ML20236X833

Application for Amend to License NPF-3,revising Tech Specs Re Fire Protection

ML20236X833
Person / Time
Site:	Davis Besse
Issue date:	12/07/1987
From:	Shelton D TOLEDO EDISON CO.
To:
Shared Package
ML20236X823	List: ML20236X822 ML20236X833 ML20236X859
References
1446, TAC-65361, NUDOCS 8712100304
Download: ML20236X833 (13)

Text

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Docket No. 50-346 License No. NPF-3 Serial 1446 Enclosure APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Enclosed are requested changes to the Davis-Besse Nuclear Power Station, Unit No. 1, Facility Operating License No. NPF-3. Also included are the Safety Evaluation and Significant Hazards Consideration.

The proposed changes (submitted under cover letter Serial No. 1446) concern:

Index, 3/4.7.10, Fire Barriers; Index, Bases, 3/4.7.10, Fire Barriers; Section 3/4.7, Plant Systems, Specification 3/4.7.10, Fire Barriers; Bases, Section 3/4.7.10, Fire Barriers; Section 6.4, Training; and Section 6.9, Reporting Requirements, Specification 6.9.2, Special Reports.

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By l

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D. C. Shelton, Vice President, Nuclear I

l Sworn to and subscribed before me this 7th day of December, 1987. -

Y fl? l!

NotarpPublic, State of Ohio My commission erpires /J [

8712100304 871207 PDR ADOCK 05000346 P PDR

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Docket No. 50-346.

License No. NPF-3 Serial 1446 Enclosure The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License No NPF-3,. Appendix A, Technical Specifications: 3/4.7.10, Bases l Section 3/4.7.10, Section 6.4 and Section 6.9.

A. Time required to implement: This change is to be effective within 30 days after issuance of the License Amendment.

B. Reason for change (Facility Change Request No. 84-0084B): Revise Technical Specifications related to Fire Protection Barriers in order to reflect the current plant design, testing and compensatory measures considered to be adequate and practical.

C. Description of Changes: See attached Detailed Description of Changes (Attachment 1).

D. Safety Evaluation: See attached Safety Evaluation (Attachment 2).

E. Significant Hazards Consideration: See attached Significant Hazards Consideration (Attachment 3).

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. Docket No. 50-346 License No. NPF-3 Seric1.1446

' Attachment 1 Page 1 DESCRIPTION OF THE PROPOSED TECHNICAL SPECIFICATION REVISIONS (References to the existing Specifications are in parenthesis)

INDEX - FIRE PROTECTION

'Index, Page vii, 3/4.7.10 Revised title from Penetration Fire Barriers to Fire Barriers.

Index, Page xii, Revised title from Penetration Fire Barriers Bases 3/4.7.10 to Fire Barriers 3/4.7.9.10 (Pages 3/4 7-47 through 3/4 7-48) - FIRE BARRIERS Title Revised from " Fire Barrier Penetrations" to " Fire Barriers."

3.7.10 Revised to clarify the equipment protected by the fire (3.7.10) barrier and to increase the barriers addressed by the Technical Specification.

ACTION a: Reformatted for clarity and to delete the reporting (ACTION a) requirements.

SURVEILLANCE REQUIREMENTS 4.7.10 Revised to include sealing devices.

(4.7.10) 4.7.10.a Revised to clarify the scope of the visual inspection (4.7.10.a) of certain fire barriers.

4.7.10.b Revised to clarify the scope of the visual inspection (4.7.10.a) of fire doors and dampers.

Footnote Added this footnote to exempt certain barriers from (None) the visual inspection due to ALhRA considerations.

4.7.10.c Revised to clarify the scope of the visual inspection (4.7.10.a) of sealed penetrations; added the requirement to continue the inspection for an additional barrier ,

sample; and limited the scope of the inspection to 10  !

percent of the penetrations each surveillance interval.

4.7.10.d Added this requirement to verify every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that (None) unlocked fire doors are closed and that fire doors I

with automatic hold-open and release mechanisms are free from obstructions.

Docket No. 50-346 License No. NPF-3

'Seriel 1446 Attatament 1 Page 2 4.7.10.e Added to verify that each locked fire door is closed and (None) locked every seven days.

4.7.10.f Added to perform every 18 months a functional test of the (None) automatic hold-open and release mechanisms and the latch and closing mechanisms.

