conduits in concrete from redundant trains of SSD circuits and associated circuits required by Section 111.G.2. Basis Date: 04/18/1990 To Be Transitioned? Yes Basis: In an exemption dated April 18, 1990 (Log No. 3219) the NRC stated the following: For certain cables of electrical circuits which are enclosed in conduit and embedded in concrete walls, floors and ceilings (Item 8 of the table above), the licensee has requested an exemption from the requirement of Section Ill. G.2. a of Appendix R which requires in part that cables and equipment and associated nonsafety circuits of redundant circuits required to achieve a safe shutdown be separated by a fire bamer having a 3-hour rating. The sub;ect cables were not evaluated by the licensee in its safe shutdown analysis for a fire. Moreover, the depth and configuration of the concrete covering these cables is insu/Wcient in the event of a fire to meet the Appendix R requirement cited above. The licensee later submitted supplemental information regarding the subject exemption request in its letter dated September 30, 1989. The licensee stated in the cited documents that it conducted a comprehensive effort to determine where potentially vulnerable cables were installed and to determine the depth and configuration of the concrete cover, the steel reinforcing bars and anchor bolts, all of which have an effect on the fire resistance of the reinforced concrete cover. The licensee determined in its analysis, using the standard heat input specified in A SME E-119, that if a fire were to occur in any of the subject areas, the temperature of the electrical cables would not exceed 310 degrees Fin a 30-minute period. When active fire suppression acb"vities begin after the arrival of the fire brigade, thereby removing the heat source, the licensee stated that the cable temperatures would continue to rise to a maximum of 370 degrees F and then diminish. The temperature-time profiles cited above were used as a reference to assess the adequacy of fire protection for the embedded cables in the subject fire areas. The staff agrees with the licensee that 370 degrees Fis an acceptable temperature limit below which significant nre damage to the electrical cables would not occur. Furthermore, the staff finds that this acceptance critena is conservative in that the nature and configuration of the combustibles in the subject fire areas will produce a temperature-time profile which is lower than that derived when using A STM E-119. Davis-Besse Page K-36 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 11: Embedded Conduits r The licensees analysis of the subject fire areas was divided into three categories when comparing the fire hazards with the existing fire protection in each portion of the subject fire areas. The first of these categories was those areas which had combustibles that would result in an equivalent fire loading less than 30 minutes. The staff finds the areas in this first category acceptable on the basis that an all consuming fire less than 30 minutes would not produce sufficient heat to damage the cables,* i.e., the maximum possible cable temperature of 310 degrees F would be below the acceptance criterion of 370 degrees F. In the second category, there are a number of nre areas having combustibles which would yield an equivalent fire loading greater than 30 minutes but which are also protected by automatic fire suppression systems. The staff finds the areas in this second category have an acceptable level of protection on the basis that the nre suppression systems in these areas would actuate automatically dunng the early stages of a nre. There are two locations (i.e., Rooms 428 and 515) which have combustibles that would produce an equivalent fire loading greater than 30 minutes but which do not have automatic fire suppression systems. Based on our
* evaluation of the licensees justification for not providing automatic suppression systems for these two rooms and on our inspection of these areas during August 1989, the staff agrees with the licensee that any potential nre in these two rooms would be suppressed by the plant fire brigade well before room temperatures reached a level high enough to cause cable damage. Based on the validity and conservatisms in the ltcensee s heat transfer analyses of the protective cover over the embedded conduits in the subject areas and on the subsequent evaluation as discussed above, the staff concludes that the licensee has provided an acceptable level of nre protection for the subject fire areas. On this basis, the staff nnds that the licensee has demonstrated, as reqwred by 10 CFR 50. 12(a)(2)(ii), that the subject redundant embedded cables need not have a 3-hour nre barrier to achieve the underlying purpose of the rule (i.e., achieve and maintain a safe shutdown) 1i7 that the reinforced concrete cover and other protective measures will limit the temperature rise in the embedded cables below the threshold of damage. / Davis-Besse Page K-37 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 11: Embedded Conduits Fire Compartment A-08 DF-01 DH-01 EE-01 11-01 Q-01 R-01 X-01 Reference Document Description No. 4 Mechanical Penetration Room No. 2 Electrical Penetration Room Main Steam Line Areas Auxiliary Bldg Ventilation Rooms Turbine Building High Voltage Switchgear Room B Auxiliary Shutdown Panel Room and Duct Chase Low Voltage Switchgear-F *bus and No. 1 Electrical Isolation Rooms
* A-224F, Revision 24, "Fire Protection General Floor Plan EL. 603' -0""
* A-225F, Revision 19, "Fire Protection General Floor Plan EL 623'-0""
* C-FP-013.10-006, Revision 4, "Combustible Loading Analysis"
* C-NSA-013.06-001, Revision 0, "lmbedded Conduit Heatup Due to Anchor Bolt Conduction"
* C-NSA-013.06-002, Revision 0, "PVC Conduit Heatup with Anchor Bolt"
* DB-FP-00005, Revision 7, "Fire Brigade"
* E-892, Revision 7, Sheet 2, "Raceway-Fire Alarm System Auxiliary Building Plan EL. 623"'
* E-892, Revision 11, Sheet 4, "Raceway-Fire Alarm System Auxiliary Building Plan EL. 603"'
* E119-2000, "ASTM Standard Test Methods for Fire Tests of Building Construction and Materials"
* FHAR, Revision 25, "Davis-Besse Nuclear Power Station Unit 1 Fire Hazard Analysis Report"
* Log No. 3219, "Exemption to 10CFR50, Appendix R, Section 111.G & 111.J"
* M-410, Revision 26, "HVAC Aux Bldg. Plan at Elevation 623"'
* NUREG/CR-6850, "Fire PRA Methodology for Nuclear Power Facilities, Vol 2: Detailed Methodology" Davis-Besse Page K-38 FE NOC Attachment K -existing Licensing Action Transition Licensing Action 11 : Embedded Conduits
* Serial No. 1719, "Fire Protection -Appendix R Exemption Request Involving Conduits Embedded in Concrete, September 30, 1989" Evaluation: DBNPS letter dated September 30, 1989, (Serial No. 1719) states: Certain circuits, required to achieve and maintain safe shutdown in the event of a fire, are enclosed in condwt and embedded in concrete walls, floors, duct banks or ceilings of the Davis-Besse Nuclear Power Plant. These circuits were evaluated in the safe shutdown analysis for a fire. It was identified that the existing fire protection features for the safe shutdown embedded circuits in Rooms 252, 314, 323, 324, 334, 427, 428, 430, 431, 501, 515, and 602 are not in accordance with the requirements of Secb"on Ill. G of Appendix R to 10CFR50. However, as discussed below the fire protection features are sufficient to ensure one train of these circuits would be free of fire damage. An exemption is requested from Secb"on Ill. G of Appendix R to 10CFR50, pursuant to 10CFR50. 12, to obviate the need for modifying the existing nre protection features for these circwts embedded in concrete in Rooms 252, 314, 323, 324, 334, 427, 428, 430, 431, 501, 515, and 602 .... Toledo Edison has evaluated the existing fire protection measures provided for embedded conduits in Rooms 252, 314, 323, 324, 334, 427, 428, 430, 431, 501, 515, and 602 and has determined thatthese measures provide a level of protecb"on equivalent to Section Ill. G of 1 OCFR50, Appendix R These measures are: 1. An analysis of the worst case configuration (i.e., a minimum conduit embedment of 2 7/8 inches and anchor bolts in the concrete) was performed The circuits' temperatures would not exceed 310 degrees Fin 30 minutes. Once the heat source is removed or extinguished, the hoUest temperature in the conduit will continue to rise to approximately 370 degrees F and then drop off These temperatures are enveloped by the environmental qualification data for the cable used in the circuits embedded in these rooms/and thus the circuits will remain operable. 2. Rooms 252, 314, 323, 324, 334, 427, 430, 431, 501, and 602 either have a combustible loading of 30 minutes or less or are protected by an automatic sprinkler system. In those rooms with a combustible loading of 30 minutes or less, the passive protection of the concrete will maintain the circuits at an acceptable temperature and thus they will remain operable. In those rooms with a combustible loading of greater than 30 minutes and an automatic sprinkler system, the passive protection of the concrete and the active protection provided by the Davis-Besse Page K-39 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 11 : Embedded Conduits automatic sprinkler system will maintain the circuits at an acceptable' temperature and thus they will remain operable. 3. Room 428 has a combustible loading greater than 30 minutes and is not protected by automatic sprinkler systems. In this room the passive protection of the concrete will maintain the circuits at an acceptable temperature and thus they will remain operable. Room 428 is provided with fire detection zones which would alert Control Room personnel to a fire and they would initiate the response of the Are Brigade. Within 30 minutes, the fire brigade would respond to extinguish the fire and the circuit temperature will remain at an acceptable temperature and thus they will remain operable. 4. Room 515 has a combustible loading greater than 30 minutes and is not protected by an automatic sprinkler system. However, ninety-five percent of the total combustible load is charcoal which is contained in three charcoal filters that are within heavy metal plenum boxes as part of the ventilation system. The charcoal has an extremely_ slow burn rate. Also it is reasonable to assume that only one of the charcoal filter plenums would be on fire at a time. Even though the combustible loading exceeds 30 minutes, the effect of any potential fire is very limited and the passive protection of the concrete will maintain the circuits at an acceptable temperature and thus remain operable. 5. The Davis-Besse Fire Brigade has a minimum shift size of five members and is onsite at all times in accordance with Technical Specification 6.22f The Fire Brigade does not include the members of the minimum shift crew's necessary for safe shutdown of Davis-Besse during a fire emergency. The Fire Brigade has established training programs and fire drills under exisbng administrative controls. Normal fire bn"gade response at Besse has been timed in dnlls at less than 15 minutes from alarm imtiation to providing water on the fire. 6. Figure 7-8E of the NFPA Handbook, 16th Edition, indicates that 2 7/8 inches of concrete provides over45 minutes of fire resistance. The analysis considered the impact of the anchor bolts which could reduce the fire resistance of the concrete. The analysis has a number of conservatisms that if removed from the calculation, would cause the fire resistance to approach the equivalent fire resistance of the concrete without considering the anchor bolts. The analysis is conservative for the following reasons: a. The heat input to the calculation was the AS TM E-119 time-temperature curve. The actual combustible loading in the rooms would not result in the assumed heatup rate. Davis-Besse Page K-40 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 11: Embedded Conduits b. The calculation assumed the anchor bolt is in direct alignment with the conduit and is the largest size normally allowed with a embedment of 2 7 /8" or less. Actually, it is highly improbable that the anchor bolt is in direct alignment with the conduits or is near the conduits due to the small sutface area of the conduit relative to the large sutface area of the wall, floor; duct banks, or ceiling. Also the minimum conduit embedment is based on combining the minimum concrete cover and rebar sizes which are both not likely to occur where an anchor bolt is located Consequently, Toledo Edison has determined that the existing fire protection features provided for the embedded conduits would ensure one train of equipment necessary to achieve and maintain safe shutdown in the event of a fire is free of fire damage and, thereby, provide an equivalent level of fire protection as required by Section Ill. G of Appendix R. Additionally, the imposition of additional modifications simply to satisfy the methods specified by Appendix R of 1 OCFR50 for the embedded conduit would not significantly enhance the level of fire protection currently provided Validation/Conclusions: Conformance with the Appendix R exemption agreements reached with the NRC regarding cable separation; 111.G.2 criteria, as stated in NRC exemption dated April 18, 1990, (Log No. 3219) has been verified. The as-built plant configuration verification process consisted of limited walkdowns combined with the review of current plant procedures, plant drawings, and the design change control process documentation. Based on NRC exemption dated April 18, 1990, (Log No. 3219) the following criteria was selected for validation in order to carry this exemption forward: 1. Rooms 252, 314, 323, 324, 334, 427, 430, 431, 501, and 602 have either: a. A combustible loading of 30 minutes or less b. Area protected by an automatic sprinkler system The FHAR states rooms 252, 314, 334, 427, 430, 431, and 501 have an automatic sprinkler system. A walkdown was done in April 2011 and confirmed the following areas had no automatic sprinklers visible within Rooms 323, 324, and 602. However, from C-FP-013.10-006, the combustible loading of these rooms is: Room 323 is 25,879.07 Btu/ft2, Room 324 is 2100 Btu/ft2, and Room 602 is 3559.83 Btu/ft2. Using the conversion factor of 40,000 Btu/ft2 = 30 minutes, the three rooms have a combustible loading of less than 30 minutes. Davis-Besse Page K-41 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 11: Embedded Conduits 2. Verify that, if Rooms 428 and 515 have a combustible loading of greater than 30 minutes and are not protected by automatic sprinkler systems, then the fire brigade is able to reach the rooms in less than 30 minutes and detection is available and alarms in the Control Room. Table 18.1.1 from the NFPA Handbook shows 40,000 Btu/ft2 is the equivalent to a fire severity of approximately 30 minutes. The FHAR and C-FP-013.10-006 states Room 428 has a combustible loading of 46,507 Btu/ft2 and does not have automatic wet sprinkler system. Room 515 has a combustible loading of 56,800 Btu/ft2 and does not have automatic wet sprinkler system. Both rooms have a greater than 30 minute combustible loading. The procedure DB-FP-0005 includes Attachment 4, "Fire Brigade Drill Assessment." The acceptance criteria for the brigade's timely arrival include assembling at the scene of the simulated fire and commencing discussion of firefighting agent application within 12 minutes. A note states: "Elapsed time in excess of 15 minutes will be considered unsatisfactory drill performance." Drawings A-224F and E-892, Sheet 4, indicate fire detection (smoke detectors) is available in Room 428 and alarms in the Control Room. Drawings A-225F and E-892, Sheet 2, indicate fire detection is available in Room 515 and alarms in the Control Room. A walkdown to verify detectors were located within these rooms was conducted in April 2011. Code compliance of these detectors is discussed in LAR _Attachment A, in accordance with NFPA 805 Section 3.8.2, for Compartments X-01 and EE-01. 2a. Verify that the combustible loading in Room 515 is three charcoal filters in heavy plenum boxes due to the slow burn rate of this component. Calculation C-FP-013.10-006 for Room 515 indicates a combustible load including, but not limited to, Charcoal Air Filters F17-1, F19-1, and F19-2. Filter F17-1 accounts for 30,240 Btu/ft2, and Filters F19-1 and -2 account for 22,680 Btu/ft2* Drawing M-410, "Heating-Ventilating & Air Conditioning Auxiliary Building Plan At El. 623'-0," shows Filters F-19-1 & F19-2 within "Emergency Vent. System Filter Units" and Filter F17-1 within "Containment Purge Exhaust Filters F-17, No. 1-1." 3. Verify that ASTM E119 time-temperature curves were used to determine that the circuits' temperatures would not exceed 310 degrees Fin 30 minutes and after the heat source is removed the conduit temperature will continue to rise to approximately 370 degrees F then drop off. Per the ASTM E119 time-temperature curve, at 30 minutes the temperature is 1550 degrees F. However, this does not account for the heat transfer to embedded conduits. One analysis was found on the discussion of heat Davis-Besse Page K-42 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 11: Embedded Conduits transfer to embedded conduits, but it only discusses anchor or expansion bolts installed in a hole directly over a three-inch conduit embedded in four inches of concrete. Serial No. 1719 gives an explicit geometry of 2-7/8 inches (1-3/8 inches of rebar covered by 1-1/2 inches of concrete). Calculation C-NSA-013.06-002 evaluated an anchor bolt directly above a PVC conduit with only 2-7/8" of cover. The maximum exterior temperature was approximately 481 degrees Fat 40 minutes with a conduit internal
* temperature of 370 degrees F. It should be noted that air temperature inside the conduit climbed to 156 degrees F at 40 minutes. Calculation C-NSA-013.06-001 evaluated an anchor bolt directly above a steel conduit with only 4" of cover. 300 degrees F is reached on the exterior conduit surface at approximately 30 minutes. 4. Verify that the temperatures noted in Number 3 above are enveloped by the EQ data for the cable used in the circuits embedded in these rooms. The failure temperature for cables is greater than the approximate 370 degrees F peak temperature. For thermoset cables, it is 625 degrees F, and for thermoplastic cables, it is 400 degrees F (Ref. NUREG 6850, Volume 2, Att. H, Page H-1). Failure temperature is 702 degrees F for Kerite Cables (Ref. NUREG 6850, Volume 2, Att. H, Page H-6). One analysis was found on the discussion of heat transfer to embedded conduits, but it only discusses anchor or expansion bolts installed in a hole directly over a three-inch conduit embedded in four inches of concrete. Serial Number 1719 gives an explicit geometry of 2-7/8 inches (1-3/8 inches of rebar covered by 1-1/2 inches of concrete).
* 5. Verify the DBNPS fire brigade has a minimum shift size of five members and is onsite at all times in accordance with TS 6.2.2.f. Also, verify that the fire brigade does not include the members of the minimum shift crew necessary for SSD of DBNPS during a fire emergency. Verify the fire brigade is able to respond in 30 minutes or less. . DB-FP-00005, "Fire Brigade," Section 4.7, "Fire Brigade," states: The Team consists of one Fire Captain and four brigade members who are not relied upon for safe
* shutdown essential functions in the event of a fire emergency. Section 6.1.1, "Fire Brigade Requirements" states: Davis-Besse Page K-43 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 11 : Embedded Conduits The Fire Brigade is composed of a minimum of five individuals: one captain and four brigade members. This staffing is maintained on site at all times. The brigade composition may be less than the minimum
* requirements for a period of time not to exceed two hours in order to accommodate unexpected absence, provided immediate action is taken to ftll the required positions. The procedure includes Attachment 4, "Fire Brigade Drill Assessment." The acceptance criterion for the brigade's timely arrival includes assembling at the scene of the simulated fire and commencing discussion of firefighting agent application within twelve minutes. A note states: "Elapsed time in excess of 15 minutes will be considered unsatisfactory drill performance." In conclusion, although the information has been updated over time, the bases for previous acceptance are still valid and the exemption to have a rated 3-hour barrier separating embedded conduits in concrete from redundant trains of SSD circuits and associated circuits will be transitioned to the new licensing basis under NFPA 805. Associations: Ch. 3 -Section: 3.11 I Subsection: 3.11.1 Ch. 4 -Compartment: A-08 Ch. 4 -Compartment: DF-01 Ch. 4 -Compartment: DH-01 Ch. 4 -Compartment: EE-01 Ch. 4 -Compartment: 11-01 Ch. 4 -Compartment: Q-01 Ch. 4 -Compartment: R-01 Ch. 4 -Compartment: X-01 Fire Protection -Fire Compartment: DF-01 I Form: Water-Based Suppression Fire Protection -Fire Compartment: 11-01 I Form: Water-Based Suppression Fire Protection -Fire Compartment: X-01 I Form: Detection Davis-Besse Page K-44 FENOC Attachment K -Existing Lice_nsing Action Transition Licensing Action 12: Reactor Coolant Pumps Oil Collection System RCP Oil Collection System Section 111.0 of Appendix R to 10 CFR 50 requires, in part, that the RCP lube oil collection system be designed to collect lube oil leakage in a closed, vented container that can hold the entire lube oil system inventory. An exemption has been approved from Section 111.0 to the extent it requires the oil collection system for the RCPs be capable of containing the oil from the four RCPs. The oil collection system is capable of collecting the oil from two RCPs. RCP Remote Oil Fill System An exemption has also been granted to use the remote fill system without a collection system. The underlying purpose of 10 CFR Part 50, Appendix R, Section 111.0, is to ensure that leaking oil will not lead to a fire that could damage SSD systems during normal or design basis accident conditions. Basis Date: 08/20/1984 01/30/1998 To Be Transitioned? Yes Basis: RCP Oil Collection System In the exemption dated August 20, 1984, (Log No. 1586) the staff states: The Davis-Besse Nuclear Power Station is designed with two reactor coolant loops. Each loop has two reactor coolant pumps (RCP). A high pressure and low pressure lube oil system is provided for each RCP motor. The high pressure system is used only during startup and shutdown. The low pressure system is used during normal operation. Each RCP motor contains 225 gallons of lube oil. The licensees have provided one 250 gallon oil collection tank for each loop. This provides su/Wcient capacity to hold the total lube oil inventoty of only one RCP motor in each loop with some margin. Any lube oil ovetflow will drain to the containment sump. The RCP motor lube oil system does not comply with Section Ill. 0 because the oil collection tank is not sized to contain the entire lube oil system inventory. Since any lube oil ovetflow will drain to the containment building sump where there is no other flammable material or hot surfaces which may ignite the oil, the ovetflow oil will not present an exposure fire hazard to or otherwise Davis-Besse Page K-45 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 12: Reactor Coolant Pumps Oil Collection System endanger safety-related equipment, and since the RCP motor lube oil collection system is capable of withstanding the safe shutdown earthquake, we find the 011 collection system acceptable. Based on our evaluation as discussed above, we conclude the existing RCP motor lube oil collection system provides a level of safety equivalent to the technical requirements of Section Ill. 0 and, therefore, the exemption requested is granted RCP Remote Oil Fill System The RCP motor lube oil system does not comply with Section 111.0 because the oil collection tank is not sized to contain the entire lube oil system inventory. Section 111.0 of Appendix R to 10 CFR Part 50 requires that the licensees have a collection system "capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the RCP lube oil systems." It also specifies that "leakage points to be protected shall include lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on the RCPs." The underlying purpose of 10 CFR Part 50, Appendix R, Section 111.0, is to ensure that leaking oil will not lead to a fire that could damage SSD systems during normal or design basis accident conditions. In an exemption dated Jan 30, 1998, (Log No. 5205) the NRC stated the following: On the basis of the enclosed Safety Evaluation, the NRG staff concluded that the design of the oil filling system and the level of protection provided by the licensees through the use of certain compensatory measures during oil ftll operations provides reasonable assurance that a lube oil fire will not occur. The compensatory measures, as itemized in the licensees' November 18, 1997, exemption request, are: (1) The licensees will take the following compensatory actions each time oil is added" (a) Oil will be added only when a low oil level computer alarm is received on an RCP motor. (b) Only a predetermined amount of 011 necessary to clear the alarm (approximately three pints based on experience) will be initially added to the reservoir through the remote ftll line. A maximum total volume of four pints may be added in an attempt to clear the alarm. (c) The oil fill pot will be verified empty before the technician leaves the immediate area. Any spillage resulting from adding 011 to the remote oil fill pot will be cleaned up. Davis-Besse Page K-46 FE NOC Attachment K -Existing licensing Action Transition Licensing Action 12: Reactor Coolant Pumps Oil Collection System (d) Personnel responsible for adding the oil will be instructed to report (to the control room) any evidence of smoke during the oil addition process. If smoke is seen, the fire brigade will be immediately dispatched to the area. (2) In addition, a visual inspection will be conducted following refueling outages to confirm the integrity of the remote fill line system. The staff also concluded that a worst-case postulated fire, from not having a lube oil collection system for the RCP lube oil fill lines, would be of limited magnitude and extent. In addition, the staff concluded that such a fire would not cause significant damage in the containment building and would not prevent operators from achieving and maintaining safe shutdown conditions. Accordingly, in light of the foregoing, the staff concluded that application of this collection system requirement is not necessary to achieve the underlying purpose of the rule. Fire Compartment Description D-01 RCP Oil Collection Reference Document
* DB-MM-01013, Revision 5, "Mechanical Maintenance Procedure Lubricant Addition"
* Log No. 1586, "Exemption From Certain Requirements of Appendix R to 1 OCFR50"
* Log No. 5205, "Issuance of Exemption from the Requirements of 10 CFR Part 50, Appendix R"
* M-0400, Revision 18, "Piping & Instrument Diagram Reactor Coolant pump & Motor"
* M-103-65, Revision 6, "RC Pump Motor Oil Drain Tank (T156-1 & T156-2)"
* M-508-00058-07, Revision 7, "Reactor Coolant Pump Motor Part I of Ill"
* PM 0056, "SPV MP36-1 *Oil Lift* RCP #1-1"
* PM 0057, "SPV MP36-2 *Oil Lift* RCP #1-2"
* PM 0058, "SPV MP36-3 *Oil Lift* RCP #2-1"
* PM 0059, "SPV MP36-4 *Oil Lift* RCP #2-2" Davis-Besse Page K-47 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 12: Reactor Coolant Pumps Oil Collection System
* Serial No. 991, "Topic: Appendix R Exemption Requests, September 30, 1983"
* Serial No. 2493, "Request for Exemption from 10 CFR 50, Appendix R, Section 111.0, Oil Collection System for Reactor Coolant Pumps" Evaluation: RCP Oil Collection System By letter dated September 30, 1983, (Serial No. 991) DBNPS requested an exemption from 10 CFR 50 Appendix R Section 111.0 for the RCP oil collection system. An exemption was requested from the requirement for the RCPs collection system to be capable of collecting lube oil from leakage sites in the RCP lube oil system. The current system is in compliance with Section 111.0, except for the ability to collect oil from both pumps that serve a single reactor coolant loop. The DBNPS existing RCP oil collection system design meets the overall intent of 10 CFR 50, Appendix R, Section 111.0 in that no single failure of the RCP lubricating oil system will lead to a fire during normal operations or de.sign basis accident conditions. Upgrading of the current RCP lube oil collection system to collect the total capacity (450 gallons) of both pumps would not enhance to a significant degree the protection provided by the current system. Therefore, DBNPS requests an exemption for the capacity requirements of RCP oil collection system. RCP Remote Oil Fill System By letter dated November 18, 1997, (Serial No. 2493) an exemption from the requirements of 10 CFR Part 50, Appendix R, Section 111.0, regarding oil collection systems for reactor cool ant pumps was requested. The letter states: The remote oil fill lines are of a leak-tight design, and are only used infrequently. A hypothetical worst case oil spill and ignition will not impact post-fire safe shutdown capability. Administrative controls will be established to minimize the potential for an 011 fire due to a leak from the portions of the remote oil fill line that are not enclosed by an oil collection system. Based on the above, the underlying purpose of Appendix R, Section Ill. 0, which is to ensure that leaking oil will not lead to a fire which could damage safe shutdown systems during normal or design basis conditions, is accomplished without the installation of' an oil collection enclosure around the remote oil fill lines. \ The granting of this exemption request would have no impact on plant radiological or nonradiological effluents and involves no significant radiation exposure. Davis-Besse Page K-48 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 12: Reactor Coolant Pumps Oil Collection System Validation/Conclusions: Conformance with the Appendix R exemption agreements reached with the NRC for the RCP oil collection system, as stated in NRC exemption dated August 20, 1984, has been verified. Validation of the NRC exemption criteria was performed by review of station records as identified below. Validation findings support transition of the exemption. The as-built plant configuration verification process consisted of review of current plant procedures, plant drawings, and the design change control process documentation. A walkdown of the system was not necessary in order to verify the current design configuration of the systems adequately. Based on NRC exemption dated August 20, 1984, (Log No. 1586) the following criteria was selected for validation in order to carry this exemption forward: 1. Each RCP motor contains 225 gallons of oil or less.
* Review of the vendor manual, M-508-00058, ''RCP Motor Part I of Ill," confirms that each motor has an upper bearing oil pot capacity of 200 gallons and a lower bearing oil pot of 25 gallons, for a total volume of 225 gallons of oil. 2. Each RCP oil collection tank has a volume of 250 gallons.
* Review of Drawing M-103-65-6, "3600 RC Pump Motor Oil Drain Tank," confirms that each tank has an approximate fluid volume of 250 gallons. 3. The RCP oil collection tank configuration is such that only two RCP motors are connected to each tank.
* Review of Drawing M-040D, "Piping & Instrument Diagram Reactor Coolant Pump & Motor," confirms that the oil collection tank configuration is such that only two RCP motors are connected to each tank. In conclusion, although the information has been updated over time, the bases for previous acceptance are still valid, and the exemption for the RCP oil collection system will be transitioned to the new licensing basis under NFPA 805. Conformance with the Appendix R exemption agreements reached with the NRC to use the remote fill system without a collection system, as stated in NRC exemption dated January 30, 1998, has beeo verified. Validation of the NRC exemption criteria was performed by review of station records as identified below. Validation findings support transition of the exemption. The as-built plant configuration verification process consisted of the review of current plant procedures, plant drawings, and the design change control process documentation. A walkdown of the system was not necessary in order to verify the current design configuration of the systems adequately. Davis-Besse Page K-49 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 12: Reactor Coolant Pumps Oil Collection System Based on NRC exemption dated January 30, 1998, (Log No. 5205) the following compensatory measures were selected for validation in order to carry this exemption forward: 1. Oil will be added only when a low oil level computer alarm is received on an RCP motor. * . Review of Procedure DB-MM-01013 confirms that "Oil may only be added when a computer low level alarm is received." 2. Only a predetermined amount of oil necessary to clear the alarm (approximately 3 pints, based on experience) will be initially added to the reservoir through the remote fill line. A maximum total volume of four pints may be added in an attempt to clear the alarm).
