ML20207E664

Forwards Request for Addl Info Re Util 860306 Request for Exemptions from 10CFR50,App R Requirements & Util Fire Hazards Analysis Rept.Issues Where Util Technical Approach Not in Conformance W/App a to BTP Apcsb 9.5-1 Identified

ML20207E664
Person / Time
Site:	Davis Besse
Issue date:	12/17/1986
From:	Stolz J Office of Nuclear Reactor Regulation
To:	Williams J TOLEDO EDISON CO.
References
NUDOCS 8701020248
Download: ML20207E664 (7)

Text

, e-  :

December 17, 1986 -

~ Docket No. 50-346 Qlh Mr. Joe Williams, Jr.

Senior Vice President, Nuclear

. Toledo Edison Company Edison Plaza - Stop 712 300 Madison Avenue Toledo, Ohio 43652.

SUBJECT:

FIRE PROTECTION - REQUEST FOR ADDITIONAL INFORMATION By letter dated March 6, 1986, (no. 1255) Toledo Edison Company. submitted requests .for eleven exemptions from the technical requirements of Appendix R to 10 CFR 50. 0n the same date. (letter No. 1254) Toledo Edison Company also

j. submitted a Fire Hazards Analysis Report which includes a new comparison of

the plant fire' protection program to the guidelines contained in Appendix A to BTP APCSB 9.5-1. By letter dated June 3, 1986, (No. 1253) Toledo Edison submitted Revision 1 of the Appendix R Compliance Assessment Report.

In order to complete our evaluations of these submittals, we require

, . clarification on several issues as indicated.in the enclosed request for additional information. The enclosure' identifies a number of issues where Toledo Edison Company's technical approach is not in conformance with Appendix--

A to BTP APCSB 9.5-1 and which we cannot accept.

Please review the information contained in the enclosure. We suggest that a meeting be arranged within the next 60 days to discuss these issues, i

The reporting and/or recordkeeping requirements contained in this letter

affect fewer than ten respondents; therefore, OMB clearance is not required urder P.L.96-511.

Sincerely, r

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07oto2 A g g M hPDR 46 John F. Stolz, Director PWR Project Directorate #6 L PDR l F Division of PWR Licensing-B t

Enclosure:

Request for Additional-Information l cc w/ enclosure:

See next page Distribution

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Mr. J. Williams Davis-Besse Nuclear Power Station Toledo Edison Company Unit No. I cc:

Donald H. Hauser, Esq. Ohio Department of Health l The Cleveland Electric ATTN: Radiological Health Illuminating Company Program Director P. O. Box 5000 P. O. Fox 118

, Cleveland, Ohio 44101 Columbus, Ohio 43216 Mr. Robert F. Peters Attorney General

- Manager,-Nuclear-Licensing - -

Department-of Attorney _ _ _ _

Toledo Edison Company General Edison Plaza 30 East Broad StrE&t 300 Madison Avenue Columbus, Ohio 43215 Toledo, Ohio 43652 Mr. James W. Harris, Director Gerald Charnoff, Esq. (Addressee Only)

Shaw, Pittman, Potts Division of Power Generation and Trowbridge Ohio Department of Industrial Relations 2300 N Street N.W. 2323 West 5th Avenue Washington, D.C. 20037 P. O. Box 825 Columbus, Ohio 43216 Mr. Paul M. Smart, President Mr. Harold Kohn, Staff Scientist Toledo Edison Company Power Siting Commission 300 Madison Avenue 361 East Broad Street Toledo, Ohio 43652 Columbus, Ohio 43216 Mr. Robert B. Borsum President, Bnard of Babcock & Wilcox County Comissioners of Nuclear Power Generation Ottawa County Division Port Clinton, Ohio 43452 Suite 200, 7910 Woodmont Avenue - .

Bethesda, Maryland 20814 ' State of Ohio Public Utilities Comission Resident Inspector 180 East Broad Street U.S. ' Nuclear Regulatory Ccani.ssion Columbus, Ohio 43266-0573 5503 N. State Route 2 Oak Harbor, Ohio 43449 Regional Administrator, Region III U.S. Nuclear Regulatory Comission 799 Roosevelt Road Glen Ellyn, Illinois 60137

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REQUEST FOR ADDITIONAL INFORMATION DAVIS BESSE NUCLEAR POWER STATION, UNIT NO. 1 Appendix R Exemption Requests

1. Where credit is taken for manual actions to achieve safe shutdown, provide ~

the time limit and basis to accomplish the action before an unrecoverable plant condition occurs.