Deletion Deleted the redundant requirement to perform a visual )

(4.7.10.b) inspection of a penetration fire barrier prior to returning the barrier to operable since any component addressed by a surveillance requirement, not just fire barriers, can only be returned to operability by performance of the surveillance requirement in accordance with 4.0.4 (see basis).

BASES 3/4.7.10 (Page 3/4 7-6 through B 3/4 7-7) - FIRE BARRIERS Title Revised from Penetration Fire Barriers to Fire Barriers 1st Paragraph Revised the words " penetration fire barriers" to " fire barrier"; revised the words " adjacent portions of the facility" to a) adjacent fire areas containing Nuclear Safety-related equipment, b) adjacent fire areas containing safe shutdown equipment required in the event of a fire or c) to portions of redundant safe shutdown systems required in the event of a fire within the fire area"; and revised the words " involving several areas of the facility" to

" involving several fire areas of the facility".

2nd Paragraph Added a statement that the visual inspection is a verifi-cation of the as-designed condition. An additional statement was added to clarify the basis for the as-designed condition.

3rd Paragraph Deleted statement regarding the compensatory measures to be taken with an inoperable barrier since the application of the ACTION is addressed by Specification 3.0.2.

6.4 (Page 6-5) - TRAINING 6.4.2 Deleted the requirement that the Fire Brigade training (6.4.2) program meet or exceed the requirement of Section 27 of the NFPA Code-1976 and revised the requirement that the Fire j Brigade Training Program is under the direction of the l Nuclear Training Director rather than the Fire Marshall.

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Docket No. 50-346 {

License No. NPF-3 l

[' Serial 1446 j Attachment 1. I Page 3 j i

6.9.2 (Page 6-18) - SPECIAL REPORTS L 6.9.2 Deleted the requirement for Specification (6.9.2) 3.7.10 (Item g) and re-alphabetized the remaining items requiring special reports.

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Docket No. 50-346 License No. NPF-3 Serial 1446 Attachment 2 Page 1

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SAFETY EVALUATION l

1 INTRODUCTION AND SYSTEMS AFFECTED l This safety evaluation addresses proposed revisions to the following sections of the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specifications:

INDEX Fire Barriers >

3/4.7.10 Fire Barriers i B 3/4.7.10 Fire Barriers 6.4 Training 6.9.2 Special Reports FUNCTION OF SYSTEMS The function of fire barriers is to confine or adequately tetard fires from spreading to: a) adjacent fire areas containing nuclear safety-related equipment b) adjacent fire areas containing safe shutdown equipment required in the event of a fire c) portions of redundant safe shutdown systems required in the event of a fire within the same fire area. The fire barriers at Davis-Besse consist of fire-rated walls, floors and ceilings, electrical raceway enclosures, structural steel fireproofing, fire doors, fire dampers and penetrations seals.

REFERENCES Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specifications Davis-Besse Nuclear Power Station, Unit No. 1, Updated Safety Analysis Report, June 1986 NRC Generic Letter 86-10, Implementation of Fire Protection Require- 1 ments, dated April 24, 1986 (Log No. 1983) i i

NUREG-0103, Revision 4, Standard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors Palo Verde, Unit 1, Technical Specifications, Amendment No. O Fermi, Unit No. 2, Technical Specifications, Amendment No. O Rancho Seco, Unit No. 1, Technical Specifications, Proposed Amendment No. 137 Davis-Besse Appendix R Compliance Assessment Report, Revision 2 Davis-Besse Fire Hazard Analysis Report, Revision 8 s

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Docket No. 50-346 License No. NPF-3 j Serial 1446 Attachment 2 Page 2 Davis-Besse Fire Protection Strategy Procedures NUREG-0123, Rev. 3, Standard Technical Specifications for General Electric Boiling Water Reactors (BWR15)

NUREG-0452, Rev. 5, Standard Technical Specifications for Westinghouse Pressurized Water Reactors DESCRIPTION OF CHANGES The proposed changes to the Technical Specifications are administrative in nature, provide more stringent requirements or reflect the actual plant design and fire protection program based on actual or planned plant configuration and fire protection analyses. Examples of the adminis-trative changes include reformatting the Action Statements and Surveil-lance Requirements and clarification of specific equipment addressed by the proposed Technical Specifications. Examples of the more stringent requirements include the addition of Action Statements and Surveillance Requirements. Examples of thanges that reflect the actual plant design and fire protection program include defining inaccessible equipment and revising the scope of the Technical Specifications to address safe shutdown equipment required in the event of a fire.