* Review of Procedure DB-MM-01013 confirms that "A maximum of 4 pints may be added to clear the low oil alarm (typically 3 pints is adequate)." 3. The oil fill pot will be verified empty before the technician leaves the immediate area. Any spillage resulting from adding oil to the remote oil fill pot will be cleaned up.
* Review of Procedure DM-MM-01013 confirms that "The oil fill pot shall be verified empty and any spillage wiped up, prior to leaving the immediate area." 4. Personnel responsible for adding the oil will be instructed to report (to the Control Room) any evidence of smQke during the oil addition process. If smoke is seen, the fire brigade will be immediately dispatched to the area.
* Review of Procedure DB-MM-01013 confirms that "Evidence of smoke (caused by the oil addition process) shall be reported to the Control Room. The Fire Brigade should be dispatched immediately." 5. A visual inspection is conducted following refueling outages to confirm the integrity of the remote fill line system.
* Review of PMs 0056, 0057, 0058, and 0059 confirm that the following are included as part of a maintenance inspection, "Inspect the lower reservoir and associated piping for leakage" and "Inspect the RCP oil collection system piping and storage tanks for external oil leakage. Clean up any traces of oil." In conclusion, although the information has been updated over time, the bases for previous acceptance are still valid and will be transitioned to the new licensing basis under NFPA 805. Associations: Ch. 3 -Section: 3.3 /Subsection: 3.3.12 Davis-Besse Page K-50 FE NOC Licensing Action 12: Reactor Coolant Pumps Oil Collection System Ch. 3 -Section: 3.3 I Subsection: 3.3.12(1) Ch. 3 -Section: 3.3 I Subsection: 3.3.12(2) Ch. 3 -Section: 3.3 /Subsection: 3.3.12(4) Ch. 3 -Section: 3.3 /Subsection: 3.3.12(5) Ch. 4 -Compartment: D-01 Fire Protection -Compartment: D-01 I Form: Detection Davis-Besse Attachment K -Existing Licensing Action Transition Page K-51 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 13: Cold Shutdown Within 72 hours -Withdrawn The exemption for cold shutdown within 72 hours was withdrawn. See TR Section 2.2 for details. Davis-Besse Page K-52 L FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 14: Fire Compartment HH-01 An exemption has been approved from Section 111.G.3 to the extent it requires full, fixed, fire suppression and automatic detection in an area for which alternate shutdown capability is provided. The alternate shutdown capability is physically and electrically independent of Fire Compartment HH-01 (Appendix R Fire Area HH), according to NRC Letter (Log No. 6317), "Exemption from the requirements of 10 CFR 50, Appendix R, Section 111.G.3," July 21, 2005. Basis Date: 07/21/2005 To Be Transitioned? No Basis: The licensee requested an exemption (Serial No. 1327) from Section 111.G.3 of Appendix R that requires.that alternate or dedicated shutdown areas be provided with fixed fire suppression systems. Specifically, Fire Compartment HH-01 (Appendix R Fire Area HH) is not provided with a fixed suppression system. By letter dated April 18, 1990, (Log No. 3219) the NRC concluded that the exemption for Fire Area HH was not required because Generic Letter (GL) 86-10, "Implementation of Fire Protection Requirements," allowed performance-based evaluations for satisfying the applicable requirements of Appendix R. A later NRC inspection disputed that view, and a subsequent exemption was requested in Serial No. 3003. An exemption dated July 21, 2005, (Log No. 6317) contains the following: The licensee is requesting an exemption from the requirements of Section Ill. G. 3 to provide area-wide fire detection and fixed fire suppression in Fire Area HH Control room emergency ventilation systems are routed through Fire Area HH in the auxiliary building Fire Area HH is equipped with a fire detection system (covering approximately 96 percent of Fire Area HH), but no fixed suppression system is installed In summary, FENOC has requested an exemption from the 10 CFR Part 50, Appendix R, Section Ill. G.3 requirement for a fixed fire suppression system in Fire Area HH and for fire detection in the approximately 4 percent of Fire Area HH not equipped with a fire detection system. Fire Comparbnent Description HH-01 Control Room AC Equip. Room Davis-Besse PageK-53 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 14: Fire Compartment HH-01 Reference Document
* Serial No. 1327, "Topic: Appendix R Exemption Requests, January 12, 1987"
* Log No. 3219, "Exemption to 10CFR50, Appendix R, Section 111.G & 111.J"
* Log No. 6317, "Exemption from the requirements of 10 CFR 50, Appendix R, Section 111.G 3"
* Serial No. 3003, "Request for Exemption from 10 CFR 50, Appendix R, Section 111.G.3 for Fire Area HH" Evaluation: Per NRC letter dated July 21, 2005, (Log No. 6317) the NRC staff examined the licensee's rationale to support the exemption request and concluded that adequate DID and safety margins exist. Although fixed suppression is not installed in the area, the configuration of the area makes it unlikely that the cables of interest will be damaged by a fire in the area. Also, if the cables of interest are damaged, adequate assurance remains to demonstrate that the plant can be brought to a SSD condition. The NRC staff concluded that application of the regulation is not necessary to achieve the underlying purpose of the rule and that the requested exemption was acceptable, and in accordance with 10 CFR 50.12(a)(2)(ii). Validation/Conclusions: This compartment will be evaluated using the performance-based approach as identified in NFPA 805 Section 4.2.4. As such, the existing exemption will not be transitioned into the future license basis. Associations: None Davis-Besse PageK-54 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 15: Fireproof Coating for Structural Steel An alternative method has been approved from Section lll.G.2a to the extent it requires 3-hour fire rating for structural steel. The original plan was to have fireproofing of the structural steel in these rooms. However, the fireproofing coating could not be effectively installed. Basis Date: 07/17/1980 To Be Transitioned? Yes Basis: The licensee submitted a revision to the Davis-Besse Unit 1 Fire Hazards Analysis Report in a letter dated May 15, 1980. The Fire Hazards Analysis Report described changes to the fire protection methods for several rooms in which fire-proof coatings are to be applied to the structural steel. The alternative proposed is to install overhead sprinkler systems in the rooms instead of applying the fireproof coating. By letter dated July 17, 1980, (Log No. 582) the NRC concluded that the installation of the overhead sprinkler systems is an acceptable alternative to fireproof coating of the structural steel in these rooms. Fire Compartment A-07 AB-03 AB-05 DF-01 DG-01 V-01 Reference Document Description No. 2 Mechanical Penetration Room No. 1 Mechanical Penetration Room No. 3 Mechanical Penetration Room No. 2 Electrical Penetration Room No. 1 Electrical Penetration Room Storage
* Log No. 582, July 17, 1980. Room 236 208 303 427 402 405
* M-352, Revision 1, "Fire Protection Piping, Sprinkler System Room 208, Auxiliary Building Elev. 565'-0"."
* M-353, Revision 1, "Fire Protection Piping, Sprinkler System Room 236, Auxiliary Building Elev. 565'-0"." Davis-Besse Page K-55 IFPE RAI 07 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 15: Fireproof Coating for Structural Steel
* M-354, Revision 1, "Fire Protection Piping, Sprinkler System Room 303, Auxiliary Building Elev. 585'-0"."
* M-358, Revision 1, "Fire Protection Piping, Sprinkler System Room 402, Auxiliary Building Elev. 603'-0"."
* M-359, Revision 1, "Fire Protection Piping, Sprinkler System Room 405, Auxiliary Building Elev. 603'-0"."
* M-361, Revision 1, "Fire Protection Piping, Sprinkler System Room 427, Auxiliary Building Elev. 603'-0"." Evaluation: The alternative method dated July 17, 1980 states: By leUerdated May 15, 1980, you submiUed a revision to the Davis-Besse Unit No. 1 Fire Hazards Analysis Report. The revision describes proposed changes to the fire protection methods for several rooms in which the fire-proof coatings to be applied to structural steel, as called for in the original plan, could not be effectively installed The affected areas are rooms 208, 236, 303, 402, 405, and 427. The alternative you have proposed is to install overhead sprinkler systems in these rooms rather than to apply the nreptoof coatings. We ni7d that the alternative method which you have proposed for the above rooms will provide the protection that we intended in the Davis-Besse Fire Protection Safety Evaluation Report dated July 26, 1979. The changes are therefore acceptable. Validation/Conclusions: Conformance with the Appendix R alternative method agreements reached with the NRC regarding fireproofing the structural steel, as stated in NRC alternative method dated July 17, 1980, has been verified. The as-built plant configuration verification process consisted of review of current plant procedures, plant drawings, and the design change control process documentation. As stated above, validation of the alternative method criteria for this licensing action was performed by reviewing controlled procedures, drawings, and design control process documentation. Therefore, no walkdown of the areas evaluated was considered necessary. Based on NRC exemption dated July 17, 1980, (Log No. 582) the following criteria was selected for validation in order to carry this alternative method forward: Overhead sprinkler systems are installed in rooms 208, 236, 303, 402, 405, and 427. Davis-Besse Page K-56 I FPE RAI 07 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 15: Fireproof Coating for Structural Steel
* Review of Drawing M-353 confirms sprinklers are installed in Fire Compartment A-07, Room 236.
* Review of Drawing M-352 confirms sprinklers are installed in Fire Compartment AB-03, Room 208.
* Review of Drawing M-354 confirms sprinklers are installed in Fire Compartment AB-05, Room 303.
* Review of Drawing M-361 confirms sprinklers are installed in Fire Compartment DF-01, Room 303.
* Review of Drawing M-358 confirms sprinklers are installed in Fire Compartment DG-01, Room 402.
* Review of Drawing M-359 confirms sprinklers are installed in Fire Compartment V-01, Room 405. Associations: Fire Protection -Fire Compartment: A-07 I Form: Water-Based Suppression Fire Protection -Fire Compartment: AB-03 I Form: Water-Based Suppression Fire Protection -Fire Compartment: AB-05 /Form: Water-Based Suppression Fire Protection -Fire Compartment: DF-01 I Form: Water-Based Suppression Fire Protection -Fire Compartment: DG-01 I Form: Water-Based Suppression Fire Protection -Fire Compartment: V-01 I Form: Water-Based Suppression Davis-Besse Page K-57 I FPE RAI 07 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.01: 3.3.4 -Insulation Materials A deviation has been approved from BTP 9.5-1 Appendix A Position, Section D.1.d, pertaining to the combustibility of I FPE RAI .o5 foam insulation for the borated water storage tank and of piping and ductwork insulation. The BTP position is similar to NFPA 805 section 3.3.4 requiring thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials to be noncombustible or limited combustible. Basis Date: To Be Transitioned? Basis: May 30, 1991 Yes Deviation request transmitted by DBNPS letter dated January 6, 1988 (Serial No. 1456) provided additional information and justification for deviation in safety related water tanks and combustibility of piping and ductwork insulation. An NRC letter dated May 30, 1991 (Log No. 3480), was received that approved the deviation. DBNPS letter dated January 6, 1988 (Serial No. 1456) indicated the following in Attachment 4, Table 4-1: 'The BWST is provided with a thermal insulation system applied to its exterior sides (excluding roof). The insulation system consists of a spray applied foam insulation over a protective base coat and is top-coated The insulation has a flame spread rating of 25 per ASTM E-84. The topcoat can achieve a Class A coating system rating per UL 790. The condensate storage tank serves as the pnmaty suction source for the auxiliaty feedwater system. This system is only required when the main feedwater system is not available for removal of heat from the steam generators. The auxiliaty feedwater system also has available a secondaty source of water from the service water system which would automatically be aligned upon loss of the condensate storage tank source. The fire hazards evaluation discussed in Section 5 show that loss of the supply from any one of the above tanks would not preclude achieving a safe shutdown. Hose stations are available for all of the above tanks. Portable extinguishers are available for all tanks, with the clarification that an extinguisher would have to be obtained from inside the building for the BWST. The makeup tank (c) is located in a pit for shielding from radioactivity with a 4-foot-thick concrete hatch, and use of either the hose or extinguisher is highly unlikely. However; a fire in this pit is highly unlikely. Although a hydrogen line serves this tank, there is no ignition source present" Table 4-1 continued to state the following: Davis-Besse Page 58 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.01: 3.3.4 -Insulation Materials "In other areas regular pipe insulation is noncombustible calcium silicate. Anti-sweat pipe insulation was specified 25 I FPE RAI 05 flame, 50 smoke by the manufacturer, however, the 1975 UL Building Materials List (p. 75) indicates the supplied insulation tested better (i e., 25, 35 for flame, fuel and smoke, respectively). Refrigeration piping is insulated with a material rated 25 flame, 225 smoke by the manufacturer's literature and confirmed by correspondence. No "nationally" recognized testing laboratory" was indicated as the source for the 25, 225 rating. Duct work is insulated by matenal rated as 25, 50 by UL (1975 Building Matenals List P 175)." Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991.
* Serial No. 1456, "Fire Protection -Request for Additional Information (TAC Nos. 60994, 60995, and 61745)," January 6, 1988.
* Serial No. 1685," Fire Protection -National Fire Protection Association (NFPA) Code Review (TAC Numbers 60994, 60995 and 61745), July 31, 1989.
* BTP 9.5-1 Appendix A Position, Section D.1.d.
* Technical Specification 12501-C-4160 Rev 0, Section 4.2.
* Drawing 7749-C-0034, Rev 44.
* C-FP-013.10-006 Rev 4 Combustible Loading Calculation, Attachment 10.
* Technical Specification M-198N Section 4.1.4. Evaluation: The NRC letter dated May 30, 1991, (Log No. 3480) stated: "The borated water storage tank is coated with a foam insulation. The licensee affirms that the insulation has a flame spread rating of 25 when measured in accordance with the test method of ASTM Standard E-84. A hose house with sufficient lengths of fire hose to fight a fire at the tank is present in the area. Because the flammability characteristics of the insulation meet the staff guidelines in Appendix A to the B TP and because manual nre fighting equipment is available, the staff concludes that the foam insulation on the tank is acceptable. " Davis-Besse Page 59 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.01: 3.3.4 -Insulation Materials The NRG letter also stated: "In its comparison of the plant fire protection program with the guidelines in Appendix A to the B TP, the licensee identified a deviation pertaining to the combustibility of piping and ductwork insulation. Staff guidelines stipulate that insulation material should have a flame spread, smoke and fuel contribution rating of 25 or less as determined by the test method of ASTM E-84. As indicated by the licensee in its letter dated January 6, 1988, the insulation meets the flame spread rating but exceeds the smoke and fuel contribution rating. However, the staff concludes that the degree of deviation is insignificant from a safety standpoint based on the relatively limited quantity of insulation compared to other in-situ combustible materials and the active and passive fire protection features that compn"se the defense in depth philosophy of fire protection at the plant The staff, therefore, concludes that this deviation is acceptable. " Validation/Conclusions: The following conditions were cited in the NRG SER as the bases for the deviation approval for the borated water storage tank and pertaining to the combustibility of piping and ductwork insulation:
* The foam insulation on the BWST has a flame spread rating of 25 when measured in accordance with the test method of ASTM Standard E-84. ,_
* A hose house is available for the BWST with sufficient lengths of fire hose to fight a fire at the tank.
* Piping and ductwork insulation having a flame spread rating of 25 or less, but exceeding the smoke and fuel contribution rating, is of a limited quantity compared to other in-situ combustible materials, and there are active and passive fire protection features that comprise the fire protection defense-in-depth philosophy at the plant. Conformance has been verified with the Appendix R deviation agreements reached with the NRG regarding foam insulation for the borated water storage tank and pertaining to the combustibility of piping and ductwork insulation. The as-built plant configuration verification process consisted of review of current plant documents. Based on NRG deviation approval dated May 30, 1991 (Log No. 3480), the following criteria was selected for validation in order to transition this approval into the NFPA 805 licensing basis. Validation was performed by review of station records as identified below. 1. BWST insulation must comply with design specification C-4160. Section 4.2 of Technical Specification 12501-C-4160 Rev 0 states that the polyurethane foam insulation shall be North Carolina Foam Industries 362-82 as manufactured by North Carolina Foam Industries, or approved equal, having the following physical properties: Davis-Besse Page 60 I FPE RAI 05 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.01: 3.3.4 -Insulation Materials 2. 3. 4. a. R-value of 7 .0 per inch or greater b. Maximum 2 pounds per cubic foot density c. 25 flame spread -ASTM E-84 d. 25 pounds per square inch compressive strength e. 90% closed cell Drawing 7749-C-0034 Rev 44 confirms that hydrant #13 and hose house #13 are within close proximity to the borated water storage tank. Attachment 10 of Combustible Loading Calculation C-FP-013.10-006 Rev 4 lists the quantity of combustible Rubatex thermal insulation (installed on piping and HVAC ductwork). There were initially twelve rooms that included this insulation; however, modifications were made to remove quantities of the foam insulation. Therefore, now only nine rooms include Rubatex insulation, which is found in limited quantities. Section 4.1.4 of Technical Specification M-198N states that any piping requiring new installation of anti-sweat insulation shall be covered with Johns-Manville Flame-Safe A-P (or Micro-Lok 650) fiberglass insulation (or approved equal, both of which have flame spread ratings of 25 or less per their product data sheet), and Armstrong Armaflex or Rubatex elastomeric insulation is prohibited. 5. There are active and passive fire protection features that comprise the fire protection defense-in-depth philosophy at the plant, as shown in LAR Table 4-3. This table shows the credited active and passive fire protection features throughout the fire areas in Davis-Besse. The validation findings support transition of the deviation approval and conclude that the configuration is functionally equivalent to the code requirements. Associations: Fire Protection -Section 3.3 /Subsection: 3.3.4 Davis-Besse Page 61 IFPE RAI 05 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.02: 3.3. 7 .1 -Storage of Flammable Gas A deviation has been approved from NFPA SOA, Standard for Gaseous Hydrogen Systems at Consumer Sites. NFPA 805 section 3.3.7.1 requires hydrogen storage to be in accordance with NFPA SOA. Basis Date: May 30, 1991 To Be Transitioned? Yes Basis: Deviation request transmitted by DBNPS letter dated October 11, 1989 (Serial No. 1718) provided additional information on the NFPA Standard Compliance Review for deviation in NFPA SOA, Standard for Gaseous Hydrogen Systems at Consumer Sites. An NRC letter dated May 30, 1991, (Log No. 3480) was received that approved the deviation. DBNPS letter dated October 11, 1989 (Serial No. 1718) indicated the following in Attachment 1: "NFPA 50A -Request: Davis-Besse Standard section 8. 81 of the NFPA 50A review discussed the hydrogen tanks and mobile units system maintenance and stated the other system components are maintained in accordance with plant procedures. A request was made to more clearly explain the other system components and their procedures. Response: The system components include various devices which have individual preventive maintenance procedures to maintain the components. The interval of calibration/checking varies but the longest interval for the installed components on both the turbine and makeup tank hydrogen systems is 60 months. Also, the systems are operated and maintained by the following procedures: -SP 1106. 11, Carbon Dioxide and Hydrogen Systems (System procedure). -SP 1102 12, Hydrogen Addition and Degasification (System procedure). -DB-SC-04211, Generator Hydrogen Purity and Leakage Test (Penodic test scheduled every 28 days). " Page62 IFPE RAI 05 
' FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.02: 3.3.7.1 -Storage of Flammable Gas Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991.
* Serial No. 1718, "Fire Protection; Additional Information on the NFPA Standard Compliance Review," October 11, 1989.
* NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites.
* Procedure DB-SC-04211, Section 1.2.
* Procedure DB-OP-06210.
* Procedure DB-OP-06033'. Evaluation: The NRG letter dated May 30, 1991, (Log No. 3480) stated regarding the storage of flammable gases: 'Vuring its review of the NFPA conformance analyses, the staff requested clann"cation on a number of issues including ... maintenance of hydrogen system features .... The licensee provided satisfactory responses to these requests in its letter dated October 11, 1989. On this. basis, the staff concludes that this issue is resolved " Validation/Conclusions: The following conditions were cited in the NRG SER as the bases for the deviation approval:
* The licensee provided satisfactory response regarding maintenance of hydrogen system features. Conformance has been verified with the Appendix R deviation agreements reached with the NRG regarding deviation in storage of flammable gas dated May 30, 1991. The as-built plant configuration verification process consisted of review of current plant procedures. Based on NRG deviation approval dated May 30, 1991 (Log No. 3480), the following criteria was selected for validation in order to transition this approval into the NFPA 805 licensing basis. Validation was performed by review of station records as identified below.
* Per Serial 1718 dated October 11, 1989, the hydrogen system components have various devices that each have their own individual preventative maintenance procedures. The interval for calibration/checking varies, but the Davis-Besse Page63 I FPE RAI 05 I_ FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.02: 3.3. 7 .1 -Storage of Flammable Gas longest interval for the installed components on both the turbine and makeup tank hydrogen systems is 60 months. I FPE RAI os The systems are operated and maintained by the following procedures: a. DB-OP-06210 -C02 & Hydrogen System b. DB-OP-06033 -Hydrogen Addition and Degasification c. DB-SC-04211 -Generator H2 Purity and Leakage Test Section 1.2 of procedure DB-SC-04211 states that this procedure shall be performed once every 8 weeks or as directed by Engineering. Procedures DB-OP-06210 and DB-OP-06033 include items that are performed at intervals from normal daily operating checks/calibrations up to activities that are performed during plant shutdown. These procedures also reference applicable maintenance or vendor manuals to aid in the upkeep and calibration of the associated systems. The validation findings support transition of the deviation approval and conclude that the configuration is functionally equivalent to the code requirements. Associations: Fire Protection -Section 3.3 /Subsection: 3.3.7.1 Davis-Besse Page 64 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.03: 3.3.8 -Bulk Storage of Flammable & Combustible Liquids A deviation has been approved from NFPA 30, Flammable and Combustible Liquids Code. NFPA 805 section 3.3.8 requires bulk storage and use of flammable and combustible liquids to be in accordance with NFPA 30. Basis Date: May 30, 1991 To Be Transitioned? Yes Basis: Deviation request transmitted by DBNPS letter dated July 31, 1989 (Serial No. 1685) provided the NFPA code reviews and justification for deviation from NFPA 30, Flammable and Combustible Liquids Code. An NRC letter dated May 30, 1991, (Log No. 3480) was received that approved the deviation. DBNPS letter dated July 31, 1989 (Serial No. 1685) indicated the following on Page 17 of Attachment 15: "Status: Comply with Intent Evaluation: This section of the code specifies what quantities of liquids can be allowed outside the storage area. At DBNPS, the quantity of liquids are controlled per plant procedures and. when quantities of liquids are allowed which exceed the code compensatory measures are specified Conclusion: No further action is required " Reference Document
* DB-FP-00007, Revision 13, "Control of Transient Combustibles."
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991.
* Serial No. 1685," Fire Protection -National Fire Protection Association (NFPA) Code Review (TAC Numbers 60994, 60995 and 61745), July 31, 1989.
* NFPA 30, Flammable and Combustible Liquids Code. Evaluation: The NRC letter dated May 30, 1991, (Log No. 3480) stated: Davis-Besse Page 65 I FPE RAI 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.03: 3.3.8 -Bulk Storage of Flammable & Combustible Liquids ''Consequently, the licensee provided supplemental information which explicitly 1dentined deviations froin staff fire I FPE RAI 05 protection guidelines and the relevant National Fire Protection Association (NFPA) Standards and provided justification as to why these deviations were not safety signincant. The staff considers these deviations to fall within two categories. The first are those deviations which represent minor variances. These minor variances and those features of the Davis-Besse Are Protection Program which conform with NRG and NFPA criteria are descnbed comprehensively in the documents cited above and are not discussed in detail this safety evaluation since the staff nnds that the minor deviations are acceptable. The second category are those deviations which are not considered by the staff to be minor variances and for which there was, initially some concern on the part of the staff regarding the licensees justification of its technical approach. The staff's basis for accepting these latter deviations-is contained in the following evaluation. .. "Finally, in its comparison of the fire protection program with the criteria of NFPA Standard No. 30, the licensee identified a deviation in its letter dated July 31, 1989 pertaining to the quantity of flammable and combustible liqlJlds located outside of any storage area. To evaluate this issue, the staff reviewed Administrative Procedure DB-FP-00007 (Revision 00) which covers the control of transient combustibles. The procedure limits quantities of flammable and combustible liquids as well as other combustible materials to that necessary for plant operations. When excess quantities are present 1n an area, prior approval per the procedure is necessary and, in certain conngurations, additional compensatory nre protection measures are taken. The staff concludes that the subject procedure, and the noted deviation from NFPA Standard No. 30, are acceptable. " Validation/Conclusions: The following conditions were cited in the NRG SER as the bases for the deviation approval regarding bulk storage of flammable and combustible liquids relating to NFPA 805 section 3.3.8:
* Deviations regarding bulk storage were categorized as those which represent minor variances.
* Control of flammable and combustible liquids located outside of any storage areas is adequately controlled by Administrative Procedure DB-FP-00007. Conformance with the Appendix R deviation agreements reached with the NRG regarding bulk storage of flammable and combustible liquids, as stated in NRG deviation dated May 30, 1991, has been verified. The as-built plant configuration verification process consisted of review of current plant procedures. Davis-Besse Page 66 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.03: 3.3.8 -Bulk Storage of Flammable & Combustible Liquids Based on NRC deviation approval dated May 30, 1991 (log No. 3480), the validation findings support transition of the deviation approval and conclude that the configuration is functionally equivalent to the code requirements.
* The Administrative Procedure DB-FP-00007 is still valid for the control of flammable and combustible liquids located outside of any storage areas. Associations: Fire Protection -Section 3.3 I Subsection: 3.3.8 Davis-Besse Page 67 IFPE RAI 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.04: 3.5.1 -Water Supply Adequate Reliability, Quantity & Duration A deviation has been approved from BTP 9.5-1 Appendix A Position Section E.2 (d), pertaining to reliability and quantity I FPE RAJ 05 of the water supply, requiring tanks to be a minimum of 300,000 gallon capacity. The BTP position is similar to NFPA 805 section 3.5.1, requiring tanks to be a minimum of 300,000 gallon capacity. Basis Date: May 30, 1991 To Be Transitioned? Yes Basis: Deviation request transmitted by DBNPS letter dated January 6, 1988 (Serial No. 1456) provided additional information and justification for deviation regarding adequate reliability, quantity, and duration for the water supply. An NRC letter dated May 30, 1991, (Log No. 3480) was received that approved the deviation. DBNPS letter dated January 6, 1988 (Serial No. 1456) indicated the follo_wing in Attachment 4, Table 4-1: ''Two separate reliable water supplies are provided The electric fire pump is supplied by a 250, 000-gallon water source which is stored in the above ground fire water storage tank. The diesel nre pump takes its water under a static head from Lake Ede. The two water supplies and pumps are not interconnected because of the reliability of the nre water sources. " It further states: "The largest water spray system flow plus 1000 gpm was not considered when the tank was sized since this system is installed on the main transformer locateil outside and 54 feet away from the closest exposed (Turbine Building) structure. The second nre water supply, Lake Ede, is considered an unlimited supply of water available to manual fire fighting and automatic water suppression systems,* thus, the quantity of the available nre water is considered acceptable. " Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991.
* Serial No. 1456, "Fire Protection -Request for Additional Information (TAC Nos. 60994, 60995, and 61745)," January 6, 1988.
* BTP 9.5-1 Appendix A Position, Section E.2 (d). Davis-Besse Page 68 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.04: 3.5.1 -Water Supply Adequate Reliability, Quantity & Duration
* FHAR Rev 26.