2. Provide justification for the. contention that a standard fire-rated barrier annot be installed to separate redundant circuits in Fire Area DA.

3. Justify why one train of control room emergency ventilation system cables cannot be protected in lieu of evacuating the control room for a fire in area HH.

4. Justify the use of hand-held Ifghts for accomplishing safe shutdown. Such use is not consistent with staff guidance or past precedent except for access and egress routes in outdoor areas.

Fire _ Hazards Analysis Report (FHAR)

5. Regarding Table 4-1, Sheet 1. explain the difference between the response

" Comply'and" Position (comply)." It appears that the latter response significs nonconformance. This table should be revised to clearly specify where deviations from our guidelines exist. Appropriate justification for such deviations should be provided in the FHAR.

! 6. Regarding Table 4-1. Sheet 4, except for t$e Turbine Building, identify any location (s) where sprinkler systems and standpipe systems are supplied from a single water supply pipe and describe how "back-up" fire fighting capa-bility will be provided if a failure in this pipe occurs?

7. Regarding Table 4-1. Sheet 8. describe how pre-fire plans have been modified to incorporate audit findings. (Reference meeting summary dated j February 1, 1984).

j 8. Regarding Table 4-1, Sheet 15, confinn that you comply with the referenced staff guidance on fire protection program functional responsibilities.

l 9. Regarding Table 4-1, Sheet 24, confirm that bus ducts, seismic gaps and l

spare conduit sleeves are sealed with fire-rated material equivalent to the

! rating of the fire barrier in which they are located.

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10. Describe how security modifications have affected the rating of fire-doors.

11. Regarding Table 4-1. Sheet 25, provide your response to the September 9, 1986 telecon concerning the adequacy of fire barrier penetration seal tests.

.12. Regarding Table 4-1, Sheet 32, provide. the.results of the Kaowool qualifi-cation fire test. Provide a discussion / description as to how cable tray /

conduit support steel _as well as other metal features which are framed into the fire barrier are protected.

13. Regarding Table 4-1, Page 33, describe how seals around metal penetrations of fire barriers confonn with the protected side temperature limits of ASTM E-119,

14. Regarding Table 4-1. Page 35, describe how smoke is vented from a fire area so as to avoid damaging unexposed redundant shutdown systems.

15. Describe how you have confirmed that fire dampers will close under ambient air conditions (Reference 10 CFR Part 21 notification concerning Ruskin dampers).

10. Regarding Table 4-1, Page 39, confirm:that charcoal in unsprinklered filter units has been considered in the fire hazards analysis.

17. Regarding Table 4-1 Page 46, describe how the adequacy of radio comuni-cation has been verified with regard to structural interference and joint use by the fire brigade.

18. Regarding Table 4-1 Page 49, confirm that visual and audible alanns are transmitted to the control room from e.very fire / smoke alarm initiating device.

19. Confirm that fire detectors are installed per the guidelines of NFPA Standard No. 72E.

20. Regarding Table 4-1, Page 61, provide justification for the sprinkler l

system installation deviations from the guidelines in NFPA Standard No. 13.

! (Reference IE Inspection Report 50-346/83-16(DE)).

21. Regarding Table 4-1, Page 74, the licensee's assumption of limited fire spread / damage in the control room does not conform with the criteria of Appendix R to 10 CFR 50. In all areas including the control room, the l

licensee should assess the adequacy of fire protection on the basis that all cables and components within the fire area are damaged, except where l

systems within the fire area are protected per Section III.G.2 of l Appendix R or by an alternate level of protection that the staff has

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specifica My reviewed-and-4 par.qyaA

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Appendix R Compliance Assessment Report (General Sections)

22. Provide a " simplified" flow chart which shows the interrelationships of identified components necessary to achieve safe shutdown.

23. Regarding Page 3-6, confim that shutdown procedures are based on the assumption that. fire induced failures cause components to- assume their r 2mog d_etrimental-position. -- r -- ---.

24._ Regarding Page 3-12, provide justification that reactor coolant pump seal injection and cooling via the component ' cot) ling water system is not necessary.

25. Your current submittal states that it will take "approximately 277 hours0.00321 days <br />0.0769 hours <br />4.580026e-4 weeks <br />1.053985e-4 months <br />" to reach cold shutdown. This appears to be a change from previous statements that predicted 193 hours0.00223 days <br />0.0536 hours <br />3.191138e-4 weeks <br />7.34365e-5 months <br /> as indicated in your letter No.1124, dated February 4,1985 regarding natural circulation cooldown.

Provide justification for this charge. Describe any changes in the equip-ment needed for safe shutdown, safe shutdown procedures, and methods of computation.