The proposed Section 3/4 Technical Specifications refer to the fire protection barriers that protect redundant safe shutdown equipment required in the event of a fire.

The need to limit fire damage to systems required to achieve and maintain safe shutdown conditions in post-fire conditions is greater than the need to limit fire damage to those systems required to mitigate the conse-quences of design basis accidents since the loss of the design-basis-accident systems in post-fire conditions does not per se impact public safety. Consequently, those systems required to achieve and maintain safe shutdown conditions in post-fire conditions, rather than nuclear safety-related equipment, have been identified and evaluated for its availability in the event of a fire as documented in the Davis-Besse Appendix R Compliance Assessment Report (CAR). That equipment necessary to achieve and maintain safe shutdown conditions in post-fire conditions is termed in the proposed Technical Specification revisions as safe shutdown equipment required in the event of a fire. The fire barriers for each fire area identified in the CAR are addressed by the proposed Technical Specification revision since these barriers separate redundant safe shutdown equipment.

Toledo Edison intends to implement the guidance of NRC Generic Letter 86-10 which requeste that the Fire Protection Program and major commit-ments made in Operating Licenses and Technical Specifications be deleted and referred to in the Updated Safety Analysis Report (USAR). These proposed revisions to the Technical Specifications were developed in order to reflect the current plant design, testing and compensatory measures considered to be adequate and practical.

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-Docket No.'50-346 t- L,1cens0 No. NPF-3 Serial .446 Attachment 2  ;

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These proposed Technical Specification revisions were developed considering the current Davis-Besse plant design, recent audit findings, the B&W, Westinghouse and General Electric Standard Technical Specifications (STS) and Technical Specifications of recently licensed  !

nuclear plants. The. proposed revision to the Technical Specifications reflects the design of the plant to provide an appropriate means for ensuring compensatory measures are maintained for those fire areas addressed by the proposed Technical Specifications not in accordance with the previous Toledo Edison commitments.

UNREVIEWED SAFETY QUESTIONS The proposed changes are administrative in nature, provide more stringent requirements or reflect the actua1 plant design and fire protection program based on actual or planned plant configuration and fire protection analyses. Implementation of these proposed changes would not:  !

1. Increase the probability of occurrence or the consequence of an  !

accident or malfunction of equipment important to safety previously l evaluated in the Safety' Analysis Report (10CFR50.59 (a) (2) (1)) .

The proposed administrative changes would not increase the occurrence or consequence of an accident or malfunction of equipment previously evaluated because these changes would not affect the function, operation (including operational setpoints or parameters) or failure mode analysis of any system as described in the USAR.

The proposed changes that provide more stringent requirements would  ;

not increase the occurrence or consequence of an accident or malfunc- '

tion of equipment previously evaluated because these changes would increase the scope of the Technical Specifications, add restrictions, establish increased test frequencies and add Surveillance Requirements.

The proposed changes that reflect the actual plant design and fire protection program would not increase the occurrence or consequence of an accident or malfunction of equipment previously evaluated because the collective capability of the fire protection equipment and fire protection program has been increased based on plant modifications, administrative and procedure enhancements, and fire protection analysis in accordance with the requirements of 10CFR50, Appendices A (General Design Criterion 3) and R.

2. Create the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report (10CFR50. 59 (a) (2) (ii)) .

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. 4 Docket No. 50-346 License No. NPF-3

' Serial 1446 Attachment 2 Page 4 I

The proposed administrative changes would not create the possibility for an accident or malfunction of a different type than any i previously evaluated because these changes would not affect the

[ function, operation (including operational setpoints or parameters) or failure mode analysis of any system as described in the USAR. J t

l The proposed changes that provide more stringent requirements would

.not create.the possibility of an accident or malfunction of a.

different type than any previously evaluated because these changes would increase the scope of the Technical Specifications, add restrictions, establish increased test frequencies and aJd Surveil-lance Requirements.