* Calculation C-FP-013.03-002 Rev 0. Evaluation: The NRG letter dated May 30, 1991, (Log No. 3480) stated: "The fire protection water supply consists of an electric fire pump which takes suction from a 250, 000 gallon tank and a diesel pump which draws water from Lake Ede. The tank is not sized in accordance with Appendix A to the B TP, nor are the two fire protection water supplies directly interconnected The staff considers the size of the tank to be sufficient because the criteria of Appendix A to the B TP used to determine the required water storage capacity at Davis-Besse assumes 1, 000 gallons per minute (gpm) for nre hose streams. However; the actual capability of the licensees fire brigade to deliver water during a fire is in the range of 250 to 500 gpm with a n*ve person fire brigade using the 1 1/2 and 2 1/2 inch hoses. Moreover; if addttional water greater than the tank capacity is required, an unlimited supply exists from the adjacent lake. Interconnection of the nre protection water supplies is not considered necessary because each pumping system supplying water is sufficiently reliable based on the performance of periodic testing and maintenance and because either pump is capable of satisfying the water demand requirements. The staff therefore, concludes that the fire protection water supply is acceptable even though 1t deviates from NRC nre protection guidelines. " Validation/Conclusions: The following conditions were cited in the NRG SER as the bases for the deviation approval for adequate reliability, quantity, and duration for the water supply:
* The electric fire pump takes suction from a 250,000 gallon tank.
* The diesel pump draws water from Lake Erie.
* The criteria of Appendix A to the BTP used to determine the required water storage capacity at Davis-Besse assumes 1,000 gallons per minute (gpm) for fire hose streams. However, the fire brigade delivers water in the range of 250 to 500 gpm with a five person fire brigade using the 1 1/2 and 2 1/2 inch hoses. Conformance has been verified with the Appendix R deviation agreements reached with the NRG regarding adequate reliability, quantity, and duration for the water supply, as stated in NRG deviation dated May 30, 1991. The as-built plant configuration verification process consisted of review of current plant procedures. Davis-Besse Page 69 IFPE RAJ 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.04: 3.5.1 -Water Supply Adequate Reliability, Quantity & Duration Based on NRC deviation approval dated May 30, 1991 (Log No. 3480), the following criteria was selected for validation in I FPE RAI o5 order to transition this approval into the NFPA 805 licensing basis. Validation was performed by review of station records as identified below. 1. Per the FHAR Rev 26, the Fire Water Storage Tank holds at least 250,000 gallons (water level of at least 30 feet) where the tank level is verified at least once every seven days and requires an action when the level is lower. Section 9.1.2.1 of the FHAR Rev 26 states that the 2500 gpm electric fire pump takes suction from the storage tank and is shown in Figure 9-7. The diesel vertical fire pump takes suction from the intake forebay from Lake Erie and is shown in Figure 9-8. 2. Section 8.3 of the FHAR Rev 26 states that the onsite fire brigade is composed of a minimum of 5 members with staffing maintained onsite at all times. The fire brigade staffing may be less than the minimum for a period of time not to exceed 2 hours in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions. 3. C-FP-013.03-002 Rev 0 provides an evaluation of the flowrates at hose stations HCS-32, HCS-41, and HCS-48 and at hose reels HR-50 and HR-51. Per Table 6 on page 13 of Attachment 3, the maximum hose station flow rates range from 263 to 590 gpm. This confirms that a single hose station typical to Davis-Besse will deliver approximately 250 -500 gpm as originally stated in Log No. 3480 SER. The validation findings support transition of the deviation approval and conclude that the configuration is functionally equivalent to the code requirements. Associations: Fire Protection -Section 3.5 I Subsection: 3.5.1 Davis-Besse Page70 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.05: 3.5.2 -Water Tanks A deviation has been approved from BTP 9.5-1 Appendix A Position, Section E.2 (d), pertaining to water supply tanks. I FPE RAI as The BTP position is similar to NFPA 805 section 3.5.2 requiring tanks to be interconnected such that fire pumps can take suction from either or both. A failure in one tank or its piping shall not allow both tanks to drain. Basis Date: May 30, 1991 To Be Transitioned? Yes Basis: Deviation request transmitted by DBNPS letter dated January 6, 1988 (Serial No. 1456) provided additional information and justification for deviation in water tanks. An NRG letter 9ated May 30, 1991, (Log No. 3480) was received that approved the deviation. Letter dated January 6, 1988 (Serial No. 1456) indicated _the following in Attachment 4, Table -4-1: 'Two 100 percent 2500 gpm U.L. listed fire pumps supply water for fire protection needs. They are in separate buildings and taking water from different sources located on the same side of the unit. The installation of the fire pumps utilize NFPA 20. It further states: "Two separate reliable water supplies are provided The electric fire pump is supplied by a 250, 000-gallon water source which is stored in the above ground nre water storage tank The diesel fire pump takes its water under a static head from Lake Erie. The two water supplies and pumps are not interconnected because of the reliability of the nre water sources. " Table 4-1 also states: "The largest water spray system flow plus 1000 gpm was not considered when the tank was sized since this system is installed on the main transformer located outside and 54 feet away from the closest exposed (Turbine Building) structure. The second fire water supply, Lake Erie, is considered an unlimited supply of water available to manual nre fighting and automatic water suppression systems,* thus, the quantity of the available fire water is considered acceptable. " Davis-Besse Page 71 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.05: 3.5.2 -Water Tanks Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991.
* Serial No. 1456, "Fire Protection -Request for Additional Information (TAC Nos. 60994, 60995, and 61745)," January 6, 1988.
* BTP 9.5-1 Appendix A Position, Section E.2 (d).
* FHAR Rev 26, Section 8.1.2. Evaluation: The NRG letter dated May 30, 1991, (Log No. 3480) stated: "The fire protection water supply consists of an electric fire pump which takes suction from a 250, 000 gallon tank and a diesel pump which draws water from Lake Erie. The tank is not sized in accordance with Appendix A to the B TP, nor are the two nre protection water supplies directly interconnected The staff considers the size of the tank to be sufficient because the criteria of Appendix A to the B TP used to determine the required water storage capacity at Davis-Besse assumes 1, 000 gallons per minute (gpm) tor nre hose streams. However, the actual capability of the licensees fire bdgade to deliver water during a nre is in the range of 250 to 500 gpm with a n've person nre brigade using the 1 1/2 and 2 1/2 inch hoses. Moreover, if additional water greater than the tank capacity is required, an unlimited supply exists from the adjacent lake. Interconnection of the nre protection water supplies is not considered necessary because each pumping system supplying water is sufficiently reliable based on the performance of penodic testing and maintenance and because either pump is capable of satisfying the water demand requirements. The staff therefore, concludes that the nre protection water supply is acceptable even though it deviates from NRG nre * -proteclton guidelines. "
* Validation/Conclusions: The following conditions were cited in the NRG SER as the bases for the deviation approval for water tanks, relative to the requirement that tanks be interconnected such that fire pumps can take suction from either or both:
* Each pumping system supplying water is sufficiently reliable based on the performance of periodic testing and maintenance. Davis-Besse Page 72 IFPE RAI 05 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.05: 3.5.2 -Water Tanks
* Either pump is capable of satisfying the water demand requirements. I FPE RAI os Conformance has been verified with the Appendix R deviation agreements reached with the NRG regarding water tanks, as stated in NRG deviation dated May 30, 1991. The as-built plant configuration verification process consisted of review of current plant procedures. Based on NRG deviation approval dated May 30, 1991 (Log No. 3480), the following criteria was selected for validation in order to transition this approval into the NFPA 805 licensing basis. Validation was performed by review of station records as identified below. 1. Per Section 8.1.2 of FHAR Rev 26, the fire suppression water system shall be operable with the following: a. Two operable fire suppression pumps with their discharge aligned to the fire suppression header b. An operable ultimate heat sink c. An operable fire water storage tank d. An operable flow path capable of taking suction from the ultimate heat sink or the fire water storage tank and transferring water though distribution piping with operable sectionalizing valves to the yard fire hydrant curb valves and the first valve ahead of the water flow alarm device on each sprinkler, deluge system and fire hose station/connection standpipe required to be operable.
* Additional actions apply to the following: a. With the fire water storage tank or the ultimate heat sink inoperable, confirm the operability of the alternate water supply with one hour and every 24 hours thereafter. -b. With either one of the fire pumps inoperable, verify the operability of the remaining pump within 24 hours and every seven days thereafter. c. With the fire suppression water system otherwise inoperable, establish a backup fire suppression system within 24 hours. Otherwise action shall be taken within one hour to be in hot standby within six hours, hot shutdown within the following six hours, and cold shutdown within the subsequent 24 hours. Section 8.1.2 of FHAR Rev 26 includes surveillance requirements for the fire water storage tank, ultimate heat sink, fire suppression water system, electric motor driven fire pump, and diesel driven fire pump. Davis-Besse Page 73 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.05: 3.5.2 -Water Tanks 2. The two fire pumps are each designed as 100 percent and FHAR continues to require periodic surveillance to ensure pump capacity and reliability. Section 8.1.2 of FHAR Rev 26 describes the surveillance requirements for both the electric and diesel driven fire pump where they must demonstrate the following: a. Electric motor driven fire pump shall be demonstrated operable i. At least once per 31 days on a staggered test basis by starting the electric motor driven fire pump and operating for at least 15 minutes. ii. At least once per operating cycle by verifying the electrical motor driven fire pump starts automatically on a decreasing fire suppression water system pressure of at least 115 psig and maintains the fire suppression water system pressure psig. iii. At least once per operating cycle by verifying the electric motor driven fire pump develops at least 2500 gpm at a system head of 277 feet discharge pressure. b. Diesel driven fire pump shall be demonstrated operable i. At least once per 31 days on a staggered test basis by starting the diesel driven fire pump from ambient conditions and operating it for at least 30 minutes on recirculation flow. ii. At least once per 31 days by verifying fire pump day tank contains at least 171 gallons of fuel (fuel level of at least 18.6 inches). iii. At least once per operating cycle by verifying the diesel driven fire pump starts automatically (after the sequence starting relay has timed out) and maintains fire suppression water system pressure psig, from: 1) ambient conditions on decreasing fire suppression water system pressure of at least 95 psig, 2) simulated decreasing fire water storage tank level of at least three feet and 3) loss of power to the diesel driven fire pump controller. iv. At least once operating cycle by verifying the diesel driven fire pump develops at least 2500 gpm at a system head of 277 feet discharge pressure. v. At least once per operating cycle by subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for the class of service. Davis-Besse Page 74 I FPE RAI 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.05: 3.5.2 -Water Tanks vi. At least once per 61 days by verifying the electrolyte level of each cell is above the plates, and overall *voltage of the diesel driven fire pump battery bank when not discharging is greater than or equal to 24 volts. vii. At least once per 92 days by verifying that the specific gravity of each diesel driven fire pump starting battery is appropriate for continued service of the battery. viii. At least once per 18 months by verifying that the diesel driven fire pump starting batteries, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration. ix. At least once per 18 months by verifying that the battery-to-battery and terminal connections of each diesel driven fire pump staring battery are clean, tight, free of corrosion, and coated with an anti-corrosion material. The validation findings support transition of the deviation approval and conclude that the configuration is functionally equivalent to the code requirements. Associations: Fire Protection -Section 3.5 I Subsection: 3.5.2. Davis-Besse Page 75 I FPE RAI 05 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.06: 3.5.10 -Underground Yard Fire Main Loop A deviation has been approved from NFPA 24, Standard for the Installation of Private Fire Service Mains and their Appurtenances. NFPA 805 section 3.5.10 requires the underground yard fire main loop to be designed and installed in accordance with NFPA 24. Basis Date: May 30, 1991 To Be Transitioned? Yes Basis: Deviation request transmitted by DBNPS letter dated July 31, 1989 (Serial No. 1685) provided the NFPA code reviews and justification for deviation from NFPA 24, Standard for the Installation of Private Fire Service Mains and their Appurtenances. An NRC letter dated May 30, 1991, (Log No. 3480) was received that approved the deviation. DBNPS letter dated July 31, 1989 (Serial No. 1685) introduced the NFPA 24 code review by stating the following on Page 1 of Attachment 12: "1. 0 INTRODUCTION The National Are Protection Association Standard for Outside Protection (NFPA 24) was reviewed for compliance. This review was performed to document the adequacy of the Davis-Besse fire protection features. 20SUMMARY Davis-Besse The DBNPS underground fire protection water distribution system, nre hydrants, and hose houses satisfy the majority of the requirements set forth in NFPA 24-1973. The design, supply, and layout of the water distribution system is adequate and provides a reliable distribution system for fire protection water. Maintenance of valves, hydrants, and hose houses and equipment and implementation of surveillance procedures for the affected equipment is done on a continuing basis. There are a few sections of NFPA 24-1973 with which Davis-Besse does not comply. For the performance of this evaluation the requirementof''approved"was defined as being UL listed or FM approved Some piping was not lined (intemal/y) and the lining, where used, was not approved or used on approved pipe. Based on the serviceab1lily of the system since its installation and the adequacy of the material standards no modifications are required The periodic flow tests and flow factors will be trended to monitor any degradation of the pipe in tenor and flow capacity. ,, Page76 IFPE RAI 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.06: 3.5.10-Underground Yard Fire Main Loop Attachment 12 of Serial No. 1685 goes on to provide an evaluation of each code section that was identified as "comply J FPE RAI 05 with intent." The evaluation of these deviations to NFPA 24 were documented as being acceptable; no modifications were required for this review. Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991.
* RIN 3150-AG48, "Voluntary Fire Protection Requirements for Light Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative," Federal Register, Volume 69, No. 115, June 16, 2004.
* Serial No. 1685, "Fire Protection -National Fire Protection Association (NFPA) Code Review (TAC Numbers 60994, 60995 and 61745), July 31, 1989.
* NFPA 24, Standard for the Installation of Private Fire Service Mains and their Appurtenances.
* FHAR Rev 26, Section 8.
* M-0016A Rev 57. Evaluation: The NRG letter dated May 30, 1991, (Log No. 3480) stated: ''In its letters dated May 23, 1988 and July 31, 1989, the licensee submitted a comparison of the Davis-Besse Fire Protection Program to the applicable NFPA standards. A number of deviations from these standards indicated in this analysis have been identified for correction. A summary of the proposed modifications in these two letters and the implementing schedules have been reviewed by the staff and found to be acceptable. One of the deviations the licensee identified is the absence of documentation for the water supply system,* this documentation would have provided third party approval of certain equipment However, in light of the continuing serviceability of the water supply since its installation and the cost associated with providing third party documentation for this the staff does not consider any further effort by the licensee to be justified The licensee also indicated that certain components did not conform with some of the construction specifications identified in the applicable NFPA Standards. The licensee affirmed in the letters cited above that the construction maten"als and their performance charactenstics are at least equivalent to those that are identified in the pertinent NFPA Standards. On this basis, the staff finds these deviations acceptable. " Davis-Besse Page 77 FE NOC
* Attachment K -Existing Licensing Action Transition Licensing Action 16.06: 3.5.10-Underground Yard Fire Main Loop Validation/Conclusions: The following conditions were cited in the NRG SER as the bases for the deviation approval for the underground suppression piping not installed in a code approved configuration:
* Continuing serviceability of the water supply system since its installation
* Construction materials and their performance characteristics are at least equivalent to those that are identified in the pertinent NFPA standard Conformance has been verified with the Appendix R deviation agreements reached with the NRG regarding headers. The as-built plant configuration verification process consisted of review of current plant procedures. Based on NRG deviation approval dated May 30, 1991 (Log No. 3480), the following criteria was selected for validation in order to transition this approval into the NFPA 805 licensing basis. Validation was performed by review of station records as identified below. 1. Section 8 of FHAR Rev 26 includes surveillance requirements for the fire protection systems related to the Underground Yard Fire Main Loop including: a. Fire Suppression Water System b. Sprinkler/Water Curtain Deluge Systems c. Sprinkler/Deluge System d. Fire Hose Station/Connections e. Yard Fire Hydrants and Hose Houses 2. Drawing M-0016A Rev 57 depicts the underground piping as line class KEE where the details of the class are listed in M-0601 Rev 27. 3. Specification C-050 provides equivalent requirements to NFPA 24 for the small portion of concrete underground pipe that crosses the circulating water canal. The validation findings support transition of the deviation approval and conclude that the configuration is functionally equivalent to the code requirements. Davis-Besse Page 78 I FPE RAI 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.06: 3.5.10-Underground Yard Fire Main Loop Associations: I FPE RAI 05 Fire Protection -Section 3.5 /Subsection: 3.5.10 Davis-Besse Page 79 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.07: 3.5.13 -Headers / NFPA 805 section 3.5.13 requiring ANSI B31.1, Code for Power Piping, for headers supplying seismically-designed hose I FPE RAI os standpipe systems is excluded from applicability to Davis-Besse based on the current licensing basis. The BTP 9.5-1 Appendix A Position, Section E.3 (d), requirement for seismically-designed hose standpipe system only applied to plants that did not have a construction permit as of 7/1/1976. Because Davis-Besse was under construction, they were approved without seismically-designed hose standpipes and hose stations. Basis Date: May 30, 1991 To Be Transitioned? Yes Basis: Appendix A to Branch Technical Position APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior To July 1, 1976," was provided in two-column format, with separate requirements for plants with "application docketed but construction permit not received as of 7 /1 /1976" compared to requirements for "plants under construction and operating plants." Because Davis-Besse was in the process of receiving their operating license at the time, the second column provided the applicable licensing basis. BTP 9.5-1 Appendix A Position, Section E.3 (d), requirement for seismically-designed hose standpipe system only applied to plants that did not have a construction permit as of 7/1/1976. The Davis-Besse standpipe and hose system was approved by NRC letter dated May 30, 1991 (Log No. 3480). Therefore at the time of original construction and commercial operation, Davis-Besse was not required to design the installation of its fire suppression and standpipe hose systems to be seismically qualified. Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991 ..
* RIN 3150-AG48, "Voluntary Fire Protection Requirements for Light Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative," Federal Register, Volume 69, No. 115, June 16, 2004.
* ANSI B31.1, Code for Power Piping.
* BTP 9.5-1 Appendix A Position, Section E.3 (d).
* DB-FP-00009, Fire Protection Impairment and Fire Watch. Davis-Besse Page BO FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.07: 3.5.13 -Headers Evaluation: The NRC letter dated May 30, 1991, (Log No. 3480) stated: "In its leUers dated May 23, 1988 and July 31, 1989, the licensee submitted a companson of the Davis-Besse Fire Protection Program to the applicable NFPA standards. A number of deviations from these standards indicated in this analysts have been identified for correction. A summary of the proposed modifications in these two leUers and the implementing schedules have been reviewed by the staff and found to be acceptable. One of the deviations the licensee identified is the absence of documentation for the water supply system,* this documentation would have provided third party approval of certain equipment. However; in light of the continuing serviceability of the water supply since its installation and the cost associated with providing third party documentation for this equipment the st?ff does not consider any further effort by the licensee to be justified The licensee also indicated that certain components did not conform with some of the construction specifications identified in the applicable NFPA Standards. The licensee affirmed in the leUers cited above that the construction materials and their performance characteristics are at least equivalent to those that are identified in the pertinent NFPA Standards. On this basis, the staff finds these deviations acceptable. " It further concludes: ''Based on the above review and evaluation of the licensees fire protection pro,gram, and subject to the approved deviations and exemptions and the licensees commitments to implement various additional fire protection measures during the seventh and eighth refueling outages, the staff concludes that the fire protection program at Davis-Besse conforms with the guidelines in Appendix A to the B TP, the requirements of Appendix R to 10 CFR Part 50 and the supplemental staff guidance on fire protection, and is acceptable. " NRC issued notice of final rule (RIN 3150-AG48) in Federal Register, Volume 69, No. 115, dated June 16, 2004 regarding Voluntary Fire Protection Requirements for Light Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative: *''A commenter noted that Appendix A to B TP APCSB 9. 5-1 did not require seismically qualified standpipes and hose stations for operating plants and plants with construction permits issued prior to July 1,-19 76. NRG agrees that Appendix A to B TP APCSB 9. 5-1 made separate provisions for operating plants and plants with construction permits issued prior to July 1, 19 76, and did not require seismically qualified standpipes and hose stabons for those plants. Therefore, the requirement in Section 3. 6. 4 of NFPA 805 is not applicable to licensees with nonseismic standpipes and hose stations previously approved in accordance with Appendix A to B TP APCSB 9. 5-1. " Davis-Besse Page 81 I FPE RAI 05 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.07: 3.5.13 -Headers Validation/Conclusions: Based on the previous approval of the yard main system, the requirements of section 3.5.13 are not applicable to Besse. Based on NRC approval dated May 30, 1991 (Log No. 3480), there is no applicable criteria for validation in order to carry this deviation forward. The validation findings support transition of the deviation approval. Associations: Fire Protection -Section 3.5 I Subsection: 3.5.13 Davis-Besse Page 82 IFPE RAI 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.08: 3.6.1 -Standpipe and Hose Systems A deviation has been approved from NFPA 14, Standard for the Installation of Standpipe, Private Hydrant, and Hose I FPE RAI 05 Systems. NFPA 805 section 3.6.1 requires Class Ill standpipe and hose systems to be installed in accordance with NFPA 14. Basis Date: May 30, 1991 Yes To Be Transitioned? Basis: A deviation request transmitted by DBNPS letter dated January 6, 1988 (Serial No. 1456) and October 11, 1989 (Serial No. 1718) provided information and justification for deviation of the hose standpipe systems. Another letter dated July 31, 1989 (Serial No. 1685) provided the NFPA code reviews and justification for deviation from NFPA 14, Standard for the Installation of Standpipe, Private Hydrant, and Hose Systems. An N RC letter dated May 30, 1991, (Log No. 3480) was received that approved the deviations. Letter dated January 6, 1988 (Serial No. 1456) indicated the following in Attachment 4, Table 4-1: ''Individual standpipes are at least 4-inch diameter for multiple hose connections and 2-1/2-inch pipe for single hose connections. The standpipe system is seismically supported in areas containing safety systems in the auxiliary building The standpipes and hose station system in the turbine bwlding and auxiliary building were designed in utilizing NFPA-14 for sizing, spacing, and pipe support. Certain deviations from the requirements of NFPA 14 are due to plant specific configurations and operations not anticipated by general requirements. Known deviations are identified in the Fire Protection Program. " Letter dated July 31, 1989 (Serial No. 1685) indicated the following in Attachment 9: *1":"* ''Hose system: All Standpipe: All Hose Station(s): All Code Section Deviated from: 1-9, 4-3.1, 4-5 1 Status: Comply with Intent Subject: Approved Devices Davis-Besse Page 83 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.08: 3.6.1 -Standpipe and Hose Systems Evaluation: The standard required all devices and materials used in standpipe systems to be approved For the I FPE RAI os authority having jurisdiction to approve devices, a UL listing or FM approval is desired Hose cabinets, hose reels, and nozzles are not UL listed or FM approved
* Hose reels are Seco model 1000-1012 manufactured by Seco manufacturing, Wanseon, Ohio. The hose reels were compared to the UL test standard for hose reels and meet or exceed the test criteria. Therefore, the unlisted hose reels are acceptable based on the fact that they meet or exceed the UL test criteria. Hose cabinets are not UL listed, however, they adequately perform the function for which they are intended and can be considered approved Nozzles are Akron, Marauder Model 4616. The nozzles are not listed but meet the test criteria established by UL; the nozzles are constant flow, rated for pressure :::: 100 psi, usable on Class A or B fires, usable with lined or unlined hose and are equipped with threads that comply with NHST. Since the nozzle complies with the UL test standard, the nozzles are acceptable. Conclusion: Although the devices are not listed, they have been compared to the standards used by UL to provide listing and are adequate. Therefore, the equipment complies w1lh the intent of the standard Letter dated October 11, 1989 (Serial No. 1718) stated the following: "NFPA 14 -Request Davis-Besse Standard sections 3-2 1 and 3-3. 4 of the NFPA 14 Code review have a fire hose reach deficiency identified for Room 250. An explanation was requested to describe how this will be overcome by the nre brigade. Response: The protection provided by hose stations is not needed in the Service Water/Turbine Building tunnel (Room 250) due to the limited amount of combustibles in the area, the lack of ignition source, the kaowool cable tray covering and the nre suppression capabilities provided at each end of the tunnel The fire brigade has information provided in the existing pre-nre plans for location of additional hose when needed for certain fire areas. This is described in the pre-fire plans specifically ... Room 250. ,, (Room 250 is now part of Fire Compartment BG-01.) Page84 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.08: 3.6.1 -Standpipe and Hose Systems Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991.
* Serial No. 1456, "Fire Protection -Request for Additional Information (TAC Nos. 60994, 60995, and 61745)," January 6, 1988.
* Serial No. 1685," Fire Protection -National Fire Protection Association (NFPA) Code Review (TAC Numbers 60994, 60995 and 61745), July 31, 1989.
* Serial No. 1718, "Fire Protection; Additional Information on the NFPA Standard Compliance Review," October 11, 1989.
* NFPA 14, Standard for the Installation of Standpipe, Private Hydrant, and Hose Systems.
* FHAR Rev 26, Section 8.2.3. Evaluation: The NRG letter dated May 30, 1991, (Log No. 3480) stated: ''As part of its comparison of the design of the standpipe and hose system to NRG fire protection guidelines and the criteria contained in NFPA Standard No. 14, the licensee identified several deviations in its letters dated January 6, 1988 and July 31, 1989. Several of these deviations pertain to the use of unlisted use of materials which do not meet the construction specifications of this standard, and the nature of the acceptance testing. The staff reviewed these deviations, including the licensee's justification and concludes that these conditions will not adversely affect system petformance and are, therefore, acceptable based on the continuing acceptable petformance of these system." Validation/Conclusions: The following conditions were cited in the NRG SER as the bases for the deviation approval in standpipe and hose systems:
* Continuing acceptable performance of the standpipe and hose systems. Davis-Besse Page 85 I FPE RAI 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.08: 3.6.1 -Standpipe and Hose Systems Conformance has been verified with the Appendix R deviation agreements reached with the NRC regarding standpipe I FPE RAI 05 and hose stations, as stated in NRC deviation dated May 30, 1991. The as-built plant configuration verification process consisted of review of current plant procedures. Based on NRC deviation approval dated May 30, 1991 (Log No. 3480), the following criteria was selected for validation in order to transition this approval into the NFPA 805 licensing basis. Validation was performed by review of station records as identified below.