26. Provide a discussion regarding how you are addressing the concerns expressed in to IE Information Notice 86-79.

27. Regarding Page 3-21, confim that all emergency diesel engine auxiliary systems have been analyzed for Appendix R conformance.

28. Regarding Page 4-2, describe how valve operators have been protected from fire damage.

29. Regarding Page 5-6, .the assumption that fire damage to' three phase AC power cables will not result in a spuriously e'n'ergized cable is unacceptable when applied to the analysis of high-low pressure interfaces. Revise your response to address protection of high-low pressure interfaces accordingly.

30. Regarding Page 5-/, provide the basis for concluding that representative circuits will not spuriously actuate.

31. The information provided has not specifically addressed the associated circuits concerns / findings of the Se detailed in report 50-346/83-16 (DE)ptember 1983, Appendix Provide a description as to howR audit as the associatcJ circuits review methodology, results, and corrective action has responded to these issues. (Reference findings: 346/84-16-01B and 346/83-16-08).

32. Regarding Page 7-6, provide a status of the technical specifications revi-sions referenced on this page. , w _-- m#

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33. Regarding Pages 7-7 and 7-8 the information in this section has not specifically ac' dressed the staff's previous concerns regarding the adequacy of the alternate shutdown capability as described in the above referenced inspection report and in the safety evaluation pertaining to

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interim measures, dated September 23, 1983. Provide a response which includes the information required for staff review of alternate shutdown capabilities as delineated in the clarification to Generic Letter 81-12, (Reference findings: 346/83-16-02 and 346/83-16-01A).

Fire Area Review

34. Regarding Page 4.A-5, we' are concerned about potential confusion resulting frca the reliance on both Train 1 and Train 2 shutdown systems for a fire

- ~ ~ - . in Area A._ Describe how shutdown procedures _ make it_ clear to the _

operators which systems will be available for a fire in this area.

35. Regarding Page 4.A-12 (and others), are all of the circuits which are relied upon for safe shutdown located in Room 1247 (ReferenceNotes: 2, 3, 4, 8, 9,11,18,19, 20, 21, 22, 23, 26, 40, and 42) .

36. Regarding Page 4.A-14, justify the contention that output from SG1-1 is sufficient to run the AF14 Pump Turbine 1-1, even if valve MS107A was open.

37. Regarding Page 4.A-19, state whether the circuit associated with component S33-1 is located outside of the fire area as stated in Appendix B-1 or within the area as stated in the narrative.

38. Regarding Page 4.A-26, confirm that the shutdown procedures , stipulate that the HPI system shall be used to shutdown the plant for a fire in Area A.

39. Regarding Page 5.A-8, considering that cables for both shutdown divisions are located in Area A and that reliance is placed on 35 feet of spatial separation, justify why the cable chasd is unsprinklered (fire load of 655,000 BTU's/sq.ft.).

40. .Regarding Page 4.A8 14, state whet h er th e.por at ble fans used for alternate shutdown are the same fans relied upon by the fire brigade for post-fire salvage / overhaul activities or are dedicated for shutdown operations.

41. Regarding Page 4.AB-15, provide details . describing the installation of ground-fault protection to preclude multiple high impedance faults.

42. Regarding Page 4.BN-4, sufficient justification has not been provided to

- accept the use of an offsite fuel oil supplier to compensate for the loss of the redundant fuel oil transfer pumps. The licensee should propose protection to assure that one fuel oil transfer pump train remains free of fire damage.,

43. Regarding Fire Areas D/DA, provide details describing the radiant energy-shield used to protect vulnerable circuits.

44. RegardidFireArisi"'DD/FF7provideacopyofrevisedprocedureAB 1203.26 l~ - (post September 1983 procedure).

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45. Regarding Pane 4.00-40 (and others), cnnfirm that the desian and installation of isolation switches and redundant fuses will conform with the criteria established in Generic letter 81-12.

46. Regarding page 4.00-41, justify the lack of a commitment to install isolation devices 'or circuit ICAC103A, as was done for other previously unisolated hot shutdown circuits.

47. Regarding Page 4.00-56, the lack of RCS Loop I cold leg temperature indication as part of post-fire alternate shutdown instrumentation represents an unjustified nonconformity with Section III.L of Appendix P.

This condition also fails to r,espond_to e concerns / findings'of the J ppendix R audit team as described in the previously referenced report.

48. Regardinf Patfe- t FF-77 fa h fire-in the control room, describe the actions within the control: room that are being relied upon to achieve and maintain safe shutdown prior to control room evacuation.

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