The proposed changes that reflect the actual plant design and fire protection program would not create the possibility of an accident or malfunction of a different type than any previously evaluated because the collective capability of the fire protection equipment and fire protection program has been increased based on plant modifications, administrative and procedure enhancements, and fire protection analysis in accordance with the requirements of 10CFR50, Appendices A (General Design Criterion 3) and R.

3. Reduce the mcrgin of safety as defined in the basis for any Technical Specification (10CFR50.59(a)(2)(iii)) .

The proposed administrative changes would not reduce the margin of safety because theae changes would not affect the function, operation (including operational setpoints or parameters) or failure mode analysis of any system as described in the USAR.

The proposed changes that provide more stringent requirements would not reduce tne margin of safety because these changes would increase the scope of the Technical Specifications, add restrictions, establish increased test frequencies and add Surveillance Requirements.

The proposed changes that reflect the actual plant design and fire protection program would not reduce the margin of safety because the collective capability of the fire protection equipment and fire protection program has been increased based on plant modifications, administrative and procedure enhancements, and fire protection analysis in accordance with the requirements of 10CFR50, Appendices A (General Design Criterion 3) and R.

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

Docket No. 50-346 License No. NPF-3 Serial 1446 Attachment 3  ;

Page 1 l SIGNIFICANT RAZARDS CONSIDERATION INTRODUCTION AND SYSTEMS AFFECTED This License Amendment Request proposes revisions to the following sections of the Davis-Besse Nuclear Power Station; Unit No. 1 Operating License, Appendix A, Technical Specifications:

INDEX Fire Barriers 3/4.7.10 Fire Barriers B 3/4.7.10 Fire Barriers 6.4 Training 6.9.2 Special Reports FUNCTION OF SYSTEMS The function of fire barriers is to confine or adequately retard fires from spreading to: a) adjacent fire areas containing nuclear safety-related equipment b) adjacent fire areas containing safe shutdown equipment required in the event of a fire c) portions of redundant safe shutdown systems required in the event of a fire within the same fire area. The fire barriers at Davis-Besse consist of fire-rated walls, floors and ceilings, electrical raceway enclosures, structural steel fireproofing, fire doors, fire dampers and penetrations seals.

REFERENCES Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specifications Davis-Besse Nuclear Power Station, Unit No. 1. Updated Safety Analysis Report, June 1986 NRC Generic Letter 86-10, Implementation of Fire Protection Require-ments, dated April 24, 1986 (Log No. 1983)

NUREG-0103, Revision 4, Standard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors Palo Verde, Unit 1, Technical Specifications, Amendment No. O Fermi, Unit No. 2, Technical Specifications, Amendment No. O Rancho Seco, Unit No. 1, Technical Specifications, Proposed Amendment No. 137 Davis-Besse Appendix R Compliance Assessment Report, Revision 2 Davis-Besse Fire Hazard Analysis Report, Revision 8 l

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. . 1 Docket No. 50-346 License No. NPF-3 Serial 1446 Attachment 3 Page 2 Davis-Besse Fire Protection Strategy Procedures NUREG-0123, Rev. 3, Standard Technical Specifications for General Electric Boiling Water Reactors (BWR15)

NUREG-0452, Rev. 5, Standard Technical Specifications for Westinghouse Pressurized Water Reactors DESCRIPTION OF CHANGES The proposed changes to the Technical Specifications are administrative in nature, provide more stringent requirements or reflect the actual plant design and fire protection program based on actual or planned plant configuration and fire protection analyses. Examples of the adminis-trative changes include reformatting the Action Statements and Surveil-lance Requirements and clarification of specific equipment addressed by the proposed Technical Specifications. Examples of the more stringent requirements include the addition of Action Statements and Surveillance Requirements. Examples of changes that reflect the actual plant design and fire protection program include defining inaccessible equipment and revising the scope of the Technical Specifications to address safe shutdown equipment required in the event of a fire.

The proposed Section 3/4 Technical Specifications refer to the fire protection barriers that protects redundant safe shutdown equipment required in the event of a fire.