* Section 8.2.3 of FHAR Rev 26 states the surveillance requirements of Fire Hose Stations/Connections and requires continuing acceptable system performance, consistent with the NRC statement in Log No. 3480 SER. The validation findings support transition of the deviation approval and conclude that the configuration is functionally equivalent to the code requirements. Associations: Fire Protection -Section 3.6 I Subsection: 3.6.1 Davis-Besse Page 86 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.09: 3.6.2 -Water Flow and Nozzle Pressure A deviation has been approved from BTP 9.5-1 Appendix A Position, Section E.3 (d), pertaining to fire hose standpipe I FPE RAI 05 system water flow and nozzle pressure. The BTP position is similar to NFPA 805 section 3.6.2 requiring an adequate water flow rate and nozzle pressure for all hose stations, including the provision of hose station pressure reducers where necessary. Basis Date: May 30, 1991 To Be Transitioned? Yes Basis: A deviation request transmitted by DBNPS letter dated January 6, 1988 (Serial No. 1456) provided information and justification for deviation with the water flow and nozzle pressure. Another letter dated July 31, 1989 (Serial No. 1685) provided the NFPA code reviews and justification for deviation in NFPA 14, Standard for the Installation of Standpipe, Private Hydrant, and Hose Systems. An NRG letter dated May 30, 1991, (Log No. 3480) was received that approved the deviations. DBNPS letter dated January 6, 1988 (Serial No. 1456) indicated the following in Attachment 4, Table 4-1: ''Individual standpipes are at least 4-inch diameter for multiple hose connections and 2-1/2-inch pipe for single hose connections. The standpipe system is seismically supported in areas containing safety systems in the auxiliary building. The standpipes and hose station system in the turbine building and auxiliary building were designed in utilizing NFPA-14 for sizing, spacing, and pipe support. Certain deviations from the requirements of NFPA 14 are due to plant specific configurations and operations not anticipated by general requirements. Known deviations are identified in the Fire Protection Program. " Letter dated July 31, 1989 (Serial No. 1685) indicated the following in Attachment 9: ''Hose system: All Standpipe: All Hose Station(s): All Code Section Deviated from: 2-1.2 Status: Comply with Intent Subject: Water Supply Davis-Besse Page 87 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.09: 3.6.2 -Water Flow and Nozzle Pressure Evaluation: The code required each standpipe to be sized for a flow of 500 gpm. The code also requires all common I FPE RAI 05 supply piping to be sized for 500 gpm for the first standpipe and 250 gpm for each additional standpipe up to 2500 gpm. Only standpipes AB-1 and AB-12 are not sized per the code. Based on hydraulic calculations, the 2 1/2 inch pipe installed at these two standpipes can provide the flow necessaty to fight a fire in the plant Standpipe AB-1 supplies hose stations HCS 32 and HCS 48. Standpipe AB-1 can supply approximately 260 gpm at 69 psi to either HCS 32 or ACS 48. The flow and pressure available at either HCS 32 or HCS 48 is adequate based on the following conditions. HCS 32 and HCS 48 are located in separate fire areas which means that both hose stations are not likely to be required at the same time to combat a fire. This means that the design basis for water supply for either of these hose line stations is the demand necessaty to supply a single hose and 260 gpm at 69 psi is more than adequate to supply a single hose line. Standpipe AB-12 supplies hose reels HR 50 and HR 51. Standpipe AB-12 can supply approximately 290 gpm at 65 psi to either HR 50 or HR 51. The flow and pressure available at either HR 50 or HR 51 is adequate based on the following conditions. HR 50 and HR 51 are located on different elevations of the turbine bll!lding which provides some means of separation and reduces the likelihood of both reels being used for the same fire. Another tire hose can be used for back up to reach any location that either HR 50 or HR 51 can reach. Common supply piping, with the exception of the above referenced standpipes, is sized adequately per PLC hydraulic calculations. Conclusion.* Based on the argument that only one of the two hose stations supplied by non-code sized standpipes would be needed in a given fire, the hydraulically designed piping is adequate. "Hose system: All Standpipe: All Hose Station(s): All -especially HCS 41 Code Section Deviated from: 5-3. 1 Status: Comply with Intent Subject Water Supply Davis-Besse Page 88 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.09: 3.6.2 -Water Flow and Nozzle Pressure Evaluation: The hydraulically most remote outlet is required to flow 500 gpm at 65 while the top most outlet on I FPE RAI 05 each additional required standpipe is flowing 250 gpm. The hydraulically most remote outlet, based on its distance from the water supply loop and its elevation, is HCS 41. HCS 41 is capable of flowing approximately 260 gpm at 69 psi. The code requires HCS 41 to be able to flow 500 gpm at 65 psi. HCS 41 provides an adequate supply of water to a hose system on which the nozzles can only flow 125 gpm. The other required hose stations are capable of flowing 250 gpm at 65 psi by deduction, since HCS 41 is hydraulically the worst case. Conclusion: Based on the hydraulic calculations which verify the demand of the nozzles relative to the available supply is adequate for the installed conditions, it can be concluded that the intent of the standard has been met. "Hose system: Vanous Standpipe: Various Hose Station(s): Various Code Section Deviated from: 4-4.2 Status: Comply with Intent Subject Pressure Reducing Devices Evaluation: The code requires an approved pressure reducing device at any standpipe outlet where the pressure exceeds 100 pounds per square inch. No such pressure reducing devices are installed at DB-1 despite the fact that pressures can exceed 100 psi at many of the outlets. Appropriate warning signs are posted at each outlet indicating that excessive pressure is available and that the hose stations are intended for nre brigade use only. The fire brigade is trained and drilled using the higher pressures available at DB-1 and thus the existing installation is considered adequate. In addition, all personnel within the protected area receive training to make them aware of their responsibil!ties-regarding manual fire fighting activib"es. Davis-Besse Page 89 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.09: 3.6.2 -Water Flow and Nozzle Pressure Conclusion: The existing arrangement is considered acceptable based on the fire bngade and general orientation training prowded Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991. * *Serial No. 1456, "Fire Protection -Request for Additional Information (TAC Nos. 60994, 60995, and 61745)," January 6, 1988.
* Serial No. 1685, "Fire Protection -National Fire Protection Association (NFPA) Code Review (TAC Numbers 60994, 60995 and 61745), July 31, 1989.
* Serial No. 1718, "Fire Protection; Additional Information on the NFPA Standard Compliance Review," October 11, 1989.
* Calculation C-FP-013.03-002 Rev 0.
* DB-FP-04014 Rev 9, Section 2.1.2. Evaluation: The NRC letter dated May 30, 1991, (Log No. 3480) stated: number of deviations were identified related to the size of piping and system pressure and flow characteristics which result in certain locations where standpipe outlets are not able to deliver the quantity of water at sufficient pressure as required by the applicable NFPA Standard As stated above in our evaluation of the plant water supply, the staff finds that the NFPA Code requirements for water for manual fire fighting are conservative in light of the fact that the smaller piping at the Davis-Besse plant can deliver at least 250 gpm per outlet. This is equivalent to flow from two 1 % inch hose lines or one 2% inch hose line. The staff concludes that this capability is sufficient to suppress potential fires in the subject areas based on the lirmted combustible loadings in these areas. Another deviation pertains to the lack of pressure reducing devices at standpipe outlets where the system pressure exceeds 100 psi. Because warning signs are posted at these locations and the fire bngade is trained to operate hoses at the higher pressure, the staff concludes that this condition is acceptable. " Davis-Besse Page90 I FPE RAI 05 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.09: 3.6.2 -Water Flow and Nozzle Pressure Validation/Conclusions: The following conditions were cited in the NRG SER as the bases for the deviation approval in water flow and nozzle pressure:
* Davis-Besse plant can deliver at least 250 gpm per outlet.
* Where the system pressure exceeds 100 psi, warning signs are posted at the standpipe.
* The fire brigade is trained to operate hoses at pressure higher than 100 psi. Conformance has been verified with the Appendix R deviation agreements reached with the NRG regarding water flow a11d nozzle pressure, as stated in NRG deviation dated May 30, 1991. The as-built plant configuration verification process consisted of review of.current plant procedures. Based on NRG deviation approval dated May 30, 1991 (Log No. 3480), the following criteria was selected for validation in order to transition this approval into the NFPA 805 licensing basis. Validation was performed by review of station records as identified below. 1. Calculation C-FP-013.03-002 Rev 0 provides an evaluation of the flowrates at hose stations HCS-32, HCS-41, and HCS-48 and hose reels HR-50 and HR-51. Per Table 6 on page 13 of Attachment 3, the maximum hose station flowrates range from 263 to 590 gpm. This confirms that the actual capability of the licensee's fire brigade to deliver water during a fire is at least 250 gpm. 2. Section 2.1.2 of Procedure DB-FP-04014 Rev 9 states that each fire hose station should have a warning sign stating, "System operates at pressure above 100 PSI. Equipment should be used by trained fire brigade personnel only. No other use of this equipment is authorized." Since this requirement is included in the Limits and Precaution section of the hose station periodic inspection procedure, the signs are being maintained in place. The validation findings support transition of the deviation approval. Associations: Fire Protection -Section 3.6 /Subsection: 3.6.2 Davis-Besse Page 91 IFPE RAI 05 FE NOC Attachment K -Existing Licensing Action Transition Licensing Action 16.10: 3.6.4 -Manual Fire Suppression NFPA 805 Section 3.6.4, requiring seismically-designed hose standpipes and hose stations for manual fire suppression, is I FPE RAI os excluded from applicability to Davis-Besse, based on the current licensing basis. The BTP 9.5-1 Appendix A Position, Section E.3 (d), requirement for seismically-designed hose standpipe system only applied to plants that did not have a construction permit as of 7/1/1976. Because Davis-Besse was under construction, they were approved without seismically-designed hose standpipes and hose stations. Basis Date: May 30, 1991 To Be Transitioned? Yes Basis: Appendix A to Branch Technical Position APGSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior To July 1, 1976," was provided in two-column format, with separate requirements for plants with "application docketed but construction permit not received as of 7/1/1976" compared to requirements for "plants under construction and operating plants." Because Davis-Besse was in the process of receiving their operating license at the time, the second column provided the applicable licensing basis. BTP 9.5-1 Appendix A Position, Section E.3 (d), requirement for seismically-designed hose standpipe system only applied to plants that did not have a construction permit as of 7 /1 /1976. The Davis-Besse standpipe and hose system was approved by NRG letter dated May 30, 1991 (Log No. 3480). Therefore at the time of original construction and commercial operation, Davis-Besse was not required to design the installation of its fire suppression and standpipe hose systems to be seismically qualified. Reference Document
* Log No. 3480, "Safety Evaluation of Fire Protection Measures at the Davis-Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 GFR Part 50 (TAC NOS. M60994, M60995, M61745 AND M61923)," May 30, 1991.
* RIN 3150-AG48, "Voluntary Fire Protection Requirements for Light Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative," Federal Register, Volume 69, No. 115, June 16, 2004.
* BTP 9.5-1, Appendix A.
* DB-FP-00009, Fire Protection Impairment and Fire Watch. Evaluation: The NRG letter dated May 30, 1991, (Log No. 3480) stated: Davis-Besse Page K-92 FENOC Attachment K -Existing Licensing Action Transition Licensing Action 16.1 O: 3.6.4 -Manual Fire Suppression ':As part of its comparison of the design of the standpipe and hose system to NRG fire protection guidelines and the I FPE RAI 05 criteria contained in NFPA Standard No. 14, the licensee identified several deviations in its letters dated January 6, 1988 and July 31, 1989. Several of these deviations pertain to the use of unlisted equipment, use of matenals which do not meet the construction specifications of this standard, and the nature of the acceptance testing. The staff reviewed these deviations, including the licensee's justification and concludes that these conditions will not adversely affect system performance and are, therefore, acceptable based on the continuing acceptable performance of these system." It further concludes: "Based on the above review and evaluation of the licensee's fire protection program, and subject to the approved deviations and exemptions and the licensee's commitments to implement vanous additional fire protection measures during the seventh and eighth refueling outages, the staff concludes that the fire protection program at Davis-Besse conforms with the guidelines in Appendix A to the B TP, the requirements of Appendix R to 10 GFR Part 50 and the supplemental staff guidance on fire protection, and is acceptable. " NRC issued notice of final rule (RIN 3150-AG48) in Federal Register, Volume 69, No. 115, dated June 16, 2004 regarding Voluntary Fire Protection Requirements for Light Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative: i4 commenter noted that Appendix A to B TP APGSB 9. 5-1 did not require seismically qualified standpipes and hose stations for operating plants and plants construction permits issued prior to July 1, 1976. NRG agrees that Appendix A to B TP APCSB 9. 5-1 made separate provisions for operating plants and plants w1lh construction permits issued prior to July 1, 19 76, and did not require seismically qualified standpipes and hose stations for those plants. Therefore, the reqwrement in Section 3. 6. 4 of NFPA 805 is not applicable to licensees with nonseismic standpipes and hose stations previously approved in accordance with Appendix A to B TP APGSB 9. 5-1. " Validation/Conclusions: Based on the previous approval of the standpipe system, the requirements of section 3.6.4 are not applicable to Besse. Based on NRC deviation approval dated May 30, 1991 (Log No. 3480), there is no applicable criteria for validation in order to carry this deviation forward. The validation findings support transition of the deviation approval. Davis-Besse Page K-93 FENOC Attachment K-Existing Licensing Action Transition Licensing Action 16.10: 3.6.4 -Manual Fire Suppression Associations: I FPE RAI 05 Fire Protection -Section 3.6 I Subsection: 3.6.4 Davis-Besse Page K-94 
 
==Enclosure==
B L-17-253 LAR Attachment L -NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii)) (61 pages follow)
FE NOC L. Davis-Besse Attachment L -NFPA 805 Chapter 3 Requirements for Approval NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii)) 60 Pages Attached Page L-1 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approval Request 1 NFPA 805 Section 3.3.5.1 states: Wiring above suspended ceiling shall be kept to a minimum. Where installed electrical wiring shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers. DBNPS is requesting approval for limited use of low power data and communication cables above suspended ceilings which are neither plenum-rated nor routed in armored cable, metal conduit, or trays with metal covers. The cable installation meets the intent of NFPA 805, Section 3.3.5.1. Basis for Approval Request 1: As part of the transition to risk-informed performance-based regulation, DBNPS examined NFPA 805, Chapter 3 requirements for installations above suspended ceiling. Suspended ceilings are used sparingly throughout the power block at DBNPS. LAR Attachment I, "Definition of Power Block," lists the areas included in the power block. Within the DBNPS power block, suspended ceilings are in the following fire areas:
* CC-01, Old RRA Access and Chemistry Lab Areas
* FF-01, Control Room Complex
* FF-02, Control Room Study Room
* FF-03, Control Room Kitchen With the exception of the Control Room Complex (FF-01) and Old RRA Access and Chemistry Lab Areas (CC-01 ), the other areas with suspended ceilings are not significant, nor do they contain systems and equipment essential to address nuclear safety performance criteria. Area walkdowns identified a number of cable types routed above ceilings in CC-01 only. Other areas (FF-01, FF-02, and FF-03) do not have rated, non-enclosed cables routed above suspended ceilings. The cables above the suspended ceilings in CC-01 are data and communication cables. Also included above the suspended ceilings are type CMP cable that is plenum-rated; therefore, it is not within the scope of this approval request. A condition exists in CC-01 where power supply wiring for Emergency Backup Lighting is non-enclosed and routed above the suspended ceiling. This single instance of non-enclosed 120V power wiring is being tracked for resolution in LAR Attachment S action item, DB-2020. The wiring in CC-01 located above suspended ceilings that is non-enclosed or non-plenum-rated does not pose a significant hazard due to the following:
* The cables routed above suspended ceilings include data and communication cable. These are low power cables; therefore, unlikely to carry sufficient electrical energy for self-ignition.
* It is common practice to consider only self-ignited cable fires to occur in medium to high voltage cables since they carry electrical energy sufficient for self-ignition Davis-Besse Page L-2 J FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Control and instrumentation cables do not carry enough electrical energy for ignition.
* In the absence of an ignition source, it is unlikely for a significant fire event to originate in the space above the suspended ceilings that would be capable of* challenging nuclear safety performance criteria. Fixed ignition sources located in the space above suspended ceilings are limited to small hazards such as low voltage lighting.
* Cables in CC-01 used for safe shutdown are routed in metallic conduit; therefore, they are protected from the low power data and communication and other cables.
* Cables at DBNPS are classified according to level of service. Medium power cables capable of self-ignition are grouped separately from low power, control and instrument cables which lack sufficient energy to self-ignite.
* Low power cables located above ceilings, serving data or communication systems, are not required to achieve nuclear safety performance criteria.
* Process documents are being revised to ensure future cable installations at DBNPS will meet NFPA 805-2001, Section 3.3.5.1. This is being tracked in LAR Attachment S action item, DB-1964. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The location of non-enclosed or non-plenum rated low power data and communication cable above the suspended ceiling of CC-01 does not pose a significant fire hazard. The low power cable is not susceptible to shorts that would result in a fire and does not constitute an ignition source capable of challenging nuclear safety. Cables performing a nuclear safety function are routed and protected in metallic conduit in this space. Therefore, the presence of non-plenum-rated cables located above suspended ceilings does not affect nuclear safety performance criteria. The presence of non-plenum-rated cables located above the suspended ceiling of fire compartment CC-01 has no impact on fire suppression activities, nor impact on radiological release performance criteria. The radiological review was performed based upon the potential location of radiological concerns and is not depen.dent on the type of wiring or location of suspended ceilings. The cables do not change the results of the radiological release evaluation that concluded potentially contaminated water is contained and smoke is monitored. The cables do not add additional radiological materials to the fire compartment. The existing use of non-enclosed or rated low voltage wiring above suspended ceilings at DBNPS has no impact on nuclear safety and radiological release performance criteria. Safety Margin and Defense-in-Depth: The non-enclosed or non-plenum rated low power data and communication cable above suspended ceilings carry insufficient energy to self-ignite. Such cables do not compromise automatic or manual fire suppression functions nor adversely impact safety margin given the absence of a credible ignition source and the low likelihood of occurrence of fire. The cables have been analyzed in their current configuration. The Davis-Besse Page L-3 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval amount of non-rated and non-enclosed cable above the ceiling in CC-01 is minor and does not present a significant fire hazard. In addition, the cable used for nuclear safety are routed and protected in. metallic conduit. Therefore, the safety margin inherent in the analysis for the fire event has been preserved. Defense-in-depth (DID) protects public health and safety from radioactive or hazardous material releases resulting from a fire event. Multiple independent and redundant echelons of DID offset potential human errors and mechanical failures so that no single echelon, no matter how robust, is exclusively relied upon. The three echelons of fire protection DID include the following: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, and pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, and recovery actions). I Per NFPA 805, Section 1.2, DID is achieved when an adequate balance of each of these elements is provided. At DBNPS, the subject low power data and communication cable does not carry sufficient energy to self-ignite, which prevents potential fires from starting and preserves DID echelon 1. Procedure changes ensure future cable installations above suspended ceilings will be listed for plenum use or enclosed per NFPA 805, Section 3.3.5.1, to support DID echelon 1. In the low likelihood event of a fire, pre-fire plans provide guidance for a well-trained and regularly-drilled Fire Brigade to promptly respond to the emergency. Fire extinguishers and hose stations are located within or readily accessible from nearby fire areas, preserving DID echelon 2. Finally, the DB-NPS fire program provides robust fire barriers and circuit separation of redundant trains of essential safety related equipment that preserve one train free of fire damage to enable safe shutdown of the plant and preserve DID echelon 3. Limited fixed ignition sources and the low potential energy in the exposed non-shutdown data and communication cables located above the suspended ceiling make it unlikely for a significant fire event to originate in the space above the suspended ceilings. In the unlikely event of a fire, it would not be capable of challenging the cable contained in the metallic conduits that support the nuclear safety performance criteria, which further supports echelon 3. The low power data and communication cable routed above suspended ceilings does not directly result in compromising automatic fire suppression systems, manual fire suppression functions, or post-fire safe shutdown capability. Each of these elements in balance achieves DID and supports a margin of safety at DBNPS. Conclusion: NRC approval is requested for the use of low power data and communication cable that is non-enclosed or non-plenum-rated above the suspended ceilings in CC-01. Cables Davis-Besse Page L-4 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval used to meet the nuclear safety performance criteria of NFPA 805 located above the CC-01 suspended ceiling are few in number and enclosed in metallic conduit. This conduit effectively separates the safety-related cable from the negligible hazard posed by the low voltage, non-enclosed cable. Non-enclosed or non-plenum-rated low power data and communication cable above suspended ceilings at DBNPS is acceptable. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release,
* Maintains safety margins, and
* Maintains fire protection DID (fire prevention fire detection, fire suppression, mitigation, and post-fire safe and stable capability). Davis-Besse Page L-5 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approva1Request2 NFPA 805 Section 3.3.5.3 states: Electrical cable construction shall comply with a flame propagation test as acceptable to the AHJ. Exception: Existing cable in place prior to the adoption of this standard shall be permitted to remain as is. NFPA 805, Section A.3.3.5.3 states: Electric cable insulation should be of a type that has been tested using a recognized flame spread test. An example of such a test is IEEE 817, "Standard Test Procedure for Flame-Retardant Coatings Applied to Insulated Cables in Cable Trays," and IEEE 1202, "Standard for Flame Testing of Cables for Use in Cable Tray and Industrial and Commercial Occupancies." DBNPS is requesting approval for recognition that the type of cable insulation used throughout the plant meets the intent of NFPA 805, Section 3.3.5.3. Basis for Approval Request 2: NFPA 805, Section 3.3.5.3 requires electric cables to comply with flame propagation tests as found acceptable by the AHJ. NFPA 805, Appendix A explains acceptable test types as IEEE 817 and IEEE 1202. FAQ 06-0022, "Acceptable Electrical Cable Construction Tests," clarifies Section 3.3.5.3 of NFPA 805 to refer generally to IEEE 383-1974 or IEEE 1202-1991 as the NRG accepted test standards for flame propagation. Cables installed as part of the original construction of DBNPS predate the issuance of IEEE 383. NRG review in "Safety Evaluation of Fire Protection Measures at the Besse Nuclear Power Station, Unit No. 1, Per Appendix R to 10 CFR Part 50 (TAC Nos. M60994, M60995, M61745 and M61923)" (Log No. 3480. ML033490026) states that u_c(i_i alternative testing measures were used to qualify cables, and further states: ... based on the levels offire protection (e.g., (ire detection, fire suppression and fire barriers) provided for safe shutdown systems and hazardous areas as described in the FAOR, Revision 1 and subsequently in Revision 12 of the FHAR, the staff concludes that this deviation is acceptable. Cable insulation material can be classified into two main types: thermoset and thermoplastic. Thermoset materials char and their shape when heated, limiting fire growth along the material extruded as cable insulation. Thermoplastic materials melt and burn when heated, and have lower failure temperatures than thermoset materials per NUREG-6850, "EPRl/NRC RES Fire PRA Methodology for Nl:lclear Po*Ner I FPERAr04.01 Facilities.". Typically, the IEEE 383 qualified cables have thermoset insulation material, while the unqualified cables are constructed of thermoplastic insulation material (NUREG-1805, Ch. 7). The majority of the cables in trays at DBNPS are equivalent to qualified cables because they have thermoset insulation that limits fire propagation along the cable. Davis-Besse Page L-6 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval +Re As determined in DBNPS Condition Report 10-74188. the thermoset insulated j FPERA104.01 cables in cable trays at DBNPS account for over 90% of the cables. be&s In actuality less than e i% of the cables in trays at DBNPS were sategorized identified as thermoplastic (PVC or Teflon) insulated. Approximately The actual cable insulation type could not be determined for approximately an additional 4% of the cables were and they are conservatively assumed to atsa be thermoplastic insulated besause the astual insulation type sould not be determined. DBNPS atsa has cables manufactured by Kerite, which do not perform as well under fire conditions as other thermoset insulated cables. These; therefore. the Kerite cables are conservatively included into the fire I FPERAia4.01 models as thermoset thermoplastic insulated cables aR9 based on FAQ 08-0053. The cables categorized as thermoplastic are included as input to fire modeling as part of the NFPA 805 projest into the fire models. The known thermoplastic (PVC) insulated cables identified by the DBNPS Condition Report 10-7 4188 are used in low voltage applications for process and area radiation monitors, the GAl-Tronics system, and in the original construction for the television I FPERA104.01 circuits. These low power instrumentation cables do not carry enough electrical energy for self-ignition {based on NUREG-1805, Ch. 7*. These cables were found only in non-I FPERA104.01 essential trays and are routed separately from safety-related cables. Cables in conduit are not a concern and not considered as an ignition source, as cables I FPERAI04.oi in conduit do not significantly contribute to fire growth and spread because they are enclosed, have limited oxygen, and less surface area for fire spread. Cables in sonduit are not sonsidered as ignition sourses and typisally do not sontribute to fire growth and (NUREG-6850, Appendix H). Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: Thermoplastic insulated cables are used primarily in non-safety and low voltage applications; therefore, they are not considered an ignition source. The thermoplastic (PVC) insulated cables identified by the DBNPS Condition Report 10-74188 were found I FPrnA104.01 j ' only in non-essential cable trays. These cables are routed separately from safety-related cables. In the event of an externally initiated fire that may ignite these cables, the separation will minimize the potential of flame spread to safety-related cables. Therefore there is no impact on the nuclear safety performance criteria. The radiological review was performed based on the potential location of radiological concerns and is not dependent on the type or location of thermoplastic cables. The results of the radiological release evaluation concluded that potentially contaminated water is contained and smoke is monitored. The thermoplastic cables do not add additional radiological materials to the areas or challenge systems boundaries. ) Therefore, non-qualified thermoplastic (this includes cables of unknown construction) I FPERA104.01 cable currently in use at DBNPS has no impact on radiological release performance criteria. Safety Margin and Defense-in-Depth: Thermoset insulation is used in the majority of cables in the plant. This type of insulation will char and retain its shape when heated, limiting flame propagation. The Davis-Besse Page L-7 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval thermoplastic insulated cables not confirmed to be of thermoset insulation account for I FPE RA104.01 less than 10% of all cables within the plant, with the majority of these thermoplastic cables being low-voltage and non-safety related. The non-thermoset cables are all treated as if they are of thermoplastic construction. Damage to these thermoplastic cables is not expected to impact safety-related cables due to cable separation. Flame spread to adjacent cable trays in high density safety-related areas is reduced by the use of solid-bottom trays. Some cable trays enclose the cable with a layer of ceramic fiber I FPERA104.01 on top ... ; thereby further reducing the likelihood of fire spread to additional cable trays. The detailed fire models as well as the probabilistic risk assessment incorporated the information from DBNPS Condition Report 10-74188 to identify and account f.or I FPERA104.01 thermoplastic cable impacts. conservatively account for thermoplastic cable impacts. The electrical cable material properties were included in the fire modeling evaluations. in the PRA models. and in the fire risk evaluations to determine the locations where additional fire protection features (such as fire suppression and/or detection) are required for risk reduction or defense-in-depth. Therefore, the safety margin inherent in the analysis for the fire event has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls) (2) Rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans) (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions) Per NFPA 805, Section 1.2, DID is achieved when an adequate balance of each of these elements is provided. Thermoplastic insulated cables are used primarily in non-safety and low voltage applications and are not considered an ignition source. Therefore, echelon 1 is met through plant fire prevention procedures and is not affected by use of non-qualified thermoplastic cable. These cables do not affect echelons 2 or 3 because they are found only in non-essential trays and are routed separately from safety-related cables. The use of tRese thermoplastic insulated cables do not directly result in compromising automatic fire suppression systems, manual fire suppression functions, or post-fire safe shutdown capability. Since a balance of the elements is provided, DID is achieved. Conclusion: NRG approval is requested for the use of the existing non-IEEE 383/1202 (or equivalent) thermoplastic cables. The majority of cables used throughout DBNPS are insulated with thermoset material, which chars and retains its shape when heated, limiting flame spread; therefore, the cables meet the intent of IEEE 383-1974 qualification. The thermoplastic cables including the cables of unknown type account for less than 10% of the total cables in trays, are used primarily for low-voltage, safety related instrumentation, and are routed separately from cables for safety-related systems. Evaluations demonstrate that this small population of thermoplastic electrical Davis-Besse Page L-8 I FPE RAJ 04.01 I FPE RAI 04.01 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval insulated cable meets the performance criteria for nuclear safety and radioactive release, safety margin, and DID as stated above. Future Gable electrical installations at I FPERA104.01 DBNPS will meet the established acceptance criteria of NFPA 805-2001, Section 3.3.5.3 for cable construction. I FPERA104.01 DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release,
* Maintains safety margins, and
* Maintains fire protection DID (fire prevention fire detection, fire suppression, mitigation, and post-fire safe and stable capability). Davis-Besse Page L-9 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approva1Request3 NFPA 805 Section 3.3.12(1) states: The oil collection system for each reactor coolant pump shall be capable of collecting lubricating oil from all potential pressurized and non-pressurized leakage sites in each reactor coolant pump oil system. NFPA 805 Section 3.3.12(4) states: Leakage points on a reactor coolant pump motor to be protected shall include but not be limited to the lift pump and piping, overflow lines, oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and the oil reservoirs, where such features exists on the reactor coolant pumps. Approval is requested for DBNPS reactor coolant pumps (RCP) oil collection systems (OCS) from the requirements of NFPA 805, Section 3.3.12(1) and 3.3.12(4) to the extent that RCP oil misting is not captured within the originally approved OCS 10 CFR 50, Appendix R review. Basis for Approval Request 3: The DBNPS reactor coolant system (RCS) is configured with two reactor coolant loops. The RCPs are not safety related. There are a total of four RCPs; thus redundancy is provided. Each reactor coolant loop is partitioned at various levels by reinforced concrete walls. A single reactor coolant loop contains two RCPs, a steam generator, and associated piping. An OCS is constructed of oil drip pans with spray shields and enclosures surrounding the RCP lubricating oil system. This design is intended to prevent the RCP lubricating oil system from becoming a potential ignition source by collecting oil leakage. Appendix R, Item 111.0of10 CFR Part 50 requires that the RCPs be equipped with an *OCS to mitigate the fire hazard associated with the RCP lubricating system. DBNPS installed an enclosure surrounding the oil cooler, fill pipe, and bearing lift pump. Each of the reactor coolant loops has a single oil collection tank located and sized to handle the total lube oil inventory from only one of the two RCP motors in that loop. The enclosures are segmented and gasketed to facilitate disassembly and motor maintenance. The enclosures are designed to contain oil from leak or a pipe failure and drains to a vented collection tank. During normal operation, small quantities of viscous oil collect on the enclosure gaskets. Vibration and thermal movement allows nominal weeping of the gaskets producing periodic oil drips. The quantity of oil is not sufficient to be considered significant leakage. In the event of significant leakage or pipe failure, the force of gravity readily exceeds the viscosity of the oil to ensure the captured lubricant is directed to the collection tank. Insignificant quantities of residual oil are expected to cling to the enclosures, gaskets and drain piping. The OCS collection tank is periodically emptied to assure e;idequate capacity for the oil contained in one RCP motor. The exposed piping which is not encapsulated by the OCS enclosure is either not pressurized (e.g., it is a drain pipe) nor sleeved. Any lube oil overflow in excess of a single RCP lube oil inventory, will drain to the monitored Davis-Besse Page L-10 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval containment sump and be detected by a change in sump level. The RCP OCS is seismically supported and has been designed to accommodate the differential movement of the reactor coolant loops. DBNPS Serial No. 991 documents the previously accepted exemption request for the OCS design. Log Number 1586 documents the NRC's acceptance of the exemption request as follows: c) Exemption from Section Ill. 0 Section Ill. 0 of Appendix R to 10 CFR 50 requires, in part, that the reactor coolant pump lube oil collection system be designed to collect lube oil leakage in a closed, vented container that can hold the entire lube oil system inventory. The licensees have requested exemption from this requirement. The Davis-Besse Nuclear Power Station is designed with two reactor coolant loops. Each loop has two reactor coolant pumps (RCP). A high pressure and low pressure lube oil system is provided for each RCP motor. The high pressure system is used only during startup and shutdown. The low pressure system is used during normal operation. Each RCP motor contains 225 gallons of lube oil. The licensees have provided one 250 gallon oil collection tank for each loop. This provides sufficient capacity to hold the total lube oil inventory of only one RCP motor in each loop with some margin. Any lube oil overflow will drain to the containment sump. The RCP motor lube oil system does not comply with Section Ill. 0 because the oil collection tank is not sized to contain the entire lube oil system inventory. Since any lube oil overflow will drain to the containment building sump where there is no other flammable material or hot surfaces which may ignite the oil, the overflow oil will not present an exposure fire hazard to or otherwise endanger safety-related equipment, and since the RCP motor lube oil collection system is capable of withstanding the safe shutdown earthquake, we find the oil collection system acceptable. Based on our evaluation as discussed above, we conclude the existing RCP motor lube oil collection system provides a level of safety equivalent to the technical requirements of Section Ill. 0 and, therefore, the exemption requested is granted. The RCP OCS was designed and was reviewed in accordance with 10 CFR Part 50, Appendix R, Section 111.0 and Section C.7.a(1)(e) of BTP CMEB 9.5-1 to collect leakage from pressurized and non-pressurized leakage sites in the RCP oil system. The DBNPS RCP OCS's design and installation was approved for DBNPS in the NRG exemption approval request identified as Log 1586, dated August 20, 1984. The license approval did not discuss the collection of oil mist as 'a result of pump/motor operation. Remote oil fill lines were added in 1990 to facilitate the addition of oil at power from a low-dose location to the lower oil reservoir of each RCP. The fill lines terminate within the approved OCS enclosure for the lower reservoir, above the normal oil level, to eliminate the potential for oil leakage during normal operation. The fill lines are devoid of oil except when the fill operation is conducted; therefore, the single wall tubing is not sleeved. Centerior Energy letter of November 18, 1997 (Serial No. 2493) includes Davis-Besse Page L-11 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval compensatory measures to be implemented each time oil is added via remote oil fill lines including the following: * "Oil may be added only when a low oil level computer alarm is received on an RCP motor.
* Only a predetermined amount of oil necessary to clear the alarm (approximately three pints based on prior experience) will be initially added to the reservoir via the remote oil fill line. A maximum total volume of four pints of oil may be added in an attempt to clear the alarm.
* The oil fill pot will be verified empty prior to exiting the immediate area. Any spillage resulting from adding oil to the remote oil fill pot will be cleaned up.
* Personnel responsible for the oil addition evolution will be instructed to report to the control room any evidence of smoke during the oil addition process. If smoke is visually detected, the fire brigade will be immediately dispatched to the area.
* A visual inspection will be conducted following refueling outages to confirm the integrity of the remote oil fill line system." The exemption request letter concludes: "The remote oil fill lines are of a leak-tight design, and are only used infrequently. A hypothetical worst case oil spill and ignition will not impact post-fire safe shutdown capability. Administrative controls will be established to minimize the potential for an oil fire due to a leak from the portions of the remote oil fill line that are not enclosed by an oil collection system. Based on the above, the underlying purpose of Appendix R, Section Ill. 0, which is to ensure that leaking oil will not lead to a fire which could damage safe shutdown systems during normal or design basis conditions, is accomplished without the installation of an oil collection enclosure around the remote oil fill lines." NRC letter of January 30, 1998 (Log No. 5205) approved the exemption stating: "Accordingly, the commission hereby grants an exemption from the requirements of 10 CFR Part 50, Appendix R, Section Ill. 0, to the extent that the RCP lube oil fill lines are required to be protected with a collection system. The granting of this exemption is conditioned upon the licensees' use of the compensatory measures set forth in the licensees' November 18, 1997 exemption request." The RCP OCSs are designed and sized to collect and contain oil from pressurized and non-pressurized potential leakage areas in a seismic event resulting in failure of the lubrication system and have been previously approved in NRC letter of January 30, 1998 (Log No. 5205): Davis-Besse Page L-12 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval "Accordingly, the commission hereby grants an exemption from the requirements of 10 CFR Part 50, Appendix R, Section Ill. 0, to the extent that the RCP lube oil fill lines are required to be protected with a collection system. The granting of this exemption is conditioned upon the licensees' use of the compensatory measures set forth in the licensees' November 18, 1997 exemption request." RCP motors are large and will consume oil during the course of normal operation. During normal operation, some of the lost oil will vaporize due to heat and is pushed out of motor seals. As the warm air from the motor combines with oil that has vaporized, it becomes oil mist. Therefore, the phenomena of oil misting is not leakage due to equipment maloperation, but a condition inherent in the design and proper operation of large rotating equipment. It is normal for large motors to lose some oil through seals and for the oil to potentially become "atomized" into the air circulating the motor for cooling. This atomized oil mist is then transported and can collect on surfaces in the vicinity of the RCP/motor as its design does not provide complete sealing in order to allow airflow for cooling. This oil mist then travels into the Reactor Containment (RC) atmosphere until it subcools into small drops or comes into contact with cooler surfaces. The quantity of oil lost through misting resulting from normal operation will not adversely impact the ability of a plant to achieve and maintain safe shutdown (SSD) even if ignition occurs. The previously approved OCS design cannot contain this mist because the system is not designed to completely enclose the motor since adequate air circulation for safe motor cooling is required. The quantity of oil that may be found in areas of the containment due to the RCP oil vapor mist is very small and does not contribute to any significant fire loading nor create potential fire propagation potential between fire compartments. SD-039A, "System Description for Reactor Coolant System for First Energy Nuclear Operating Company Davis-Besse Nuclear Power Station Unit 1," states that, "the Reactor Coolant Pump Motor is a totally enclosed squirrel cage induction motor with thermalastic [sic] epoxy VPI (vacuum pregnated insulation) and an water heat exchanger to cool the ventilating air." Despite this, the release of oil vapor (oil misting) cannot be prevented unless the RCP motor bearing seals design is changed. A design change of this nature for motors of this size would be a significant modification and would result in little, if any, change in fire risk in the RC fire compartment. The RCP, including the oil system, is seismically designed and the nearby hot surfaces of the RCS piping are protected by seismically designed mirror insulation such that any spilled lube oil would contact only outer surfaces of the insulation, which have temperatures below the lube oil flash point. It is demonstrated by engineering design that sump and splash shields would be capable of preventing a fire during normal and design basis accident conditions. Therefore, the safety objective of 10 CFR 50, Appendix R, Section 111.0 would be achieved. In addition, Generic Letter 86-10, "Implementation of Fire Protection Requirements," dated April 24, 1986, Question 6.2 (presented below) discussed oil dripping. The response concluded that there was no concern with oil consumption (which is an oil misting Davis-Besse Page L-13 L_ FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval phenomena) but the primary concern was with an oil fire started from a pressurized leakage point and/or spilled leakage. Question 6.2 states: It would appear that a literal reading of Section Ill. 0 regarding the oil collection system for the reactor coolant pump could be met by a combination of seismically designed splash shields and a sump with sufficient capacity to contain the entire lube oil system inventory. If the reactor coolant pump is seismically designed and the nearby piping hot surfaces are protected by seismically designed splash shields such that any spilled lube oil would contact only cold surfaces, does this design concept conform to the requirements of the rule? The response states: If the reactor coolant pump, including the oil system, is seismically designed and the nearby hot surfaces of piping are protected by seismically designed splash shields such that any spilled lube oil would contact only cold surfaces, and it could be demonstrated by engineering analysis that sump and splash shields would be capable of preventing a fire during normal and design basis accident conditions, the safety objective of Section Ill. 0 would be achieved. Such a design concept would have to be evaluated under the exemption process. The justification for the exemption should provide reasonable assurance that oil from all potential pressurized and unpressurized leakage points would be safely collected and drained to the sump. The sump should be shown capable of safely containing all of the anticipated oil leakage. The analysis shol)ld verify that there are no electric sources of ignition. Historically, there have been no fires attributed to oil misting based on normal operation in the industry. Fires have occurred due to oil leakage from equipment failure such as cracked welds on piping or inadequate collection pan design. DBNPS does not have a history, since its licensing for commercial operation was issued on April 22, 1977, of significant oil loss from the RCPs as a result of oil misting or oil leakage that is not contained by the properly designed and installed oil leakage collection system. Additional crediting factors include:
* The OCS as designed com.plies with 10 CFR 50, Appendix R Section 111.0 and was approved to collect leakage from pressurized and non-pressurized leakage sites in the RCP oil system.
* Oil misted from normal operation is not leakage; it is normal motor oil consumption. *
* Oil drips and nominal oil weeping from gasketed connections and access covers of the OCS during normal operation does not constitute significant leakage.
* Oil misting and gasket weeping during normal operation does not significantly reduce the oil inventory. Davis-Besse Page L-14 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval
* The oil released as misting does not account for an appreciable heat release rate or accumulation near potential ignition sources or non-insulated reactor coolant piping.
* The RCPs use synthetic oil having a high flash point in excess of 392°F per the manufacturer's specifications for the oil defined in Lubrication Data Package for these RCPs. The flash point temperature is well above the maximum expected surface temperature [less than 200°F] of any of the mirror insulation and other small components with which the oil will come in contact. o Specification No. M-197N, Section 5.1 defines the RCS cold leg coolant to have a design temperature of approximately 550°F at full power. o The Detailed Heat Loss Calculation on the Metal Reflective Insulation System for the Steam Generator Replacement Project identifies that the bounding primary side design temperature of 600 °F yields an outer insulating surface temperature of less than 200 °F with no air flow. The predicted surface temperature is further reduced when air flow is accounted.
* Although there are redundant RCPs and they are not required to achieve or maintain fire SSD, they are available during fire scenarios.
* RCPs for each loop are located in separate spaces (rooms) within reactor containment and are separated from adjacent compartments by rated fire barriers.
* RCPs are protected by early warning smoke detection. The fire detection alarms are received in the Control Room which is constantly attended. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The nuclear safety performance criteria are met because RCPs are available as necessary, and the RCPs are not required to achieve or maintain post-fire SSD. The radiological release performance criteria are met because (1) the containment vessel during power operations is an environmentally sealed radiological area, (2) the potential for oil mist from the RCPs does not change the radiological release evaluation performed for each fire zone where potentially contaminated water and smoke is contained and monitored, (3) the oil mist does not add additional radiological materials to the area or challenge systems boundaries that contain such materials, and (4) the fire brigade control of water runoff and smoke' is not hindered because of the existence of the misting. Safety Margin and Defense-in-Depth: RCP oil mist resulting from normal operation will not adversely impact the ability of the plant to achieve and maintain fire safe shutdown, even if ignition occurs. There are redundant RCPs available as necessary, and RCPs are not required to achieve and maintain safe and stable conditions. Therefore, the safety margin inherent in the analysis for the fire event has been preserved. Davis-Besse Page L-15 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls) (2) Rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, and pre-fire plans) (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, suc"cess path remains free of fire damage, and recovery actions) Per NFPA 805 Section 1.2, DID is achieved when an adequate balance of each of these elements is provided. Echelon 1 is maintained by the OCS and by the RCP motor design, and is not affected by this configuration. The introduction of small amounts of oil misting does not affect Echelons 2 and 3 as oil misting will not serve as either an ignition source or a secondary combustible. Furthermore, Echelon 3 is preserved by the redundant reactor coolant loop. The oil misting does not result in compromising fire detection, manual fire suppression functions, or post-fire safe shutdown capability. Since a balance of the elements is provided, DID is achieved. Conclusion: NRC approval is requested for the potential of oil misting from the DBNPS RCPs/motors since the normal consumption of oil is not captured by the RCP OCS, which is designed for pressurized and non-pressurized leakages and spillage. As discussed above, oil misting does not create an ignition source within the reactor containment building or require a modification to the previously approved 10 CFR 50, Appendix R, Section 111.0 RCPs. No fires have occurred in the DBNPS RC as a result of RCP oil misting since it was licensed for commercial operation on April 22, 1977. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release,
* Maintains safety margins, and
* Maintains fire protection DID (fire prevention fire detection, fire suppression, mitigation, and post-fire safe and stable capability). Davis-Besse Page L-16 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approva1Request4 NFPA 805 Section 3.5.5 states: Each pump and its driver and controls shall be separated from the remaining fire pumps and from the rest of the plant by rated fire barriers. DBNPS is requesting approval for the remote start circuit separation configuration of the remote control circuits to each fire pump. Basis for Approval Request 4: The fire pump remote start circuit cables deviate cable routing deviates from NFPA 805, I FPERA1os Section 3.5.5 because circuits for the electric fire pump and the diesel fire pump are not separated from each other by rated fire barriers throughout their routing. The design is in conformance with the NFPA code of record, NFPA 20-1974, "Standard for the Installation of Centrifugal Fire Pumps," and the previous BTP 9.5-1 licensing commitments for the pump circuits having electrical separation. The configuration is I FPERA1os considered to meet the intent of NFPA 805, Section 3.5.5, based on the following:
* The only fire compartments containing remote start circuit cables for both the I FPE RA1 as electric and diesel fire pumps are BG-01. DD-01. and FF-01. In the unlikely event that both sets of remote start cables are damaged and impair a NFPA 805 fire in these compartments damages both fire pumps' remote starting circuits, ff. the plant can be safely shut down without any water-based fire suppression.
* It is unlikely that a fire in compartments BG-01. DD-01. or FF-01 could prevent start of both fire pumps since: a) the remote start circuits are routed in separate raceways (for opposite channels) that are configured with solid metal bottoms and ceramic fiber blankets on top. and b) damage to the remote start circuit would only be a concern if one of the fire pumps has not affect the ability to perform an emergency start of the pump already started automatically upon a drop of pressure in the fire main. The fire pump(s)' run circuitry is configured by NFPA code such that once started. the fire pump(s) can only be shutdown manually.
* In the event of a fire, Procedure DB OP 02529, "Fire Procedure," requires communication between the Control Room and Fire Brigade. This communication would expedite manual starting of the electric fire pump in the event that both fire pump automatic starting circuits were inoperable. The plant is also provided 'Nith alternate means of manual suppression via fire extinguishers to contain the fire 'Nhile the electric fire pump is being manually locally started. An offsite fire department pumper may also be used to supply fire water when needed and is detailed within procedure DB OP 06610, "Station Fire Suppression V\later System."
* Water-based suppression in the event of a fire in BG-01. DD-01 and FF-01 is available by proceduralized options for emergency fire water supply. such as the following: a) locally. within the Intake Structure. starting the electric fire pump or b) utilizing an onsite or municipal portable fire water pumper to supply water. Davis-Besse Page L-17 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval
* Capability for fire suppression also exists using available portable fire extinguishers. DBNPS has an electric fire pump, P5-1, and a diesel-driven fire pump, P5-2, which supply the yard loop that serves fire protection water supply system in the structures included within the Power Block and outlying buildings. Each of these pumps is a 100% capacity pump capable of supplying the largest sprinkler system plus a hose stream allowance. Additional 'Nater supplies capable of supplying the fire suppression system are the portable diesel dri,1en fire pump and the cross tie 'Nith the Carol To*Nnship municipal supply capability to supply the fire water system is available utilizing an onsite or municipal portable fire water pumper to supply water through a Fire Department Pumper Connection. or through reverse flow into a fire hydrant. I The twG station fire pumps are located in separate fire rated compartments, and each pump has its own independent water supply. The electric fire pump is located in Fire Compartment BH-01, and the diesel engine-driven pump is located in Fire Compartment BE-01. The fire pumps are designed to start automatically witll upon a drop in fire main I water pressure, in the event of a suppression system actuation or from the use of a fire hose in manual firefighting. Remote control switches for starting the electric and diesel fire pumps are provided in the Main Control Room (MCR and in; Fire Compartment FF-01) on panel C5720. All other fire pump control circuits are contained within the fire pump compartments. Fire damage to the remote start circuits only affects the starting function of the fire pumps. If a fire pump starts upon a drop in water pressure. and then the remote start circuit is subsequently damaged. the fire pump will continue to run. The cables associated with the remote start switches leave the MCR and enter the Cable Spreading Room (CSR-,; Fire Compartment DD-01) through penetrations in the floor of the MCR before going. From DD-01 the subject cables are then embedded in concrete through separate conduits to BG-01. From BG-01 the cables go to their respective pump in Fire Compartments BE-01 and BH-01. The circuits are routed through the same rooms for the majority of the routing. They v.'ere installed as separate channels and are not routed through the same raceways. The circuits are routed through cable trays, except in two instances where each of the fMm cable paths are not in cable trays and short sections which are routed in conduits (the longest conduit run being 55' and for a total of 90' of conduit in the greater than 600' of total cable length). \l\Jhere the trays are in the same. Within these rooms, the electrical cable trays are configured with solid bottoms with a layer of ceramic fiber blanket on the top. For the electric fire pump circuit, the remote start cable is routed from the remote start pushbutton on the MCR panel to the pump's control panel via cable CCBEF41G, which is routed through Fire Compartments FF-01, DD-01, BG-01, and BH-01. A fire that causes an open circuit on this cable would have no effect on the automatic operation of the pump. /\ fire that causes an open or short in the or short on this cable would either start the pump or have no effect on the automatic operation of the pump. A fire that causes a short-to-ground on the cable could result in the loss of the pump's starting circuits. However, it would not affect the ability to perform an emergency start of the pump (DB OP 06610, Section 5.1) locally. Davis-Besse Page L-18 I FPE RAI 06 I FPE RAI 06 I FPE RAI 06 I FPE RAI 06 I FPE RAI 06 I FPE RAI 06 I FPE RAI 06 I FPE RAI 06 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval The pump is powered from the non essential 480VAC switshgear. The offsite po*Ner I FPERAio6 supply could be lost due to a fire in various sompartments. Except for a fire in Fire Compartments FF 01 and DD 01, the other oompartments 'Nhere the eleotrio fire pump_ circuits are routed, a loss of offsite power is not expected. Therefore, it is assumed that po1Ner to the eleotrio fire pump will not be lost in these oompartments. For the diesel fire pump start circuit, the fire pump remote start cable is routed from the MCR via sable ACFD02A per E 49B, Sheet 43, "Elementary 'AGring Diagrams, Treated I FPERA106 '/\later Systems, Fire '/\.later Diesel Pump Auxiliary," 'Nhich is routed through Fire Compartments FF-01, DD-01, BG-01, BF-01, and BE-01. This sontrol oirouit sable is the only external field sable for the engine driven pump, other than a battery sharger cable and an annunoiator sable, whioh are not required for engine operation. The starting batteries are assumed to be initially charged. 'Nith the start switsh in its normal (auto) position, the starting sirouit is energized through 24 volt Battery 2 and sirsuit breaker CB2 and auto sontact of the control S'Nitsh. In event of a ground fault on the start pushbutton circuit of suffisient surrent, CB2 would trip, and relays 1Nould pisk up and energize the start oirsuit through Battery 1 and CB1. If the fault were still present, this would trip sirsuit breaker CB1 and, in certain conditions the start circuit would be disabled. If this oondition ocsurred, preventing local starting of the pump would not be effestive besause the fuel solenoid fails shut on loss of sontrol voltage. The fire compartments in which a fire may cause a loss of both fire pumps inslude are:
* Fire Compartment BG-01 -This compartment is comprised of the Intake Valve Room and Tunnel. The Intake Valve Room contains safety-related cables. The fire pump remote start cables are routed independently in solid bottom trays with I FPE RA1 06 a layer of ceramic fiber on the top. This compartment has a low combustible loading and the sredited means of suppression is by use of portable I FPERA106 extinguishers and fire hose stations and/or a yard hydrant (less than 0.5 hour fire severity). The detailed fire model only credits manual fire suppression in one fire scenario. and that scenario does not damage raceways containing the fire pump remote start circuits. Fire extinguishers are available for manual suppression.
* Fire Compartment DD-01 -This compartment consists of the CSR, which has automatic suppression. Small fires would be extinguished with portable I FPERA106 extinguishers and The detailed fire hoses model does not credit manual or automatic fire suppression. As discussed above, the fire pump remote start cables are routed independently in solid bottom trays with a layer of ceramic fiber on the top. Any fire large enough to damage potentially both sets of sables I FPERAio6 would quiskly result in The automatic sprinkler astivation 1.vhish would oscur system in DD-01 is credited by the multi-compartment analysis for a fire scenario from outside of DD-01 propagating in through a failed fire-rated penetration seal. Based on the restricted propagation path. and the cable tray configuration of solid metal bottoms with ceramic fiber tops. damage would be limited to a single fire pump circuit. Activation of the automatic suppression system in this fire compartment is expected prior to damaging both of the cables. Once started, the elestris pump 1Nould be shutdown losally and its operation would not be affested Davis-Besse Page L-19 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval by the fire damage to either or both fire pump remote start circuits. Fire I FPE RA1 oG extinguishers are available for manual suppression.
* Fire Compartment FF-01 -This compartment consists of the MGR, which is constantly occupied. There is no automatic suppression in the MGR. Small fires I FPERA106 would be extinguished Consistent with wheeled or hand held the guidance from NUREG/CR-6850. the MGR fire analysis credits handhold extinguishers 9f-a for fire hose from nearby staiF\*.:ells suppression. The fire pumps and controls are in compliance with Section 3.5.5 in the remaining fire compartments of the plant. In addition. the following describes the power supply separation compliance:
* The electric fire pump is powered from two non-essential 480VAC switchgear buses which also can be supplied by off-site power. Each power supply is routed in a separate underground conduit from the switchgear room to a manhole in the yard (Fire Compartment MA-01 ). then directly into Fire Compartment BH-01 through a duct bank. Fire in BH-01 or other compartments that could affect the electric fire pump or its power supplies do not affect the diesel fire pump.