The need to limit fire damage to systems required to achieve and maintain safe shutdown conditions in post-fire conditions is greater than the need to limit fire damage to those systems required to mitigate the conse-quences of design basis accidents since the loss of the design-basis-accident systems in post-fire conditions does not per se impact public safety. Consequently, those systems required to achieve and maintain safe shutdown conditions in post-fire conditions, rather than Nuclear safety-related equipment, have been identified and evaluated for its availability in the event of a fire as documented in the Davis-Besse Appendix R Compliance Assessment Report (CAR). That equipment necessary to achieve

,and maintain safe shutdown conditions in post-fire conditions is termed in the proposed Technical Specification revisions as safe shutdown equipment required in the event of a fire. The fire barriers for each fire area identified in the CAR are addressed by the proposed Technical Specification revision since these barriers separate redundant safe shutdown equipment.

Toledo Edison intends to implement the guidance of NRC Generic Letter 86-10 which requests that the Fire Protection Program and major commit-ments made in Operating Licenses and Technical Specifications be deleted and referred to in the Updated Safety Analysis Report (USAR). These  ;

proposed revisions to the Technical Specifications were developed in order to reflect the current plant design, testing and compensatory measures considered to be adequate and practical.

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Docket No. 50-346 License No NPF-3 Serial 1446

. Attachment 3 Page 3 These proposed Technical Specification revisions were developed considering the current Davis-Besse plant design, recent audit findings, the B&W, Westinghouse and General Electric Standard Technical Specifications (STS) and Technical Specifications of recently licensed nuclear plants. The proposed revision to the Technical Specifications reflects the design of the plant to provide an appropriate means for ensuring compensatory measures are maintained for those CAR fire areas not in accordance with the previous Toledo Edtson commitments.

SIGNIFICANT HAZARDS CONSIDERATION The proposed changes are administrative in nature, provide more stringent requirements or reflect the actual plant design and fire protection  ;

pt,3rae unsed on actual or planned plant configuration and fire protec-tion analyses. Implementation of these proposed changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated (10CFR50.92(c)(1)) .

The proposed administrative changes would not increase the probab-ility or consequence of an accident previously evaluated because these changes would not affect the function, operation (including operational setpoints or parameters) or failure mode analysis of any system as described in the USAR.

The proposed changes that provide more stringent requirements would not increase the probability or consequence of an accident previously evaluated because these changes would increase the scope of the Technical Specifications, add restrictions, establish  !

increased test frequencies and add Surveillance Requirements.

Ihe proposed changes that reflect the actual plant design and fire protection program would not increase the probability or consequence of an accident presAously evaluated because the collective capability of the fire protection equipment and fire protection program has been increased based on plant modifications, administrative and procedure j enhancements, and fire protection analysis in accordance with the requirements of 10CFR50, Appendices A (General Design Criterion 3) and R. '

2. Create the possibility of a new or different kind of accident from any previously evaluated (10CFR50.92(c)(2)).

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License No. NPF-3 l Serial 1446' l Attachment 3 Fage 4 The proposed administrative changes would not create the possi-bility for an accident of a different type than any previously evaluated because these changes would not affect the function, operation (including operational setpoints or parameters) or failure mode analysis cf any system as described in the USAR.

The proposed changes that provide more stringent requirements would not create the possibility of an accident of a different type than any previously evaluated because these changes would increase the scope of the Technical Specifications, add restrictions, establish increased test frequencies and add Surveillance Requirements.

The proposed changes that reflect the actual plant design and fire protection program would not create the possibility of an accident of a different type than any previously evaluated because the collec-tive capability of the fire protection equipment and fire protection program has been increased based on plant modifications, administrative and procedure enhancements, and fire protection analysis in accordance with the requirements of 10CFR50, Appendices A (General Design Criterion ,

3) and R. I

3. Involve a significant reduction in a margin of safety (10CFR50.92 (c) (3)) .

The proposed administrative changes would not reduce the margin of safety because these changes would not affect the function, operation (including operational setpoints or parameters) or failure mode analysis of any system as described in the USAR.

The proposed changes that provide more stringent requirements would not reduce the margin of safety because these changes would increase the scope of the Technical Specifications, add restrictions, establish increased test frequencies and add Surveillance Require-ments.

The proposed changes that reflect the actual plant design and fire protection program would not reduce the margin of safety because the collective capability of the fire protection equipment and fire protection program has been increased based on plant modifications, administrative and procedure enhancements, and fire protection l analysis in accordance with the requirements of 10CFR50, Appendices A (General Design Crit >rion 3) and R.

CONCLUSION Based on the above evaluation, Toledo Edison has determined that the proposed Technical Specification revision does not involve a significant hazards consideration.

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