* A fire in either Fire Compartments BE.:01 or BF-01 could affect the diesel fire pump. but would not affect the electric fire pump nor its onsite or offsite power supplies. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: A The unlikely event of a fire in Fire Compartment BG-01, DD-01, or FF-01 that renders I FPERA106 the starting remote start circuits for both fire pumps inoperable would not affect tAe ability to supply the required fire 'Nater during a fire nuclear safety functions since the fire pumps are not relied upon for nuclear safety functions these fire scenarios and the nuclear safety performance goals of NFPA 805 Section 1.5 are still achieved with available safe shutdown equipment. In the event of damage to both fire pumps' starting circuits, it would not affect the ability to perform cm a local emergency start of the fHHRP The plant is also provided 'Nith alternate means of manual suppression via fire extinguishers to contain the fire while the electric fire pump is being_ manually locally started. In addition electric fire pump would not be affected. Also, offsite agencies are available to provide firefighting assistance and portable equipment is available to baGk charge pressurize and supply the fire protection water supply system. Therefore there is no impact on the nuclear safety performance criteria. The radiological release revie'N was reviews were performed based on the manual fire I FPERA106 suppression activities in areas containing or potentially containing radioactive materials and is not dependent on the location of the fire pumps pump controls. The location of I FPERA106 the fire pumps pumps' remote start cables does not change the radiological release evaluation performed that concluded that potentially contaminated water is contained \ and smoke is monitored. The location of the remote start circuit cables for the fire pumps do not add additional radiological materials to the area or challenge systems Davis-Besse Page L-20 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval boundaries. Therefore, remote start circuit cables for the fire pumps currently in use at DBNPS has no impact on radiological release performance criteria. Safety Margin and Defense-in-Depth: The lack of rated fire barriers between the remote start circuits for the electric fire pump I FPERA1os and the diesel fire pump does not negate the ability to s1:1pply the req1:1ired water d1:1ring suppress a fire. In the using credited means. Even in the unlikely event that both sets of remote start cables are damaged and impair both fire pumps' starting circuits , it *.vo1:1ld not affect prior to automatic start due to low fire main pressure, the ability to perform an emergency start of the electric fire pump or provide an alternate water supply would not be affected. Therefore, the inherent safety margin and conservatisms in these analysis methods remain unchanged. The lack of tested fire-rated separation between fir,e pump circuits does not result in compromising credited automatic fire suppression functions, manual fire suppression functions, or post-fire SSD capability. Therefore, the safety margin inherent in the analysis for the fire has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls) (2) Rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic, fire suppression, manual fire suppression, pre-fire plans) (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions) Per NFPA 805 Section 1.2, DID is achieved when an adequate balance of each of these elements is provided. The location of the fire pumps and the associated starting circuits does not affect Echelon 1. Echelons 4-,2. and 2. Echelon 3 is are maintained by I FPERA1os I ' adeq1:1ate separation of the f-ire p1:1mps to ens1:1re one a) analysis showing that water-based fire suppression is not needed in fire p1:1mp is operable if a fire affects another p1:1mp. In the event of damage to scenarios that affect both fire p1:1mps' starting circ1:1its, it wo1:1ld not affect the ability to perform an emergency start of the p1:1mp. pumps, and b) alternate provisions for establishing a fire protection water supply. The location for the starting circuits does not result in compromising a1:1tomatic fire s1:1ppression f1:1nctions, the credited manual fire suppression functions or post-fire nuclear safety capability. Since a balance of the elements is provided, DID is achieved. Conclusion: NRG approval is requested for the lack of tested fire-rated barrier separation between I FPE RA1 os the remote start circuit cables running from the MGR to each respective fire pump as required by NFPA 805, Section 3.5.5. The present electrical circuit configuration meets NFPA 20-1974 and previous BTP 9.5-1 commitments. In the event that both sets of remote start cables are damaged and impair each corresponding the pump's starting I FPERA1os circuit, the electric fire p1:1mp can be locally man1:1ally started. Additionally, all compartments have other credited manual firefighting methods suppression method of using portable fire extinguishers is available. Davis-Besse Page L-21 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Furthermore, the remote start circuits are routed through separate channels, and not routed through the same raceways or conduits. Where the circuits are routed in the same rooms, they are in solid bottom separate cable trays with solid bottoms with a layer of ceramic fiber on top or in separate metal conduits. In the event of a fire, damage to these remote start cables after a pump was started would not prevent the pump from continuing to run. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release,
* Maintains safety margins, and
* Maintains fire protection DID (fire prevention fire detection, fire suppression, mitigation, and post-fire safe and stable capability). Davis-Besse Page L-22 I FPE RAI 06 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approva1Request5 NFPA 805 Section 3.5.14 states: All fire protection water supply and fire suppression system control valves shall be under a periodic inspection program and shall be supervised by one of the following methods. (a) Electrical supervision with audible and visual signals in the main control room or other suitable constantly attended location. (b) Locking valves in their normal position. Keys shall be made available only to authorized personnel. (c) Sealing valves in their normal positions. This option shall be utilized only where valves are located within fenced areas or under the direct control of the owner operator. DBNPS is requesting approval for curb box valves in the fire protection water supply that do not meet the NFPA 805, Section 3.5.14 requirements for electrical supervision, locking, or sealing. These valves are included in DB-FP-04031, "Quarterly Fire Valve Alignment Verification," and are allowed by NFPA 24, . "Standard for Outside Protection -1970." Basis for Approval Request 5: NFPA 805, Section 3.5.14 requires the valves to be electrically supervised, locked, or sealed. Several control valves in the supply lines to the individual fire hydrants and a portion of the south loop are underground valves and are not supervised as required. These valves do not have an extended permanently attached method of changing the valve's position. This type of valve was selected because the location of the underground piping in the yard precludes the installation of a post indicator valve above the surface level that would interfere with vehicle traffic, equipment movement, and have the potential for damage. These valves are referred to as curb box valves in DB-FP-04031. The subject underground control valves are provided with a curb box for access and require the use of a long handle T-wrench to reposition the valve. These valves are periodically inspected per DB-FP-04031, to confirm that they are in the required open position. The underground valves and/or curb boxes are not designed to accept monitoring switches, locks and chains, or sealing devices. The valves are not subject to inadvertent closure or tampering because they require the use of a special T-wrench to be operated. Curb box valves are used to control the water supply to outdoor fire hydrants. Curb box valves also provide isolation to the south loop, which controls the water supply to a few hydrants, to the Containment Access Facility, and to the Personnel Shop Facility, per DB-FP-04031 and M-016A, "Station Fire Protection System." The valves are located underground, so they cannot be inadvertently operated or accidentally mis-positioned. The valves are included in a periodic inspection program that verifies that the valves are in the correct position. Even though the valves do not have a method to monitor Davis-Besse Page L-23 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval tampering or repositioning as other type of valves, their inaccessibility and the physical requirement to obtain the special T-wrench prevents tampering. NFPA 805-2001 references NFPA 24-1995, which in Section 3.6.2 has an exception for non-supervised underground gate valves with roadway boxes (i.e. curb box valves). Therefore, due to their inaccessibility, supervision or valve locking is not required. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The non-supervision of curb valves for the underground yard fire main loop does not affect nuclear safety performance criteria (NSPC) since the valves are located underground and are not subject to inadvertent closure or tampering because of their inaccessibility and requirement to use a special T-wrench for operation. The valves are operated by trained personnel to ensure that water is available to plant fire protection systems as required; therefore, there is no impact on the NSPC. Periodic inspections ensure that the valves are in the correct position. Similarly, the non-supervision of curb box valves has no impact on the radiological release performance criteria. The radiological review was performed based on the potential location of radiological concerns and is not dependent on the fire protection water system. The use of non-supervised curb box valves does not change the radiological release evaluation performed that concluded that potentially contaminated water is contained and smoke is monitored. The fire protection water system does not add additional radiological materials to the areas or challenge systems boundaries. Safety Margin and Defense-in-Depth: The non-supervised curb valves for the underground fire main loop require a special T-wrench for operation, and are operated by trained, authorized personnel. The curb valves are periodically inspected to ensure they are in the correct position. The code edition of NFPA 24 referenced in NFPA 805 and subsequent editions allows an exception not to lock or electrically supervise curb box valves. Therefore, the safety margin inherent in the analysis for the fire event has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions). Per NFPA 805, Section 1.2, DID is achieved when an adequate balance of each of these elements is provided. Echelon 1 is met through plant fire prevention procedures and is not affected by this configuration. Echelons 2 and 3 are met since the non-supervised valves do not adversely affect the system pressure or flow, nor compromise fire suppression Davis-Besse Page L-24 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval functions, manual fire suppression functions, or post-fire safe shutdown capability. Since a balance of the elements is provided, DID is achieved. Conclusion: NRC approval is requested for unsupervised curb box valves as required by NFPA 805, Section 3.5.14. The underground valves and/or curb boxes are not designed to accept monitoring switches, locks and chains, or sealing devices. The valves are not subject to inadvertent closure or tampering because they require the use of a special T-wrench to be operated and are located below grade. The valves are located underground, so they cannot be inadvertently operated or accidentally mis-positioned. Therefore, even though the valves do not have the method to monitor tampering or repositioning as other type valves, their inaccessibility and the physical requirement to obtain the special T-wrench prevents tampering. NFPA 24 referenced in NFPA 805 allows an exception not to lock or electrically supervise curb box valves. The valves are included in the DBNPS inspection program, which periodically verifies that the valves are in the correct position. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release,
* Maintains safety margins, and
* Maintains fire protection DID (fire prevention fire detection, fire suppression, mitigation, and post-fire safe and stable capability). Davis-Besse Page L-25 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approval Request 6 NFPA 805 Section 3.6.3 states: The proper type of hose nozzle to be supplied to each power block area shall be based on the area fire hazards. The usual combination spray/straight stream nozzle shall not be used in areas where the straight stream can cause unacceptable damage or present an electrical hazard to fire-fighting personnel. Listed electrically safe fixed fog nozzles shall be provided at locations where high-voltage shock hazards exist. All hose nozzles shall have shutoff capability and be able to control water flow from full open to full closed. DBNPS is requesting approval for using adjustable fog nozzles at hose stations which are located outside the high voltage electrical switchgear rooms. Basis for Approval Request 6: The current nozzles allow trained fire brigade members to select the desired spray pattern manually in lieu of limiting the nozzle's capabilities to a fixed fog, giving the trained firefighter more control over the various types of fires that could potentially occur in the vicinity of these hose stations. Although Hose Station HR-51 is located in Turbine Building Room 326, it is the nearest hose station to Room 325 (High Voltage Switchgear Room A in Fire Compartment S-01 ), which is located in the Auxiliary Building. Similarly for Hose Station HCS-23, which is located in Room 321 of the Auxiliary Building, it is the nearest hose station to Room 323, High Voltage Switchgear Room Bin Fire Compartment Q-01 (A-223F, "Fire Protection General Floor Plan El. 585'-0"" and C-FP-013.10-007, "Fire PRA Task 1 -Plant Boundary Definition and Partitioning"). Either of these hose stations may potentially be used in the event of a fire in one of the high voltage switchgear rooms. These hose stations can provide manual suppression capabilities for a multitude of areas and hazards within the Turbine Building and Auxiliary Building. Fire brigade members are trained to use the appropriate spray pattern for different types of fires expected at DBNPS. In the event of an electrical fire, fire brigade members are trained on using the appropriate fog pattern. Administrative procedure DB-FP-00005, "Fire Brigade," refers to Fire Brigade training requirements in NT-OT-07007, "Fire Brigade Training." Administrative procedure NT-OT-07007 establishes the requirements for the training and qualification of DBNPS Fire Brigade members. Training includes both classroom and on-the-job practical training to ensure that the Fire Brigade members have the necessary knowledge, skills, and abilities to successfully fight fires at DBNPS. Fire Brigade Member Qualification Manual FBl-900, states in the Practical Requirements section, "Set-up and operate a combination fog nozzle." Nuclear Operating Business Practice DBBP-TRAN-0012, "Conduct of Live Fire Training," states that the primary objective of live fire training is "to train and evaluate the Fire Brigade in the use of recognized safe firefighting practices in extinguishment of Class A, B, C, and D type fires." Since the fire brigade members are experienced and trained to use the correct spray pattern, it is essential for the fire brigade members to have the appropriate tools to extinguish fires using practiced techniques. The adjustable fog nozzles allow the Fire Brigade to extinguish potential electrical fires in other areas. The nozzles currently in use at DBNPS allow the Fire Brigade to adapt Davis-Besse Page L-26 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval manual suppression techniques quickly to potentially changing fire sources and scenarios. Limiting the nozzle capability to fixed fog will not enhance plant safety and could delay the Fire Brigade response time if the nozzle is required to be interchanged to match the source and scenario. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The use of adjustable nozzles in lieu of fixed fog nozzles at hose stations does not affect nuclear safety performance criteria-. The fire brigade members are experienced and trained on using the nozzles. Hose stations can be used on multiple types of fires in the Turbine, Auxiliary Buildings, other locations, as well as the high voltage switchgear rooms. It is critical to maintain a nozzle that can quickly be adjusted to adapt to any expected fire source, as well as potentially changing fire scenarios. The use of adjustable nozzles at hose stations has no impact on the radiological release performance criteria. The radiological review was performed based on the potential location of radiological concerns and is not dependent on the fire protection water system. The use of adjustable nozzles at hose stations does not change the radiological release evaluation performed that concluded that potentially contaminated water is contained and smoke is monitored. The use of adjustable nozzles at hose stations does not add additional radiological materials to the areas or challenge systems boundaries. Safety Margin and Defense-in-Depth: Fire brigade members are trained to use the appropriate spray pattern for different types of fires. It is also essential for the fire brigade members to have the appropriate tools to extinguish fires using practiced techniques. The nozzles currently in use allow the fire brigade to adapt manual suppression techniques to changing fire sources and scenarios. Limiting the nozzle capability to fixed fog will not enhance plant safety. Therefore, the safety margin inherent in the analysis for the fire event has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions). Per NFPA 805, Section 1.2, DID is achieved when an adequate balance of each of these elements is provided. Echelon 1 is met through fire brigade training procedures and is not affected by this configuration. Training includes both classroom and on-the-job practical training to ensure that the Fire Brigade members have the necessary knowledge, skills, and Davis-Besse Page L-27 ____ J FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval abilities to successfully fight fires. Echelon 2 is met since the use of adjustable nozzles in lieu of fixed fog nozzles at these hose stations will allow the fire brigade members to adapt the manual suppression capability to the appropriate fire scenarios. Echelon 3 is met since the use of adjustable nozzles do not adversely affect the system pressure or flow, nor compromise fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability. Since a balance of the elements is provided, DID is achieved. ' Conclusion: NRC approval is requested to approve the use of adjustable fog nozzles in lieu of fixed fog nozzles at hose stations. This is in compliance with NFPA 805, Section 3.6.3 regarding the proper type of hose nozzle for the fire hazard, but is not in compliance with the requirement for fixed fog nozzles where high-voltage shock hazards exist. Fire Brigade experience and training is relied upon to ensure the appropriate nozzle setting is used on each type of fire. The performance-based approach is acceptable based on the following:
* It is impractical to limit the nozzle capabilities to a fixed fog nozzle because of its versatile requirements.
* The nozzles in use have the capability for fog spray patterns and are able to extinguish electrical fires effectively.
* The fire brigade members are experienced and trained on the use of the appropriate spray pattern for each specific fire scenario.
* The intent of the NFPA 805, Section 3.6.3 requirement is met because the capability to provide the appropriate hose stream (i.e., fog pattern) can be provided at these hose stations due to the adjustable capabilities of the nozzle. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release,
* Maintains safety margins, and
* Maintains fire protection DID (fire prevention fire detection, fire suppression, mitigation, and post-fire safe and stable capability). Davis-Besse Page L-28 
-------------------------------------------------FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approval Request 7 NFPA 805 Section 3.9.4 states: Diesel-driven fire pumps shall be protected by automatic sprinklers. DBNPS is requesting approval for the lack of automatic sprinkler coverage over the diesel-driven fire pump. ' Basis for Approval Request 7: Although the diesel-driven fire pump is not protected by automatic sprinklers, the following characteristics of the diesel-driven fire pump (Fire Compartment BE-01, Room 51) exist and thus serve as a basis for acceptability of the configuration. The driven fire pump:
* Is located in a separate room and divided by a 3-hr rated fire wall from the electric fire pump (Fire Compartment BH-01, Room 15).
* Is separated from adjacent compartments by 3-hr rated fire walls (Fire Compartment BD-01, Room 50; Fire Compartment BF-01, Rooms 52 and 52A).
* Is protected by early warning smoke detection. Alarms are received in the Main Control Room (MCR), which is constantly attended.
* Additionally: o Manual suppression means are available by use of the following elements:
* Protection by a manually isolated sprinkler system. The manual valve (FP215) is located in an adjacent room, which would not require the operator to enter the pump room prior to charging the supply pipe with water. The manual control valve is easily accessible and appropriately marked.
* Portable fire extinguishers and local hose stations are available from adjacent fire compartments (Fire Compartment BD-01, Room 50; Fire Compartment BF-01, Room 52; Fire Compartment BG-01, Room 53).
* Has a relatively low combustible loading in the room and combustibles in the area are controlled. o Plant pre-fire plans and associated training ensures that the fire brigade and operations personnel are adequately trained regarding manual actuation and response to a fire in this area. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The lack of automatic sprinklers to protect the diesel-driven fire pump does not affect nuclear safety. Both the diesel-driven and electric fire pump individually have the ability to supply the required fire water and the diesel engine-driven fire pump is not relied upon for other water requirements. Therefore there is no impact on the nuclear safety performance criteria. Davis-Besse Page L-29 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval The lack of automatic sprinklers to protect the diesel engine-driven fire pump has no impact on the radiological release performance criteria. The radiological release review was performed based on the manual fire suppression activities in areas containing or* potentially containing radioactive materials and is not dependent on the location of the fire pumps. The radiological release evaluation concluded that potentially contaminated water is contained and smoke is monitored. The configuration of the diesel-driven fire pump room does not add additional radiological materials to the area or challenge systems boundaries. Safety Margin and Defense-in-Depth: The lack of automatic sprinklers to protect the diesel-driven fire pump does not affect the ability to supply the required fire water in a fire event. Only one fire pump is required for fires in safety-related areas. The use of the diesel-driven fire pump has been defined by the limitations of the analysis of the fire. Therefore, the safety margin inherent in the analysis for the fire has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect, control and extinguish fires that do occur, thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions). Per NFPA 805, Section 1.2, DID is achieved when an adequate balance of each of these elements is provided. The lack of automatic sprinklers to protect the diesel engine-driven fire pump does not affect administrative controls for preventing fires from starting; therefore echelon 1 is not affected by this configuration. The lack of automatic sprinklers to protect the diesel engine-driven fire pump does not impact the ability of the automatic suppression systems to perform their functions. A fire affecting the diesel-driven fire pump would not impact the ability to provide 100% of the required fire water demand for safety related areas due to the capabilities of the electric fire pump. The lack of automatic sprinklers to protect the diesel engine-driven fire pump does not allow fire propagation through the barrier, and does not result in compromising automatic fire suppression functions, manual fire suppression functions, or post-fire SSD capability. Since a balance of the elements is provided, DID is achieved. Conclusion: Based on this review, the existing mitigating features provide an equivalent level of fire protection to the fire pump area. Early notification of fire is provided. Manual suppression means are available by use of sprinklers, which can be actuated without entry into the fire pump room, and/or by the use of other manual devices such as portable fire extinguishers and local hose stations. Davis-Besse Page L-30 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release,
* Maintains safety margins, and
* Maintains fire protection DID (fire prevention fire detection, fire suppression, mitigation, and post-fire safe and stable capability). Davis-Besse Page L-31 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approval Request 8 The NRG approved an exemption to 10 CFR 50, Appendix R, Section 111.G.2, in letters to Toledo Edison dated November 23, 1982 (Log 1138) , and Deeember 26, 2002 (Log 6041). The exemption was for Fire Compartment T 01 that does not comply with 111.G.2 because the separation between the CC'N pumps is less than 20 feet and 1 hour fire barriers have not been installed between the pumps. The Exemption dated Deeember 26, 2002, states in part ... "The GGl/'/p1:1mp room at the DBNPS is "L "shaped and appro-ximate!y 67 feet Jong and 26 feet to 35 feet 'Nide. The entire room is a separate fire area bo1:1nded by fire barriers ha*1ing a three ho1:1r rating. The room contains the following SSD components: three GGl!1/p1:1mps, heat exchangers, a ventilation system and associated flow svAtches, temperafl:Jre indicators, iso!ation v-a!'IOs, control!ers, and cab!ing. On!y one operationa! GGl!1/p1:1mp is req1:1ired for SSD. Each GGV'lp1:1mp contains two ga!lons of Glass!!! !1:1be of! and is shie!ded to protect against sprin.'<!er water spray. Centro! and power cables are in cond1:1its and the .CHA report contains data that indicate a comb1:1stib!e loading of 1, 375 btul-ff.. Smoke detectors, a wet pipe sprink!er system, a man1:1a! hose station, and portable exting1:1ishers are provided for fire detection and s1:1ppression. The three CCV'/ pumps are located in the 35 foot wide section of the room and are separated 11 feet on center. This configuration does not meet the 20 foot separation req1:1ired in Appendix R, Section !!!.G.2.b. The 1982 exemption was granted due to the acti*1e fire protection features pro*1ided and the fo.'!owing passive fire protection feafl:Jres: 1. Jn situ combustib!e !oading is significantly !ess than one hour fire d1:1ration. 2. Redundant fire pumps [sic] are hori:zontally separated, 22 feet on center. A spare third p1:1mp is betv1een the red1:1ndant p1:1mps with only tv10 ga.'!ons of GI-ass !.'! !ube oil comprising the only significant intervening combustible. 3. G1:1rbldikes are pro*1ided aro1:1nd each p1:1mp to contain potentia! of! !eakage. 4. One hour fire rated barriers are pro*1ided on cab!es and *1a!ves. Since the granting of the existing exemption, the !icensee has re eva!1:1ated the fire hazards and made modifications to e!iminate the need for fire wrap on cab!ing and v-a!*1es in the GGV'lroom. DBNPS informed the NRG of these e*1a!uations and modifications in a series of !otters. On March 15, 1989, the !icensee s1:1bmitted a !otter postulating the !oss of CCV'/ room *1entilation due to a fire and the e#ect on the CCV'/ pumps. From manufacfl:Jrer's data, the Hcensee determined that the maxim1:1m room temperature the pumps co1:1!d remain operationa! was 1856F. The !icensee conc!1:1ded that since the sprink!er system operated at 1656F, the sprinkler system wou!d keep the p1:1mps from reaching 1856F, allowing the p1:1mps to remain operational. Therefore, the Davis-Besse Page L-32 I SSA RAI 12 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval !ieeRsee eoRe.'-l:Jded the CCV'/ room v-eRfilafioR was Rot Reeessary for SSD aRd fire wr:ap OR the assoeiated eabliRg for the veRti!atioR system v1as Ro loRger Reeessary. OR ,cebruary 16, 1990, the !ioeRsee s1Jbmitted a Jetter OR Rew fire proteotioR oomp!iaRoe approaohes iRo!uding a .r:e eva.'-l:JatioR of the Reoessity for fire wrap OR the CCV'/ header va!ves. For SSD, these va!'les Vlere orfgiRaJ!y oredited with pro*1idiRg oooliRg for the make1Jp p1Jmps aRd the immediate mestab!ishmeRt of reaotor ooo.'aRt p1Jmp (RCP) seal oooliRg. The re e*1a!1JatioR Roted that the high pressl:JrfJ iRjeotioR system wi!! ass1Jre reaotor ooo.'aRt system .irJjeotioR iRveRtory aRd reaotivity ooRtro! aRd RCP sea! iRjeotioR. The !ioeRsee mported the insta.'!atioR of Rew RCP seals that do Rot req1Jire .immediate ooo!iRg, a!JowiRg time to maR1JaJ!y !iRe 1JP *1a!ves for RCP sea! oooliRg. Therefore, the !ieeRsee ooRe!uded that the CCV'/ header 'la!ves were Rot immediately req1Jired for SSD aRd fire wrap '/'las Ro !oRger Reoessary. D1Jr.ir1g 1992, the !ioeRsee rep!aoed servioe water (SV''9 va!*1es OR the CCV'/ heat D*GhaRgers with fai! safe valves. The replaoemeRt *1a!*1es 1Jse a siRgle so!eRoid, aRd dl:Jr.irlg a fim the va!ves fai! iR aR opeR positioR a!!owiRg the SV'/ flow tl=u:o1Jgh the CCV'/ heat e:xohaRger. The !ioeRsee 00Ro!1Jded that fire w-rap a.co1JRd these valves was RO !oRger Reoessary. OR JaR1Jary 25, 1999, the !ioeRsee Ratified the ,l\lRC that eiro1Jit modifioatioRs had e!im.irlated the Reed for fire wrap OR the CCV'/p1Jmp eoRtro! e.iro1Jits. The !ieeRsee remov-ed !oea! ooRtro!J.ers aRd .I.ow flow aRd high temperafl:Jm limit switohes from the CCV'/p1Jmp ooRt.co! ei.r:o1Jits. l1.1Jtomatio start ofredlJRdaRt p1Jmp aRd va!ve traRsfer .l.ogio rema.irled aRd !oea! eoRtro! VJOIJ!d be doRe from the switohgear. The !ioeRsee e0Rcl1Jded that remo*1a! of these eiro1Jits e!im.irlated a poteRtiaJ so1Jroe of sp1Jrfo1Js trips of aR operatiRg CCV'lp1Jmp aRd therefore fire wrap OR this e.i.ro1Jitry was RO .'-ORger req1Ji.r:ed. The UeeRsee s1Jpp!ied, as part of the 01.:JrreRt f>><:emptioR req1Jest, a tab!e that ideRtified the oab!iRg aRd valves iR the CCV'/ room that orfg,irJaJ!y req1Ji.r:ed fire wrap aRd the , oorrespoRdiRg eva!1JatioR aRdlor modffioatioR that e!imiRated the Reed for the fire 'llrap. The IJRder!yiRg p1Jrpose of AppeRdiK R, SeotioR !!.'. G is to provide masoRab!e ass1JraRoe that at least ORO meaRs of aohieviRg aRd maiRta.irliRg SSD ooRdftioRs wi!! remaiR available d1JriRg aRd a#er aRy posfl:J!ated fire. EKemptioRs to the speeifio .r:eq1J.iremeRts of the r1J.'e oaR be graRted wheR, amoRg other th.irlgs, eiro1JmstaRees f>><:ist Sl:Joh that the IJRder!ying p1Jrpose of the fl:J!e is aohie*1ed, noflllithstanding speeifio rule reql:Jirements am not met. The SSD .r:eq1Jirements at DB.l\lPS req1Ji.r:e at !east one CCV'lp1Jmp to .r:emain operational d1Jring aRd a#er a fi.r:e. The November 23, 1982, f>><:emptioR al!owed less than 20 foot separatioR aRd RO fi..r:e barrfe.cs betweeR the CCV'/p1Jmps. This was based OR the eKistenoe of adeq1Jate aotive and fire proteotion feafl:J.r:es that provided Davis-Besse Page L-33 I SSA RAJ 12 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval I reasonable assuranoe tl=mt one CCWpump w-ou!d remain operational. The aotive proteotion features were smok-e deteotors, a 1Net pipe sprinkler system, a manual hose station, and portable fire extinguishers. The passive fire proteotion features pro*1ided Ill-ere: low in situ oombustib!e loading, minima! inteAf()ning oombustibl-es, and ourbing around the puFRps to oontain an of! sp#! fire, in addition to the fire wrap that is the subjeot of the ourrent exeFRption .r:equest. Aeti*1e fire proteotion features have not ohanged sinoe the granting of the e-xisting exemption and eombustib!e loading remains low. Under the re evaluations disoussed earlier proteotion of CCII'/ header 'IB!ves and *1-entf.'.ation oircuits is not neoessary in order for at !east one CCll'lpufflfJ to remain operationa! during and after a fire. Modifioations have ohanged the SV'I va!ves to fail safe and removed oirouits that would cause a spurious puFRp trip. ln summary, DB.'VPS has demonstrated reasonable assuranee of the a*J-ai!abiJity of CCII'/ during and a#er a posfl:J!ated fire in the CCll'lp1:1mp room, nofllJithstandfng Jess than 20 foot separation between the CCVJ/pumps, the absence of fire barriers and no fire 'llrap on the SSD cables and 'l-8!ves in the CCII'/ pump room. Therefore, under these oircumstanoes, the underlying purpose of the reg1:1lation is stiJ! aohieved. 4.0 CONCLUSION On the basis of the staff r<niew and evaluation of the information pro'lided in the licensee's request to amend the existing exemption, the staff concludes that the request for exemption from the teehniea! req1:1irements of Seetion !!!. G.2 of Appendix R to 10 CFR Part 50 demonstrates that under the proposed alternative oircumstances from original circumstances that existed at the time the existf.ng exeFRption was granted, the underlying purpose of the regulation is sti!! aohieved. Thus, the P.'RC staff has determined that the.r:e a.r:e speoia! oircumstances present, as speoified in 10 CFR 50.12(a)(2)(ii), in that app.'ication of Section !!!. G.2. of 10 Cf=R Part 50, Appendix R is not neoessary in order to aohieve the underlying purpose of the regulation." NFPA 805 Transition Review Results D1::1ring the transition to NFPA 805 each exemption to 10 CFR 50, Appendix R was e'lal1::1ated to ensme the basis for the exemption remained 'Jalid. D1::1ring the e'Jal1::1ation of Licensing Action 02 (LA 02), it was determined that the following exemption attrib1::1tes req1::1ire 1::1pdating: 1. The original exemption SER stated that fixed comb1::1stibles for T 01 consisted of six gallons of l1::1bricating oil. The e'lal1::1ation determined that there is approximately two gallons of l1::1bricating oil per CC'N p1::1mp, and oil to operate ventilation dampers, 'Nith a total of nine gallons of oil in T 01.
* E'lal1::1ation Davis-Besse Page L-34 I SSA RAJ 12 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval i. The equipment and total quantity of lube oil in fire compartment T 01 I ssARA112 has not changed since the initial exemption request. Due to a lack of inteF\,'ening combustibles, a fire involving the damper actuators would not affect the GC'N pumps. ii. The small change of reported oil quantity for a room of this si:z:e (approximately 2036 has a very low overall effect to the total fire severity of the room. 2. The lube oil properties used at the time of the exemption request indicated a flashpoint of 450&deg;F and an ignition temperature of approximately 700&deg;F could not be verified due to changes in the lubrication oil process. The current lubricating oil properties for Mobil Medium and Mobil Light state that the flashpoint is greater than 3Q2&deg;F. In addition, the current MSDS depicts "N/D"; therefore, the auto ignition temperature is indeterminate. .. Evaluation i. The lower reported flashpoint temperature is of low significance. A review of the potential sources from NU REG 6850 Task 6 Analysis for fire ignition sources does not show any potential ignition sources within the fire compartment to generate the temperatures required to reach the flashpoint. ii. The CC'A' pump motor is the closest fixed ignition source and, due to the low energy of a motor fire, it is not likely for a motor fire to ignite oil with a flashpoint of greater than 3Q2&deg;F. 3. The exemption SER dated December 26, 2002, stated that the combustible loading for T 01 was 1,375 BTU/FV. The current calculations still indicate significantly low combustible loading for T 01; however, the calculation no'N includes the cable insulation contained within the steel conduit, some HVAC thermal insulation, and the abandoned Thermo Lag insulation. The current quantity of combustible loading is approximately 10,000 BTU/FT2.,.
* Evaluation Davis-Besse i. The new combustible loading value is acceptable because it is still well belo1N the reported value of less than a 1 hour rated fire severity as originally described, and the automatic 'Net pipe suppression remains installed, functional, and is transitioning to NFPA 805 as a credited system. ii. The additional combustibles contained within the fire compartment are distributed uniformly throughout the fire compartment, but not in a configuration to create intervening combustibles. Due to the small quantities, it is very unlikely for a fire within the compartment to invol11e all combustibles. iii. Combustible loading calculations determine the fuel duration contributions, estimating free oxygen and the total consumption of all available fuel sources. In actuality, not all the fuel is consumed Page L-35 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval due to oxygen limitations, limited surfase area exposure, and fire suppression; therefore, the salsulated fire severities for any given area are sonservative. 4. DBPNS submitted a letter dated Desember 14, 2004, (Serial No. 3105) to the NRG notifying them of a shange in fire sompartment T 01 sprinkler head astivation temperatures from 165&deg;F to 212&deg;F. This temperature *11as not asknowledged *11ith a SER; therefore, it is insluded as a reported change in this request.
* Evaluation i. Typisally, fires produce a buoyant plume that rises to the ceiling *.vhere heated gases begin to assumulate. As the fire continues to burn, hot gases rise into a stratified layer, resulting in a sontinuing insrease in its depth. In the meantime, the air belmu the hot gas layer remains at ambient temperature. The CC'lV pump room has a ceiling height of approximately 17 feet. The top of the CCV\' pump motors are approximately 7 feet above the floor, 'Nith the motor ventilation air intakes at a slightly lm\ler elevation. Therefore, the distance from the CC'N pump motor air intakes to the room seiling exseeds ten feet. Even though the sprinkler astuation temperature is no1N higher than the 185&deg;F temperature limit for the CC'N pump motor intake, the vertical distanse betv.1een the sprinklers and the CCVV pump motor intakes ensures that sprinkler astuation will still ossur before the CCW pump motor intake temperature limit is exseeded. In no ease will the temperature atthe CCW motor air intakes exseed 185&deg;F. Based on the above evaluation of the shanges sinse the exemption SER approvals, it has been demonstrated that the shanges are insignifisant and do not shange the intent or margin of safety from the approved exemption request; therefore, approval of the surrent conditions is requested to transition LA 02 into the DBNPS NFPA 805 Lisensing Basis. Aeeeptanee Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: NFPA 805 Sestion 4 .2.3.3(s) requires a 1 hour fire barrier bePl1een redundant safe shutdoi.\ln components, and fire detestion and suppression in the area. The CC'IV pumps are losated within the fire sompartment T 01, which has credited detection and suppression. The absense of 1 hour fire barriers separating the CC'IV pumps has no impact on fire suppression activities, nor impact on radiological release performance sriteria. The radiological review was performed based upon the potential location of radiological conserns and is addressed by the fire brigade response procedures, training to minimize radiological release by ensuring that potentially contaminated water is sontained, and that potential radiologisal smoke is monitored. Therefore, since one CCVV Pump would be available in the event of a fire in this sompartment, and any Davis-Besse Page L-36 I SSA RAI 12 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval potential for radiologisal release is monitored, .there is no impast on nuslear safety and radiologisal release performanse criteria. Safety Margin and Defense in Depth: The CCVV pumps losated in compartment T 01 are su#iciently separated and there are enough *defense in depth (DID) fire protestion features in plase to ensure that a fire initiating at any of the three CCVV pumps has a low likelihood not to impact the remaining t\\'o. Therefore, the safety margin inherent in the analysis for the fire event has been preseF\<ed. DID protests publis health and safety from radio::tstive or hazardous material releases resulting from a fire event. Multiple independent and redundant echelons of DID offset potential human errors and mechanical failures so that no single echelon, no matter how robust, is exclusively relied upon. The three echelons of fire protestion DID inslude the follmuing: 1. To fires from starting (sombustible/hot 'Nork controls) 2. Rapidly detest, sontrol and extinguish fires that do ossur, thereby limiting damage (fire detection systems, automatis fire suppression, manual fire suppression and pre fire plans); 3. Provide adequate level of fire protestion for systems and structures so that a fire will not prevent essential safety funstions from being performed (fire barriers, fire rated sable; sucsess path remains free of fire damage and resovery actions). Per NFPA 805, Section 1.2, DID is ashieved 1Nhen an adequate balance of eash of these elements is provided. At DBNPS, the subjest CCVV pumps sontain very little lubrisation oil in their unpressurized reseF\<oirs and there are no erodible ignition sourses nearby. The sabling within this fire compartment is routed through Sshedule 40 steel sonduit. The site has administrative sontrols on transient sombustibles and controls potential ignition sourses; therefore, DID eshelon 1 is preserved. In the unlikely event of a fire, the fire would be promptly detested by the fire detestion system. Onse a fire detester is activated and the presence of a fire is confirmed, the pre fire plans provide guidanse for a well trained fire brigade to respond promptly to the emergensy. Furthermore, the automatic 'wet pipe' sprinkler system 1..:ould begin suppression astivities at a temperature belm*.* whish the hot gas layer temperature would affest the remaining CC'IV pumps. In addition, fire extinguishers and hose stations are losated within and are readily assessible from nearby fire areas, preserving DID echelon 2. DBNPS Sshedule 40 steel sonduit provides a robust fire barrier for cirsuit separation of redundant CCW trains to preseF\<e one train free of fire damage, enabling safe shutdown of the plant. Limited fixed ignition sourses make a significant fire unlikely to initiate in Fire Compartment T 01. The existing distance separating the CCVV pumps, lack of signifisant intervening sombustibles, automatic suppression and detestion, the fire brigade, and administrative Davis-Besse Page L-37 I SSA RAI 12 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval controls provide a balance of elements that achieves DID and slJpports a margin of safety at DBNPS. Conclusion: NRG approval is requested for the lack of 1 holJr fire rated barriers separating the three CCVV plJmps in fire compartment T 01 (Room 328) per NFPA 805, Section 4 .2.3.3(c). DBNPS determined that the performance based approach satisfies the following criteria:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nlJclear safety and radiological release,
* Maintains safety margins, and
* Maintains fire protection defense in depth (fire prevention, fire detection, fire suppression, mitigation, and post fire safe and stable capability). This approval request has been withdrawn. Davis-Besse Page L-38 I SSA RAI 12 J FE NOC Attachment L -NFPP. 805 Chapter 3 Requirements for Approval Approval Request 9 NFPA 805 Section 3.6.1 states: For all power block buildings. Class Ill standpipe and hose systems shall be installed in accordance with NFPA 14. Standard for the Installation of Standpipe. Private Hydrant. and Hose Systems. DBNPS is requesting approval for the lack of fire hose standpipe system for the containment building as an acceptable variance from the requirements of NFPA 805 Section 3.6.1. Basis for Approval Request 9: On July 26. 1979. the NRC issued Amendment No. 18 to the Facility Operating License No. NFP-3 and the Fire Protection Safety Evaluation Report for DBNPS (ML021160382). The NRC has previously reviewed the DBNPS Fire Hazards Analysis and approved the absence of the fire hose standpipe system for the containment building in Section 4.4. "The major fire hazard within the containment is the reactor coolant pump (RCP) lube oil system. To prevent a fire due to oil leakage the licensee has provided an engineered oil containment and collection system for each RCP. The system has been designed to contain the oil from leakage or a pipe failure. and drains to a collection tank which is periodically emptied to assure tank capacity for the oil contained in one motor at all times while the reactor is critical. The redundant safety related cable divisions enter the containment at penetrations approximately 90&deg; from each other or 120 feet apart resulting in acceptable separation. In addition all safety related cables are installed in rigid steel conduit or covered steel wireway. The fire detection system consists of ionization tvpe detectors installed at various areas within the containment. The fire suppression system inside the containment relies on manual fire fighting operation. Portable fire extinguishers are provided. Hose stations are a/so provided just outside the containment. We have reviewed the licensee's Fire Hazard Analysis for the areas inside containment and conclude that. with the addition of the RCP oil collection system. appropriate fire protection is provided for this area. The fire protection meets the guidelines of Appendix A of BTP ASB 9.5-1. and is therefore acceptable." The basis for the previous approval has changed due to modification of the ionization type detectors to photoelectric-type smoke and heat detectors and are functionally equivalent for this application. The remaining basis remains the same. The photoelectric-type smoke detectors and heat detectors are more reliable than the original ionization fire detectors which were susceptible to erroneous indications and damage from the high neutron flux. temperatures. and humidity exposure during normal power operation inside containment. The low quantity of combustibles in the containment fire compartment has not changed significantly. Reactor coolant pumps lube oil is still the major combustible in containment. In addition. the reactor coolant pumps are provided with a seismically-designed lube oil collection system that will contain the oil from leakage and drains to collection tanks. Any lube oil overflow from the oil collection tanks will drain to the containment sump. The early warning fire Davis-Besse Page L-39 ILIC (2) --_ __J FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval detection system is installed at various areas within the containment. The fire I uc 12i suppression strategy inside the containment still relies on manual fire fighting operation. Portable fire extinguishers are provided inside of Containment during non-operating modes as stated in the previous approval. However. portable fire extinguishers are removed to the outside of Containment during reactor power operating modes due to potential containment sump clogging issues and exposure to high ambient temperatures. There are fire extinguishers readily available for fire brigade use outside containment near the containment access door in the event of a fire. Hose stations (HCR-27 and HCS-28) and additional lengths of fire hose and low pressure nozzles are available just outside of containment near the personnel hatch. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The lack of fire hose standpipe system for the containment building does not affect nuclear safety due to limited combustible material in the containment building and the existence of the reactor coolant pump oil collection system. In addition. the fire detection inside of containment provides early warning of fire development and allows for fire brigade notification and response to suppress a containment fire as trained. Therefore. there is no impact on the nuclear safety performance criteria. The radiological release review was performed based on the manual fire suppression in areas containing or potentially containing radioactive materials. A fire that originates in this fire area will be contained in this fire area. This fire area is separated from Fire Areas A and AB (the East and West halves of the Annulus) by the steel pressure vessel. Based on the low combustible loading and the design of the pressure vessel. a fire will not spread from one side of the pressure vessel to the other. The radiological release evaluation concluded that due to engine.ered controls to contain both smoke and fire suppression water runoff and use of revised pre-fire plans. there is no impact on the radiological release performance criteria. Safety Margin and Defense-in-Depth: The fire brigade at Davis-Besse is trained to manually extinguish fires and have access to containment pre-fire plans. Manual fire suppression equipment is also maintained specifically for containment near the containment access point; therefore. the safety margin inherent in the analysis for the fire event has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect. control and extinguish fires that do occur. thereby limiting damage (fire detection systems. automatic fire suppression. manual fire suppression. pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers. fire rated cable. success path remains free of fire damage. recovery actions). Per NFPA 805. Section 1.2. DID is achieved when an adequate balance of each of these elements above is provided. The lack of a fire hose standpipe system in the Davis-Besse Page L-40 FE NOC Attachment L -NFPA 1!05 Chapter 3 Requirements for Approval containment building does not affect administrative controls for preventing fires from I uc(2J starting. The limiting of combustibles and a reactor coolant pump oil collection system also prevents fires from starting; therefore. echelon 1 is met. The lack of fire hose standpipe system in the containment building does not impact the ability of manual fire suppression since extinguishers are maintained readily available outside of containment near the access point during power operations and installed inside containment during outages that require normal personnel access. type smoke and heat detectors are also available in containment areas: therefore echelon 2 is met. The lack of a fire hose standpipe system in the containment building does not allow or increase its potential for fire propagation through the fire compartment's steel pressure vessel barrier. Due to low combustible loading and the design of the pressure vessel. a fire will not spread from the fire compartment. Impacts to equipment due to manual fire fighting activities are not expected to result in additional fire damage states. The plant fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire source. A fire not result in compromising essential safe shutdown functions from being performed or post-fire SSD capability; therefore echelon 3 is met. Since a balance of the elements is provided. DID is achieved. Conclusion: NRC approval is requested for the deviation from NFPA 805, Section 3.6.1 for the lack of hose standpipe system in the containment building (Fire Compartments D-01. A-06, and AB-02). Based on this review. the existing mitigating features such as fire detection. manual suppression. and oil collection system provide an equivalent level of fire protection to the containment building. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals. performance objectives. and performance criteria specified in NFPA 805 related to nuclear safety and radiological release.
* Maintains safety margins. and
* Maintains fire protection DID (fire prevention fire detection. fire suppression. mitigation. and post-fire safe and stable capability). Davis-Besse Page L-41 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approva1Reguest10 NFPA 805 Section 3.3.8 states: Bulk Storaae of Flammable and Combustible Liquids. Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems. equipment. or components important to nuclear safety. As a minimum. storage and use shall comply with NFPA 30. Flammable and Combustible Liquids Code. DBNPS is requesting approval of adequate for the hazard compliance associated with NFPA 805 Section 3.3.8 for Diesel Fuel Tank T210 inside the DBNPS Station Blackout (SBO) building. Basis for Approval Request 10: The DBNPS Station Blackout (SBO) diesel fuel tank (T210) and the associated piping complies with NFPA 30-1990. except as noted below. In the instances where tank T210 is not shown to have an installed configuration that is functionally equivalent to the reguirements of NFPA 30 Edition 1990. it is concluded that the configurations are adequate for the hazard.
* Drainage is not provided to the curbed area under Tank T210 for the removal of any sprinkler system actuation discharge, per NFPA 30 Sections 1-1.6 and 5-3.4.1. NFPA 30 Section 1-1.6: Existing plants. equipment. buildings. structures. and installations for the storage. handling. or use of flammable or combustible liquids that are not in strict compliance with the terms of this code may be continued in use at the discretion of the authority having jurisdiction provided they do not constitute a recognized hazard to life or adjoining property. The existence of a situation that might result in an explosion or sudden escalation of a fire. such as inadequate ventilation of confined spaces. Jack of adequate emergency venting of a tank. failure to fireproof the supports of elevated tanks. or Jack of drainage or dikes to control spills. may constitute such a hazard. NFPA 30 Section 5-3.4. 1: Emergency drainage systems shall be provided to direct flammable or combustible liquid leakage and fire protection water to a safe location. This may require curbs. scuppers. or special drainage systems to control the spread of fire (see 2-3. 3). (Appendix A of NFPA 15. Standard for Water Spray Fixed Systems for Fire Protection. provides information on this subject.) The existing curbing arrangement is adequate for the hazard because it captures and delays the water and oil runoff and the trained response of the fire brigade to contain any runoff. In the post event. the water/oil retained in the tank T210 pit will be pumped out and processed using normal plant available equipment and procedures.
* Emergency vent capability for Tank T210 is not met. per NFPA 30 Sections 1-1.6 and 2-5.2. Davis-Besse Page L-42 I LIC(3)
FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Reference NFPA 30 Section 1-1.6 above. NFPA 30 Section 2-5.2: Vents. Vents for tanks inside of buildings shall be as required in 2-3.4. 2-3. 5, 2-3. 6. 2. and 2-4. 5. except that emergency venting by the use of weak roof seams on tanks shall not be permitted. Automatic sprinkler systems designed in accordance with the requirements of NFPA 13. Standard for the Installation of Sprinkler Systems. may be accepted by the authority having jurisdiction as equivalent to water sprav systems for purposes of calculating the required airflow rates for emergency vents in 2-3. 5. 7. Except for tanks containing Class 1118 liquids. vents shall terminate outside the buildings. The prompt actions of the fire brigade to provide additional fire suppression which will also minimize tank T210 heat-up. This is expected to be sufficient to maintain any internal pressure increase from exceeding that of the existing vent to atmosphere; therefore. the existing vent size is adequate for the hazard.
* Self-actuated closing valves are not provided for the piping connections that are below the level of Tank T210. per NFPA 30 Section 2-5.4.3. NFPA 30 Section 2-5.4.3: Tanks for storage of Class I or Class II liquids inside buildings shall be provided with either: (a) A normally closed remotelv activated valve, (b) An automatic-closing heat-activated valve. or (c) Another approved device on each liquid transfer connection below the liquid level, except for connections used for emergency disposal. to provide for quick cutoff of flow in the event of fire in the vicinity of the tank. This function can be incorporated in the valve required in 2-5.4. 2 and. if a separate valve. shall be located adjacent to the valve required in 2-5. 4. 2. The self-actuated valves for this configuration are not needed for the following reasons: the full area automatic sprinkler system will provide adequate suppression coverage and cooling, the pipe and fittings are seismically designed. the piping is welded. and the fire brigade will provide additional manual suppression to ensure faster suppression. In addition. any maintenance issues. such as pipe or valve packing leaks would be repaired through the station's Condition Reporting system. Therefore. this configuration is adequate for the hazard. .
* The SBO Tank T210 does not have the required fire protection coating on the tank supports. per NFPA 30 Sections 2-6.2 and 2-6.3. NFPA 30 Section 2-6.2: When tanks are supported above the foundations. tank supports shall be installed on firm foundations. Supports for tanks storing Class I. Class II. or Class II/A liquids shall be of concrete. masonrv. or protected steel. Single wood timber supports (not cribbing) laid horizontally may be used for outside aboveground tanks if not more than 12 in. (0.30 m) high at their lowest point. Davis-Besse Page L-43 I LIC(3)
FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval NFPA 30 Section 2-6.3: Steel supports or exposed piling for tanks storing I uc(3J Class I. Class II. or Class II/A liquids shall be protected by materials having a fire resistance rating of not less than 2 hours. except that steel saddles need not be protected if less than 12 in. (0.30 m) high at their lowest point. At the discretion of the authority having jurisdiction. water spray protection in accordance with NFPA 15. Standard for Water Spray Fixed Systems for Fire Protection. or NFPA 13. Standard for the Installation of Sprinkler Systems. or equivalent may be used. The SBO Tank T210 does not have the required fire protection coating on the tank supports. per NFPA 30 Sections 2-6.2 and 2-6.3 since the system does not fully comply with NFPA 13 in the area below the oil tank T210. This is an acceptable arrangement because the full area automatic sprinkler coverage will aid in reducing the heat exposure to the tank supports and the judicious actions and expected response time of the fire brigade to assess and provide additional fire suppression. make it unlikely the tank supports would be exposed to sufficient heat to cause a collapse; therefore. the arrangement is considered adequate for the hazard. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The lack of NFPA 30 compliance for the T210 diesel fuel tank does not affect nuclear safety due to the automatic suppression system and the rapid fire brigade response. A fire in and/or loss of the SBO building, based on the NFPA 805 safe shutdown analysis does not affect Davis-Besse's ability to shutdown; therefore. there is no impact on the nuclear safety performance criteria. The lack of a drain in the curbed area under Tank T210 does not impact radiological release because there is no radiological material located within the SBO building and the fire brigade will direct any runoff to either the outside or to the SBO sump; therefore there is no impact on the radiological release performance criteria. Safety Margin and Defense-in-Depth: The deviations from the requirements of NFPA 30 were reviewed and the safety margin is maintained based on the low risk of a fire occurring, the mitigating automatic fire protection systems and features. and the response of the fire brigade. Therefore. the safety margin inherent in the analysis for the fire event has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect. control and extinguish fires that do occur. thereby limiting damage (fire detection systems. automatic fire suppression. manual fire suppression. pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers. fire rated cable. success path remains free of fire damage. recovery actions). Davis-Besse Page L-44 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Per NFPA 805. Section 1.2. DID is achieved when an adequate balance of each of I uc(3J these elements is provided. Echelon 1 is met through plant fire prevention procedures and is not affected by this configuration. Echelon 2 is met by maintaining automatic and manual fire suppression functions. In addition. the fire brigade is trained to rapidly respond to and extinguish fires. Echelon 3 is met since the deviations still provide an adequate level of fire protection suppression and cooling to ensure that a fire will not prevent essential safety functions from being performed. The deviations are adequate for the hazard and will not increase the likelihood of damage since the fire protective coating is intact on the structural steel except in a localized location where a joint between the top layer of protective material is not sealed. and the full area automatic sprinkler system and prompt fire brigade actions will minimize the tank heat-up. Additionally, the SBO building is in a remote area of the site such that the reliability of onsite emergency ac power sources (e.g., emergency diesel generators). the frequency of loss of offsite power. and the probable time to restore offsite power ensures that a temporary loss of the SBO Diesel Building will not result in compromising post-fire SSD capability. Since a balance of the elements is provided. DID is achieved. Conclusion: NRC approval is requested for deviations in NFPA 30 compliance in accordance with NFPA 805, Section 3.3.8. Based on the analysis above. the level of risk is acceptable and this current configuration is adequate for the hazard. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals. performance objectives. and performance criteria specified in NFPA 805 related to nuclear safety and radiological release.
* Maintains safety margins. and
* Maintains fire protection DID (fire prevention fire detection. fire suppression. mitigation. and post-fire safe and stable capability). Davis-Besse Page L-45 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approval Request 11 NFPA 805 Section 3.2.3(1) states: "Procedures shall be established for implementation of the fire protection program. In addition to procedures that could be required bv other sections of the standard. the procedures to accomplish the following shall be established: Inspection. testing. and maintenance for fire protection svstems and features credited bv the fire protection program." DBNPS requests the ability to use performance-based methods to establish the appropriate inspection. testing. and maintenance frequencies for fire protection systems and features required by NFPA 805. Performance-based inspection, testing, and maintenance frequencies will be established as described in Electric Power Research Institute (EPRI) Technical Report (TR) 1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features." FENOC requests NRC approval to use these performance-based methods as an acceptable alternative to NFPA 805 Chapter 3 requirements. Basis for Approval Request 11: NFPA 805 Section 2.6. "Monitoring," requires that "A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid." NFPA 805 Section 2.6.1. "Availability, Reliability, and Performance Levels." requires that "Acceptable levels of availability. reliabilitv. and performance shall be established." NFPA 805 Section 2.6.2 requires that "Methods to monitor avai/abilitv. reliabilitv. and performance shall be established. The methods shall consider the plant operating experience and industrv operating experience." This request does not involve the use of the EPRI TR-1006756 to establish the scope of the activities determined by the required systems review identified in Table 4.3, "NFPA 805 Chapter 4 Required FP Systems/Features." This request is specific to the use of EPRI TR-1006756 to establish the appropriate inspection, testing, and maintenance frequencies for fire protection systems and features credited by the fire protection program. As stated in EPRI TR-1006756 Section 10. 1, "The goal of a performance-based surveillance program is to adjust test and inspection frequencies commensurate with equipment performance and desired reliability." This goal is consistent with the stated requirements of NFPA 805 Section 2.6. The EPRI TR-1006756 provides an accepted guideline to establish appropriate inspection, testing, and maintenance frequencies that ensure the required NFPA 805 availability, reliability, and performance goals are maintained. Davis-Besse Page L-46 I FPE RAI 03 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval The target tests. inspections. and maintenance will be for the fire protection systems and features required by NFPA 805. The failure criterion in each case will be based on the credited functions of the required fire protection systems and features and will ensure those functions are maintained (or appropriate actions are implemented). Data collection and analysis will follow the TR-1006756 document guidance. The failure probability will be determined based on the TR-1006756 guidance. and a 95% confidence level will be used. The performance monitoring will be performed in conjunction with the monitoring program required by NFPA 805 Section 2.6, and it will ensure site-specific operating experience is considered in the monitoring process. The following flowchart identifies the basic process that will be used: Davis-Besse Page L-47 I FPE RAI 03 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Program Framework I FPE RAI 03 Identify Target Tests and Inspections Establish Reliability and Frequency Goals Set Failure Criteria Assess Licensing Impact and Other Constraints "'Ill .... Data Collection and Evaluation Establish Data Collection Guidelines Collect Required Surveillance Data Assemble Data in Spreadsheet or Database Analyze Data to Identify Failures "'Ill ,. Reliability and Uncertainty Analysis Compute Failure Probabilities Compute Uncertainty Limits Confirm That Reliability Supports Target Frequency "'Ill ,,.. Program Implementation Modify Program Documents Revise Surveillance Procedures Conduct Ongoing Performance Monitoring Refine and Modify Frequencies as Appropriate EPRI TR-1006756 -Figure 10-1 Flowchart for Performance-Based Surveillance Program Davis-Besse Page L-48.
FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: Use of performance-based test frequencies established per EPRI TR-1006756 methods combined with NFPA 805 Section 2.6, "Monitoring," will ensure that the availability and reliability of the fire protection systems and features are maintained to the levels assumed in the NFPA 805 engineering analysis. Therefore. there is no adverse impact to nuclear safety performance criteria by the use of the performance-based methods in EPRI TR-1006756. The radiological release performance criteria are satisfied in the radioactive release reviews presented in LAR. Attachment E. Use of performance-based test frequencies established per EPRI TR-1006756 methods. combined with NFPA 805 Section 2.6. "Monitoring." will ensure that the availability and reliability of the fire protection systems and features credited by the radiological release review are maintained to the levels assumed in the NFPA 805 engineering analysis. Therefore. there is no adverse impact to radioactive release performance criteria. Safety Margin and Defense-in-Depth: Use of performance-based test frequencies established per EPRI TR-1006756 methods. combined with NFPA 805 Section 2.6. "Monitoring." will ensure that the fire protection systems and features are maintained at the availability and reliability assumed in the NFPA 805 engineering analysis. The use of these methods maintains the inherent safety margins contained in the codes used for design and maintenance of fire protection systems and features. Safety margins are maintained if codes and standards are met. and safety analysis acceptance criteria in the licensing basis (e.g .. UFSAR. supporting analyses) are met or provide sufficient margin to account for analysis and data uncertainty. An adequate safety margin for each of the surveillance and maintenance frequencies evaluated in accordance with EPRI TR-1006756 methods is preserved by establishing reliability and availability
* standards for the affected equipment. The performance parameters for the evaluated fire protection systems and features are created to support nuclear performance criteria contained in the plant-specific accident analyses. These analyses established component and system performance criteria necessary to establish safe and stable plant operation. as well as safe shutdown of the unit in the event of a fire. These performance parameters were not modified as a result of this approval request. Therefore. the safety margin inherent to. and credited in. the analysis has been preserved. The three echelons of defense-in-depth are: (1) To prevent fires from starting; (2) To rapidly detect. control and extinguish fires that do occur. thereby limiting damage; (3) To provide adequate level of fire protection for systems and structures so that a fire will not prevent essential, safety functions from being performed. Per NFPA 805 Section 1.2, defense-in-depth is achieved when an adequate balance of each of these elements is provided. Davis-Besse Page L-49 I FPE RAI 03 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Echelon 1 is not affected by the use of EPRI TR-1006756 methods. Echelons 2 and 3 are I FPERA103 not affected by the use of performance-based test frequency guidance established per EPRI TR-1006756 report when combined with NFPA 805 Section 2.6. "Monitoring" requirements. This will ensure for Echelons 2 and 3 that the availability and reliability of the fire protection systems and features are maintained to the levels assumed in the NFPA 805 engineering analysis (or the analysis will be updated accordingly). Therefore. there is no adverse impact to DID for Echelons 1. 2. and 3. Conclusion: NRC approval is requested for use of the performance-based methods contained in EPRI TR-1006756 to establish the appropriate inspection. testing. and maintenance frequencies for fire protection systems and features required by NFPA 805. As described above. this approach is considered acceptable because it performs the following: (A) Satisfies the performance goals. performance objectives. and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth (fire prevention. fire detection. fire suppression, fire mitigation. and post-fire nuclear safety capability). Davis-Besse Page L-50 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approva1Reguest12 NFPA 805 Section 3.3.8 states: Bulk Storage of Flammable and Combustible Liquids. Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems. equipment. or components important to nuclear safety. As a minimum. storage and use shall comply with NFPA 30. Flammable and Combustible Liquids Code. DBNPS is requesting approval of adequate for the hazard compliance associated with NFPA 805 Section 3.3.8 for the Lube Oil Storage Tank. Basis for Approval Request 12: The DBNPS Lube Oil Storage Tank complies with NFPA 30-1973. except as noted below. In the instances where the Lube Oil Storage Tank is not shown to have an installed configuration that is functionally equivalent to the requirements of NFPA 30 Edition 1973, it is concluded that the configurations are adequate for the hazard.
* The Lube Oil Storage Tank (T32) is not provided with an automatic closing heat actuated valve on each withdrawal connection below the liquid level. per NFPA 30-1973. Section 2343. NFPA 30 Section 2343: Flammable or combustible liquid storage tanks located inside of buildings. except in one-storv buildings designed and protected for flammable or combustible liquid storage. shall be provided with an automatic-closing heat-actuated valve on each withdrawal connection below the liquid level. except for connections used for emergency disposal. to prevent continued flow in the event of fire in the vicinity of the tank. This function may be incorporated in the valve required in 2342. and if a separate valve. shall be located adjacent to the valve required in 2342. The deviation from having installed. automatic closing, heat-actuated valves for this configuration is acceptable for the following reasons: the full area automatic sprinkler system will provide adequate suppression coverage and cooling: the piping and fittings are seismically designed; the tank is enclosed in a room with 3-hour fire-rated barriers; and manual suppression is available from the fire brigade. In addition. leaks identified during regular operator rounds are entered into the Condition Reporting system for repair. Therefore. this configuration is adequate for the hazard. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The NFPA 30 deviations for the Lube Oil Storage Tank does not affect nuclear safety due to the automatic suppression system and the rapid fire brigade response. A fire in and/or loss of the Lube Oil Storage Tank would not affect any safe shutdown trains based on the NFPA 805 safe shutdown analysis. and does not affect Davis-Besse's Davis-Besse Page L-51 I LIC(4)
FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval ability to safely shutdown; therefore. there is no impact on the nuclear safety I uc(4l performance criteria. The Lube Oil Storage Tank does not impact radiological release because there is no radiological material located within the Turbine Lube Oil Storage Tank Room and the fire brigade monitors effluents for contamination; therefore there is no impact on the radiological release performance criteria. Safety Margin and Defense-in-Depth: The deviations from the requirements of NFPA 30 were reviewed and the safety margin is maintained based on the low risk of a fire occurring. the mitigating automatic fire protection systems and features. and the response of the fire brigade. Therefore. the safety margin inherent in the analysis for the fire event has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect. control and extinguish fires that do occur. thereby limiting , damage (fire detection systems. automatic fire suppression. manual fire suppression. pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers. fire rated cable. success path remains free of fire damage. recovery actions). Per NFPA 805, Section 1.2. DID is achieved when an adequate balance of each of these elements is provided. Echelon 1 is met through plant fire prevention procedures and is not affected by this configuration. Echelon 2 is met by maintaining automatic sprinkler system and manual suppression. In addition. the fire brigade is trained to.rapidly respond to and extinguish fires. Echelon 3 is met since there are 3-hour fire-rate barriers. an adequate level of automatic and manual fire suppression is provided. and a fire will not prevent essential safety functions from being performed. Since a balance of the elements is provided. DID is achieved. Conclusion: NRC approval is requested for deviations in NFPA 30 compliance in accordance with NFPA 805, Section 3.3.8. Based on the analysis above, the level of risk is acceptable and this current configuration is adequate for the hazard. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals. performance objectives. and performance criteria specified in NFPA 805 related to nuclear safety and radiological release.
* Maintains safety margins. and
* Maintains fire protection DID (fire prevention fire detection. fire suppression. mitigation. and post-fire safe and stable capability). Davis-Besse Page L-52 _J FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approval Request 13 NFPA 805 Section 3.3.8 states: Bulk Storage of Flammable and Combustible Liquids. Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems. equipment. or components important to nuclear safety. As a minimum. storage and use shall comply with NFPA 30. Flammable and Combustible Liquids Code. DBNPS is requesting approval of adequate for the hazard compliance associated with NFPA 805 Section 3.3.8 for the Emergency Diesel Generator (EOG) Fuel Oil Day Tanks in the Auxiliary Building. Basis for Approval Request 13: The DBNPS Emergency Diesel Generator (EOG) Fuel Oil Day Tanks (T46-1 and T46-2) comply with NFPA 30-1973. except as noted below. In the instances where the EOG Fuel Oil Day Tanks are not shown to have an installed configuration that is functionally equivalent to the requirements of NFPA 30 Edition 1973. it is concluded that the configurations are adequate for the hazard.
* The EOG Fuel Oil Day Tanks deviate from the requirements of NFPA 30-1973. Section 2343 since each of the two connections below the liquid level are not provided with an automatic closing heat actuated valve. NFPA 30 Section 2343: Flammable or combustible liquid storage tanks located inside of buildings. except in one-storv buildings designed and protected for flammable or combustible liquid storage. shall be provided with an automatic-closing heat-actuated valve on each withdrawal connection below the liquid level. except for connections used for emergency disposal. to prevent continued flow in the event of fire in the vicinity of the tank. This function may be incorporated in the valve required in 2342. and if a separate valve. shall be located adjacent to the valve required in 2342. The deviation from having installed. automatic closing, heat-actuated valves for this configuration is adequate for the hazard for the following reasons: there are no NUREG-6850 fixed ignition sources; the automatic sprinkler system will provide adequate suppression coverage for cooling to the hot gas layer and will provide effective cooling to the exposed oil liquid surfaces around the perimeter of the tank and the exposed top portion of the tank; the enclosed tank rooms are located in separate 3-hour fire-rated fire compartments; the piping below the liquid level is seismically constructed and therefore are of a rugged design: and manual suppression is available from the fire brigade. In addition. leaks identified during regular operator rounds are entered into the Condition Reporting system for repair. Therefore. this configuration is adequate for the hazard.
* The EOG Fuel Oil Day Tanks (T46-1 and T46-2) deviate from the emergency venting requirements .. per NFPA 30-1973. Section 2154. The two tanks are Davis-Besse Page L-53 I LIC(S)
FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval located in separate 3-hour fire-rated fire compartments. The EDG tanks I uc(s) require an approximately 95. 700 standard cubic feet per hour (SCFH) emergency vent with credit for the installed sprinkler system. The installation of the flame arrestor in the vent restricts the flow to approximately 38.000 SCFH. NFPA 30 Section 2154: Where entire dependence for emergency relief is placed upon pressure relieving devices. the total venting capacity of both normal and emergency vents shall be enough to prevent rupture of the shell or bottom of the tank if vertical. or of the shell or heads if horizontal. If unstable liquids are stored. the effects of heat or gas resulting from polymerization. decomposition. condensation. or self-reactivity shall be taken into account. The total capacitv of both normal and emergency venting devices shall be not Jess than that derived from Table 11-7 except as provided in 2156 or 2157. Such device maybe se/fc/osing manhole cover. or one using Jong bolts that permit the cover to Jiff under internal pressure. or an additional or larger relief valve or valves. The wetted area of the tank shall be calculated on the basis of 55 per cent of the total exposed area of a sphere or spheroid. 75 per cent of the total exposed area of a horizontal tank and the first 30 feet abovegrade of the exposed shell area of a vertical tank. See Appendix A for the square footage of tvpical tank sizes. The deviation from emergency venting requirements for this configuration is adequate for the hazard for the following reasons: the presence of an automatic sprinkler system; the enclosed tank rooms are located in separate 3-hour fire-rated fire compartments; the piping and fittings are seismically designed: in the unlikely event of a condition resulting in a Day Tank rupture. the contents would be contained within the room: a liquid release of oil, if the oil ignites. would actuate a sprinkler system discharge. The sprinkler discharge and oil leakage would raise the exposed liquid level in the room rapidly to the bottom of the tank because the tank is supported very close to the floor and then the tank's presence would cause any further increase in level to decrease the exposed surface area of any potential ignited pool fire because the tank area makes up a very large ratio of the room area (approximately 60% at the midpoint height of the tank). Therefore. the sprinkler system will provide cooling to the hot gas layer while also providing cooling to the exposed portion of the top of the day tank and oil pool surrounding the perimeter of the day tank. In addition. manual suppression is available from the fire brigade. Since both tanks are electrically grounded. it is not expected that any static charge would develop to initiate a fire inside the tank from the vapor. Leaks identified during regular operator rounds are entered into the Condition Reporting system for repair. Therefore. this configuration is adequate for the hazard. Davis-Besse Page L-54 _j FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The NFPA 30 deviations for the EDG Fuel Oil Day Tanks do not affect nuclear safety due to fire rated separation of each of the EDG Fuel Oil Day Tank rooms. the automatic suppression system and the rapid fire brigade response. A fire in and/or loss of an EDG Fuel Oil Day Tank would not affect the safe shutdown capabilities of the redundant train since the tank contents would be contained within the fire compartment containing the tank. and prevent fire migration to other areas. The loss of an EDG Fuel Oil Day Tank would only affect one safe shutdown train and based on the NFPA 805 safe shutdown analysis. does not affect Davis-Besse's ability to safely shutdown: therefore. there is no impact on the nuclear safety performance criteria. The EDG Fuel Oil Day Tanks do not impact radiological release because there is no radiological material located within the EDG area of the Auxiliary Building and the fire brigade will direct water runoff appropriately; therefore there is no impact on the radiological release performance criteria. Safety Margin and Defense-in-Depth: The deviations from the requirements of NFPA 30 were reviewed and the safety margin is maintained based on the low risk of a fire occurring, the mitigating automatic fire protection systems and features. and the response of the fire brigade. Therefore. the safety margin inherent in the analysis for the fire event has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect. control and extinguish fires that do occur. thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression. pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers. fire rated cable, success path remains free of fire damage. recovery actions). Per NFPA 805, Section 1.2, DID is achieved when an adequate balance of each of these elements is provided. Echelon 1 is met through plant fire prevention procedures and is not affected by this configuration. Echelon 2 is met by maintaining automatic sprinkler system and manual suppression. In addition. the fire brigade is trained to rapidly respond to and extinguish fires. Echelon 3 is met since each EDG Fuel Oil Day Tank fire compartment is enclosed in 3-hour fire-rate barriers. an adequate level of automatic and manual fire suppression is provided, and in the unlikely event of a condition resulting in inadequate emergency vent capacity that results in the EDG Fuel Oil Day Tank becoming over-pressurized and ruptured. the contents would be contained within the fire compartment containing the Davis-Besse Page L-55 ILIC (5) )
FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval affected EOG Day Tank. A fire will not prevent essential safety functions from being I uc(s) performed since only one safe shutdown train would be affected. ...___ __ _. Since a balance of the elements is provided. DID is achieved. Conclusion: NRC approval is requested for deviations in NFPA 30 compliance in accordance with NFPA 805. Section 3.3.8. Based on the analysis above. the level of risk is acceptable and this current configuration is adequate for the hazard. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals. performance objectives. and performance criteria specified in NFPA 805 related to nuclear safety and radiological release.
* Maintains safety margins. and
* Maintains fire protection DID (fire prevention fire detection. fire suppression. mitigation. and post-fire safe and stable capability). Davis-Besse Page L-56 
----------------------,------------------------FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Approval Request 14 NFPA 805 Section 3.3.8 states: Bulk Storage of Flammable and Combustible Liquids. Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing svstems. equipment. or components important to nuclear safetv. As a minimum. storage and use shall comply with NFPA 30. Flammable and Combustible Liquids Code.
* DBNPS is requesting approval of adequate for the hazard compliance associated with NFPA 805 Section 3.3.8 for the Emergency Feedwater Facility (EFWF). Basis for Approval Request 14: The DBNPS Emergency Feedwater Facility (EFWF) complies with NFPA 30-2015. except as noted below. In the instances where EFWF is not shown to have an installed configuration that is functionally equivalent to the requirements of NFPA 30 Edition 2015. it is concluded that the configurations are adequate for the hazard.
* The EFWF deviates from the prompt notification requirement in the event of a fire. per NFPA 30 Section 6.6.1. NFPA 30 Section 6.6.1: An approved means for prompt notification offire or emergency to those within the plant and to the available public or mutual aid fire department shall be provided. The deviation of prompt notification in the event of a fire is adequate for the hazard for the following reasons: the EFWF Room 461 which houses Tank T145 and the EFWF external barriers are of robust and fire resistant construction that is expected to contain the effects of a fire: Tank T157 located in Room 260 is manufactured with double wall construction which protects the tank from physical damage and limits heat transferred to the internal primary tank when exposed to an external fire: the top side oil transfer connections make a diesel fuel oil spill highly unlikely; manual suppression is available by the fire brigade; and leaks identified during regular operator rounds are entered into the Condition Reporting system for repair. In addition. fire damage to the EFWF does not affect either train of the safe shutdown capabilities within the remaining areas of the plant. Therefore. the absence of a prompt notification for a fire in the EFWF is considered adequate for the hazard.
* The EFWF Diesel Fuel Oil Storage Tank T145. located in Room 461. deviates from the required construction and fire protection for its steel tank supports. per NFPA 30 Sections 22.5.2.3 and 22.5.2.4. NFPA 30 Section 22.5.2.3: Where tanks storing Class I. Class II. or Class II/A liquids are supported above their foundations. tank supports shall be of concrete. masonrv. or protected steel. Exception: Single wood timber supports (not cribbing). laid horizontally. shall be permitted to be used for outside aboveground tanks if not more than 12 in. (300 mm) high at their lowest point. Davis-Besse Page L-57 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval NFPA 30 Section 22.5.2.4: Steel support structures or exposed piling for I uc(sJ tanks storing Class I. Class II. or Class II/A liquids shall be protected by materials having a fire resistance rating of not less than 2 hours. Exception No. 1: Steel saddles do not need to be protected if less than 12 in. (300 mm) high at their lowest point. Exception No. 2: At the discretion of the authority having jurisdiction. water spray protection in accordance with NFPA 15. Standard for Water Spray Fixed Systems for Fire Protection. or NFPA 13. Standard for the Installation of Sprinkler Systems. is permitted to be used. The deviation from the fire resistive requirements for the Tank T145 supports are adequate for hazard for the following reasons: Tank T145 supports are seismically designed and therefore are of additional rugged steel construction; the postulated pool fire is confined due to the oil containment provided by the room and the robust and fire resistive design of the building; manual suppression is available by the fire brigade; transient combustibles are controlled per plant procedure; the tank room is in a location without significant ignition sources; and operator rounds identified leaks are entered into the Condition Reporting system for repair. In addition. damage to the Tank T145 from a fire does not affect either safe shutdown trains or safe shutdown capabilities within the remaining areas of the plant. Therefore. the arrangement of the EFWF diesel fuel oil tank T145 supports is considered adequate for the hazard.
* The Tank T145 emergency vent piping is directly routed outside of the tank room and out of the building through the roof; however. the vent piping capability is not sized to meet the NFPA 30 Section 22.7.3.2 emergency venting flow requirements. A flame arrestor is installed at the vent discharge to atmosphere that further restricts any effluent discharge. NFPA 30 Section 22. 7.3.2: Except as provided for in 22. 7.3.5. 22. 7.3.6 and 22. 7. 3. 7. the total emergency relief venting capacity of both normal and emergency venting devices shall be not less than that determined in Table 22. 7.3.2. (See Annex B for the square footage of typical tank sizes.) NFPA 30 Section 22. 7.3.2. 1: Emergency relief vent devices shall be vaportight and shall be permitted to be any one of the following: (1) Self-closing manway cover (2) Manway cover provided with long bolts that permit the cover to lift under internal pressure (3) Additional or larger relief valve or valves NFPA 30 Section 22. 7. 3. 2. 2: The wetted area of the tank shall be calculated as follows: (1) Fifty-five percent of the total exposed area of a sphere or spheroid (2) Seventy-five percent of the total exposed area of a horizontal tank Davis-Besse Page L-58 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval (3) One hundred percent of the exposed shell and floor area of a rectangular tank. but excluding the top surface of the tank (4) The first 30 ft (9 m) above grade of the exposed shell area of a vertical tank The deviation of the emergency vent capability for Tank T145 are adequate for the hazards for the following reasons: the walls. floor. and ceiling are of robust 3-hour fire-rated construction; the tank is separated from other ignition sources outside the tank room; the tank is electrical grounded which reduces the likelihood of vapor ignition inside the tank: manual suppression is available by the fire brigade; and leaks identified during regular operator rounds are entered into the Condition Reporting system for repair. In addition. damage to the T145 tank from a fire does not affect either safe shutdown trains or safe shutdown capabilities within the remaining areas of the plant. Therefore. the existing flame arrestor and vent are considered adequate for the hazard.
* Class II liquid transfer connections in the EFWF on Tank T145 are not provided with remotely activated or heat-activated valves or other approved device. per NFPA 30 Section 24.14.3. NFPA 30 Section 24.14.3: Vents. Each liquid transfer connection on anv tank storing Class I or Class I/ liquids inside buildings shall be provided with one of the following: (1) A normally closed, remotely activated valve (2) An automatic-closing. heat-activated valve (3) Another approved device The deviation from remotely activated or heat-activated valves for the Class II liquid transfer connections on Tank T145 is adequate for the hazard for the following reasons: the tank is spatially separated from other hazards in the EFWF and means of controlling the flow of Class II liquid is provided; the piping and fittings are seismically designed; manual suppression is available by the fire brigade; piping and tubing are well maintained; and leaks identified during regular operator rounds are entered into the Condition Reporting system for repair. In addition. damage to the T145 tank from a fire does not affect either safe shutdown trains or safe shutdown capabilities within the remaining areas of the plant. Therefore. the liquid transfer connections below the liquid level for Tank T145 that do not have remotely activated or activated valves or other approved devices installed are considered adequate for the hazard. Acceptance Criteria Evaluation: Nuclear Safety and Radiological Release Performance Criteria: The NFPA 30 deviation for the EFWF Diesel Fuel Oil Storage Tank T145 does not affect nuclear safety since the EFWF is non-safety related and it has spatial separation from the other operating areas of the plant. In the event of a fire in the Auxiliary Davis-Besse Page L-59 I LIC(6)
FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval Building. the availability of a diversely powered. automatically initiated auxiliary I uc(6J feedwater supply located in the EFWF would significantly reduce the likelihood of core damage: however. the loss of the EFWF equipment from a fire does not affect the normal or emergency shutdown capabilities used in plant systems. structures. and components.
* The EFWF Diesel Fuel Oil Storage Tank T145 does not impact radiological release because there is no radiological material located within the EFWF building and the fire brigade will direct water runoff appropriately; therefore there is no impact on the radiological release performance criteria. Safety Margin and Defense-in-Depth: The deviations from the requirements of NFPA 30 were reviewed and the safety margin is maintained based on the low risk of a fire occurring, the separation from the other operating areas of the plant. and the response of the fire brigade. Therefore. the safety margin inherent in the analysis for the fire event has been preserved. The three echelons of DID are: (1) To prevent fires from starting (combustible/hot work controls). (2) Rapidly detect. control and extinguish fires that do occur. thereby limiting damage (fire detection systems. automatic fire suppression. manual fire suppression. pre-fire plans). (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers. fire rated cable. success path remains free of fire damage, recovery actions). Per NFPA 805. Section 1.2. DID is achieved when an adequate balance of each of these elements is provided. Echelon 1 is met through plant fire prevention procedures and since the EFWF building design is hardened to resist both tornado missiles and design basis earthquakes. the construction is non-combustible and fire resistant. Echelon 2 is met by manual suppression. In addition. the fire brigade is trained to rapidly respond to and extinguish fires. Echelon 3 is met since there are 3-hour fire-rated barriers and an adequate level of manual fire suppression is provided. Damage to Tank T145 from a fire does not affect either train of the safe shutdown capabilities within the remaining areas of the plant. Since a balance of the elements is provided. DID is achieved. Conclusion: NRG approval is requested for deviations in NFPA 30 compliance in accordance with NFPA 805. Section 3.3.8. Based on the analysis above. the level of risk is acceptable and this current configuration is adequate for the hazard. DBNPS determined that the performance-based approach satisfies the following criteria:
* Satisfies the performance goals. performance objectives. and performance criteria specified in NFPA 805 related to nuclear safety and radiological release. Davis-Besse Page L-60 FE NOC Attachment L -NFPA 805 Chapter 3 Requirements for Approval
* Maintains safety margins. and
* Maintains fire protection DID (fire prevention fire detection. fire suppression. mitigation. and post-fire safe and stable capability) Davis-Besse Page L-61 I LIC(6) 
 
==Enclosure==
C L-17-253 LAR Attachment S -Modifications and Implementation Items (6 pages follow)
FENOC s. Davis-Besse Attachment S -Modifications and Implementation Items Modifications and Implementation Items 5 Pages Attached Page S-1 FE NOC Attachment S -Modifications anct Implementation Items Table S-1, Plant Modifications Committed, provided below, include a description of the modifications along with the following information:
* Risk ranking of the modification,
* A problem statement,
* A description of the proposed modification,
* An indication if the modification is currently included in the FPRA,
* A statement if compensatory measure is in place; and
* A risk-informed characterization of the modification and compensatory measure.
* The following legend should be used when reviewing the tables: o High = Modification would have an appreciable impact on reducing overall fire CDF. o Medium= Modification would have a measurable impact on reducing overall fire CDF. o Low= Modification would have either an insignificant or no impact on reducing overall fire CDF. Item Rank DB-1421 H DB-2061 L Davis-Besse Problem Statement Fire damage could result in loss of both steam driven auxiliary feedwater pumps. This could challenge the NSPC for decay heat removal. The CCW pumps have less than 20 feet of separation with no intervening combustibles. A fire affecting one CCW pump could potentially damage all CCW pumps. Table S-1 Plant Modifications Committed Proposed Modification ECP 13-0195 installs the emergency water storage tank and facility. This provides emergency power sources and makeup water. ECP 13-0196 installs the diesel-driven emergency feedwater pump and auxiliary equipment. If the FRE determines a modification is required, then the specifications of the modification will be developed and implemented. In FPRA Yes Yes Comp Measure No No Risk Informed Characterization This modification provides an alternate source of feedwater by providing a diesel-driven power source and expanded emergency water storage. Any required modification will ensure availability of required RCP seal cooling in the event of a fire in T-01. Page S-2 FE NOC Attachment S -Modifications and Implementation Items Table S-2, Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 fire protection program. Item DB-0341 DB-0538 DB-0540 DB-0779 DB-1074 DB-1093 DB-1095 DB-1838 DB-1900 DB-1912 DB-2041 DB-0463 DB-0492 DB-0525 DB-1058 DB-0541 DB-0557 DB-0572 DB-0573 DB-0600 DB-0582 DB-0759 DB-1147 DB-1744 DB-1949 Davis-Besse Table S-2 Implementation Items Description Revise Pre-Fire Plans and Associated Training Modules to Include Action for Radioactive Release Scenarios; Review Pre-Fire Plans Against Safe Shutdown Analysis and Revise as Necessary; Revise Pre-Fire Plans to Include Rooms 330, 317A, 605, and 417A; Develop Pre-Fire Plan for Potential Radioactive Release Areas Update DB-OP-02501 to Reference Ammeters for Runout Detection Generate an Inspection Procedure for the Ceramic Fiber used in Trays Revise DB-FP-00007 for Combustible and Transient Loading Program Requirements and to Include Duration Limits Based on Fire Modeling Revise Fire Brigade Policies and Practices Based on the NFPA 600 Code Review Revise Fire Brigade Drills to Include Areas Essential to Plant Operation, Safe Shutdown Areas, and to Control Radioactive Release Revise Affected Procedures to Include Credited NFPA 805 Fire Protection Equipment Revise Performance-Based Inspection Requirements to Include NFPA 805 Credited Fire Protection Equipment Assess Current Transformer Fire Effects Due to Open Secondary Circuits. Revise Control Room Fire Alarm Response Procedure DB-OP-02529 Develop a Monitoring Program as Required by NFPA 805 LAR Section/Source Attachment E and Attachment A 1, Sections 3.4.3(a), 3.4.2, and 3.4.2.1 FPE RAI 01 SSA RAI 01 Attachment C Attachment V Attachment A 1, Sections 3.3.1.2 and 3.3.1.2(4) Attachment A 1, Sections 3.4.1 (a}, 3.4.3(a}, and 3.4.4 Attachment A 1, Sections 3.4.3(b) and 3.4.3(c) Attachment A 1, Section 3.2.3(2) Attachment A 1, Sections 3.11.1 and 3.2.3(1) Attachment B, NEI Section 3.5.2.1 Attachment A 1, Section 3.4.1 (d) 4.6.2, Attachment E, and Attachment V PageS-3 FE NOC Attachment S -Modifications and Implementation Items Item DB-1591 DB-1603 DB-1695 DB-1696 DB-2013 DB-2014 DB-1810 DB-1812 DB-1825 DB-1878 DB-1908 DB-1915 DB-1941 DB-1943 DB-1964 DB-1988 DB-2005 DB-2015 DB-2020 Table S-2 Implementation Items Description Revise Documents to Include Fire Protection Water System Connections Review of MOVs for Crediting CPT Revise PRA for Plant Modifications Update the Ignition Frequency Calculation and Fire Modeling for the following: Implementation of the DAFW System and FLEX, Add the Satellite phone Equipment That Will be Added to the EFWF and MGR per ECP-14-0465; Evaluate for Impacts on the Implementation of NFPA 805E for CP 14-0646 that Adds New Sound Powered Phone Equipment Revise Interior Finish Procurement Specifications to Include Radiant Heat Flux Revise Procedures to Trip RCPs During a Serious Fire Event Revise DBNPS EEEEs including NPE-98-00081 or its replacement (to remove credit for sprinklers) Verification of Fire Damper Rating Revise Procedures and Conduct Training to Implement NPO Requirements for NFPA 805 Revise Pre-Fire Plans and Training Materials to Address Radioactive Release Revise Procedures Including Fire Brigade Training and Drills to Incorporate Recovery Actions Review and Revise Fire PRA Human Reliability Analysis Upon Completion of Procedure Updates, Modifications, and Training Revise Cable Specifications Update SAFE to Document ECP 13-0406 Fuse Protection for DB Ammeters Perform NFPA 58 Code Review of the Permanent Propane Tanks Installation Revise the Level 1 Failure Reports to Reflect Where Normal Control Power is Available Resolve the Non-enclosed Power Wiring for the Emergency Backup Lighting in Fire Compartment CC-01 Davis-Besse LAR Section/Source Attachment A 1, Section 3.5.16 Attachment V Attachment V Attachment V Attachment A 1, Section 3.3.3 Attachment C 4.2.2 FPE RAI 01 FPE RAI 06 Attachment A2, Fire Compartment 11-04 Attachment D Attachment E Attachment G Attachment G Attachment A 1, Sections 3.3.5.1 and 3.3.5.3 FPE RAI 01 Attachment C Attachment A1, Section 3.3.7.1 Attachment C and Attachment V Attachment A 1, Section 3.3.5.1 PageS-4 FE NOC Attachment S -Modifications and Implementation Items Item DB-2029 DB-2031 DB-2035 DB-2036 DB-2037 DB-2049 DB-2050 DB-2053 DB-2054 DB-2055 DB-2056 DB-2057 DB-2062 DB-2063 Table 5-2 Implementation Items Description Create Analysis Assessment to create the Data Set and Testing Criteria due to Modification of EFWand FLEX Update documentation due to addition of power converters for the Auxiliary Feedwater and Motor Driven Feedwater target rock valves Update documentation such as SAFE for Containment Spray Modifications and Instrumentation Develop Fire Modeling Qualification Guides and Procedures Develop the DBNPS NFPA 805 Design Basis Document Develop New NFPA 805 Control Procedures and Processes The NFPA 20 Code of Record Compliance Review will be updated to be in the format of an EEEE. The NFPA 1 O Code of Record Compliance Review will be updated to be in the format of an EEEE. The NFPA 72E Code of Record Compliance Review will be updated to be in the format of an EEEE. The NFPA 13 and NFPA 15 Code of Record Compliance Review will be updated to be in the format of an EEEE. The NFPA 80 and NFPA 90A Code of Record Compliance Review will be updated to be in the format of an EEEE. Update the Conduct of Operations procedure to provide clarification required for fire brigade qualifications necessary to meet NFPA 805 Section 3.4.1 (c) Perform a review of the performance-based methods described in EPRI TR-1006756 for establishing the appropriate frequencies for inspection, testing, and maintenance procedures, and adjust the site program to address and differences identified. Davis-Besse LAR Section/Source Attachment V Attachment C and Attachment V Attachment C Attachment V 4.7.1 FPE RAI 01 4.7.2 FPE RAI 01 Attachment A 1, Section 3.5.3 FPE RAI 05 Attachment A 1, Section 3. 7 FPE RAI 05 Attachment A 1, Section 3.8.2 FPE RAI 05 Attachment A 1, Section 3.9.1 FPE RAI 05 Attachment A 1, Section 3.11.3 FPE RAI 05 Attachment A 1, Section 3.4.1 (c) FPE RAI 02 Attachment A 1, Section 3.2.3(1 ); Attachment L FPE RAI 03 PageS-5 FE NOC Attachment S -Modifications and Implementation Items Table S-3, Plant Modifications Completed, provided below, include a description of the modifications along with the following information:
* Risk ranking of the modification,
* A problem statement,
* A description of the proposed modification,
* An indication if the modification is currently included in the FPRA,
* A statement if compensatory measure is in place; and
* A risk-informed characterization of the modification and compensatory measure. '
* The following legend should be used when reviewing the tables: o High= Modification would have an appreciable impact on reducing overall fire CDF. o Medium= Modification would have a measurable impact on reducing overall fire CDF. o Low= Modification would have either an insignificant or no impact on reducing overall fire GDF. Item Rank DB-1983 H DB-2010 H Davis-Besse Problem Statement FLEX RCS Charging Modification Install Oil Containment Systems Table S-3 Plant Modifications Completed Proposed Modification ECP 13-0463 adds the FLEX RCS Makeup and Boration System. This includes the two FLEX RCS charging pumps that are credited in the fire PRA model. Install oil containment systems for the unit sub transformers in compartments X-01 and Y-01. In FPRA Yes Yes Comp Measure No No Risk Informed Characterization This modification will help mitigate RCP seal LOCAs should seal cooling and seal injection or seal return be lost through the use of 2 FLEX RCS charging pumps. The oil collection system is currently credited in the FPRA and is used to help prevent the creation of a hot gas layer in fire compartments X-01 and Y-01 Page S-6 _j 
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